Lemonmedia OÜ., together with its subsidiaries and its affiliated businesses, offers a digital media platform that allows content creators to monetize content by allowing us and these content creators to show advertisements on such content. We refer to these content creators as “Partners” and to the websites and apps that participate in our coalition as “Partner Content.”
This Privacy Policy explains how Lemonmedia OÜ collects, uses, and discloses information about you when you visit our websites and Partner Content, open an account or publish content with us, contact our customer service team, engage with us on social media, or otherwise interact with us. We collectively refer to these touchpoints as our “Services.”
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access our Services or otherwise interact with us to stay informed about our information practices and the choices available to you.
COLLECTION OF INFORMATION
INFORMATION YOU PROVIDE TO US
ACCOUNT INFORMATION
If you wish to use the Services, such as to create or post content, comment on other people’s content, or post your own content to Partners’ content, or if you wish to receive updates or newsletters from us or from our Partners, you may be required to create a Lemonmedia OÜ account. When you create an account or use our Services, we may ask you to provide certain personally identifiable information such as your first and last name, email address, telephone number, address, and card payment information (collectively, “Personally Identifiable Information”). We may also ask for information such as a profile picture or your social profile information. If your content is supported by advertising or paid subscriptions, we also collect your payment information to allow us to pay you in accordance with your agreement with us.
OTHER INFORMATION
We also collect any other information you provide directly to us. For example, we collect information when you participate in any interactive features of the Services, fill out a form, participate in a contest or promotion, make a purchase, apply for a job, communicate with us via third party social media sites, request customer support, or otherwise communicate with us.
INFORMATION ABOUT YOUR USE OF THE SERVICES
INFORMATION YOU POST
We collect information about the content you post, including any articles, comments, or interaction with other users’ content. We also collect information about how you use the Services, including the Partner Content you view and follow, and how you interact with Partner Content.
AUTOMATICALLY COLLECTED DATA
When you access or use our Services, we automatically collect certain technical information, including:
- Log and Usage Information: We collect information related to your access to and use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
- Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
- Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers and Partners) use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness.
INFORMATION WE COLLECT FROM OTHER SOURCES
We may also obtain information about you from other sources. For example, we may collect information about you from third parties, including but not limited to identity verification services, credit bureaus, mailing list providers, and publicly available sources. Additionally, if you create or log into your account through a social media site or third-party service (like Facebook or Google), we will have access to certain information from that service, such as your name, email address, and profile picture, in accordance with the authorization procedures determined by such social media site or third-party service.
USE OF INFORMATION
We use the information we collect to provide our Services and to customize your experience with the Services, including showing content and advertising that we think is likely to be of interest to you. We also use the information we collect to:
- Communicate with you about products, services, and events offered by Lemonmedia OÜ and others, and provide news and information we think will be of interest to you;
- Monitor and analyze trends, usage, and activities in connection with our Services;
- Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Lemonmedia OÜ and others;
- Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards; and
- Carry out any other purpose described to you at the time the information was collected.
SHARING OF INFORMATION
When you subscribe to or “follow” one of our Partners, or if you comment or post content on one of our Partner’s pages, you will be providing your username and email address to Lemonmedia OÜ as well as to that Partner, who may use such information to contact you and otherwise use and disclose your personal information in accordance with its privacy policy. We will not share your identifying information (such as your name, email address, address or phone number) with Partners in our coalition except where you decide to provide that information to the Partner, ask us to share it with them, or consent to our sharing it with them.
To allow Partners to earn advertising from their content, we share identifiers that do not identify you personally but may identify your browser or device with Partners and advertising partners as described in the “Advertising and Analytics Services Provided by Others” section below. Our Partners may also collect their own identifiers for these purposes.
We may also share the information we collect as follows:
- With vendors, service providers, and consultants that perform services for us, including email providers, IT service providers, and web hosting providers;
- In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
- If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Lemonmedia OÜ, Partners, or others;
- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
- Between and among our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership, and;
- With your consent or at your direction.
We may also share aggregated information that cannot reasonably be used to identify you.
THIRD-PARTY LINKS AND SERVICES
The Services may contain links to third-party websites such as social media sites, and also contain third-party plug-ins and functionalities (such as the Facebook “like” button and Twitter “follow” button). If you choose to use these sites or features, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.
ADVERTISING, ANALYTICS, AND IDENTITY SERVICES PROVIDED BY OTHERS
We and our Partners may allow others to provide analytics services and serve advertisements on our or their behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your visits to websites that use our Services, Partner Content, and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Lemonmedia OÜ, Partners, and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity.
TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES
Lemonmedia OÜ is based in Estonia and we process and store information in Estonia and other countries. Therefore, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. By using the Services or providing personal information to us, you consent to the transfer of your personal information to Estonia and other countries that may not provide equivalent levels of data protection as your home jurisdiction.
YOUR CHOICES
COOKIES
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
PROMOTIONAL COMMUNICATIONS
You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
If you wish to opt out of receiving promotional communications from a Partner, you may do so by following the instructions provided by the Partner.
CHILDREN’S PRIVACY
We do not knowingly collect personal information from children under 13 and do not allow Partners to host content with us that is intended for children under 13 to participate in our platform. If you are the parent or legal guardian of a child under 13 who provided personal information to us, please contact us at info@lemonmedia.io.
INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA OR SWITZERLAND
If you are in the European Economic Area (“EEA”) or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data. Note that Lemonmedia OÜ is the controller of your personal data when collected in the EU, but that Partners also act as data controllers for the personal data that we share with them and any personal data that Partners may collect independent of our relationship with them. If you have any questions about the processing of your personal data by a Partner, you should contact the Partner directly.
LEGAL BASIS FOR PROCESSING
If you are in the EEA or Switzerland, when we process your personal data we will only do so in the following situations:
- We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the products or services you have requested).
- We have a legitimate interest in processing your personal data. For example, we may process your personal data to provide, secure, and improve our products and services and to communicate with you about our services.
- Such processing is necessary to comply with our legal obligations.
- We have your consent to do so. When consent is the legal basis for our processing, you may withdraw such consent at any time.
DATA SUBJECT REQUESTS
You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights you may contact us at info@lemonmedia.io.
DATA RETENTION
We store the information we collect from you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
QUESTIONS OR COMPLAINTS
If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your Data Protection Authority, please see:
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Last Updated: January 1, 2021
This Privacy Notice for California Residents supplements the information contained in Lemonmedia OÜ Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Privacy Notice.
INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
USE OF PERSONAL INFORMATION
We may use, share/sell, or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide, support, personalize, and develop our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses.
- To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email, phone, or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
SHARING PERSONAL INFORMATION
We may disclose your personal information to a third party for a business purpose or share/sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We may share your personal information with the following categories of third parties:
- Service providers.
- Partners. “Partners” are third-party content creators and publishers
YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
DELETION REQUEST RIGHTS
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you with a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
OTHER CALIFORNIA PRIVACY RIGHTS
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request or for questions regarding our Notice for California Residents, please send an email to info@lemonmedia.io.
PRIVACY NOTICE FOR NEVADA RESIDENTS
Although we do not “sell” “covered information” of Nevada “consumers” as those terms are defined under Chapter 603A of the Nevada Revised Statutes, you may contact us by sending an email to info@lemonmedia.io and registering your email address so that we can provide you notice in the event we should do so in the future. At that future point, you will then have an opportunity to exercise your opt-out rights under that law subject to our verification. You can contact us via info@lemonmedia.io if you need to subsequently update your contact email for such notices. If you change your email address elsewhere in our Services, that change will not update your Nevada notice contact information. It is your responsibility to keep your Nevada notice contact information current.
