Privacy Policy

Privacy Policy

Updated on May, 2018

Pulpo Privacy Policy

This website is owned or managed by Pulpo Media, Inc., an Entravision company, and Luminar Insights (together referred to in this Privacy Policy as “Pulpo”, the “Company”, “us,” “our,” and “we”). As part of the Company’s services, we deliver advertisements from various advertisers across a network of online and mobile websites and applications that are owned or operated by us, our affiliates or third parties with whom we do business (“Sites”). For more information about the Company and our services, please see our websites at www.pulpo.com.

This Privacy Policy covers the information that we collect from your interactions with us on the Sites and our practices for collecting, using, maintaining, protecting, and disclosing that information, including for the purposes of online behavioral advertising. Online behavioral advertising, or interest-based advertising, generally refers to the collection of information online for the purpose of delivering advertising based on the interests of consumers. To learn more about online behavioral advertising, please visit the Digital Advertising Alliance website at www.aboutads.info/consumers/.

This Privacy Policy applies to the services offered by Pulpo, including the Sites, mobile services and any other features, content, services, or applications offered from time to time by Pulpo in connection with the Sites (collectively, the “Services”). This Privacy Policy does not apply to information collected by us offline or through any other means, including on any other website operated by Pulpo that does not link to this Privacy Policy. This Privacy Policy does not apply to additional information that we collect from other sources.

We provide this Privacy Policy to explain the type of information we collect and also to inform you of the specific practices and guidelines that protect the security and confidentiality of your personal data. Please read this Privacy Policy carefully. Please note that this Privacy Policy is incorporated into our Terms of Use, which also applies when you visit or use Services related to our Sites. If any term in this Privacy Policy is unacceptable to you, please do not use the Sites or provide any personal data. By accessing or using the Sites or the Services, you signify your acknowledgment of this Privacy Policy and consent to our practices as described herein.

This Privacy Policy may change from time to time. Visiting the Sites or using our Services after we make any changes to this Privacy Policy will be considered to be an acceptance of and consent to those changes. Please check this Privacy Policy periodically for updates. If Pulpo materially changes its practices regarding collection or use of your personal data, your personal data will continue to be governed by the Privacy Policy under which it was collected unless you have been provided notice of, and have not objected to, the change.

We adhere to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising and the Code of Conduct of the Network Advertising Initiative (NAI). This website is owned or managed by Pulpo Media, Inc., an Entravision company, and Luminar Insights (together referred to in this Privacy Policy as “Pulpo”, the “Company”, “us,” “our,” and “we”). As part of the Company’s services, we deliver advertisements from various advertisers across a network of online and mobile websites and applications that are owned or operated by us, our affiliates or third parties with whom we do business (“Sites”).

For more information about the Company and our services, please see our websites at www.pulpo.com.

This Privacy Policy covers the information that we collect from your interactions with us on the Sites and our practices for collecting, using, maintaining, protecting, and disclosing that information, including for the purposes of online behavioral advertising. Online behavioral advertising, or interest-based advertising, generally refers to the collection of information online for the purpose of delivering advertising based on the interests of consumers. To learn more about online behavioral advertising, please visit the Digital Advertising Alliance website at www.aboutads.info/consumers/.

This Privacy Policy applies to the services offered by Pulpo, including the Sites, mobile services and any other features, content, services, or applications offered from time to time by Pulpo in connection with the Sites (collectively, the “Services”). This Privacy Policy does not apply to information collected by us offline or through any other means, including on any other website operated by Pulpo that does not link to this Privacy Policy. This Privacy Policy does not apply to additional information that we collect from other sources.

We provide this Privacy Policy to explain the type of information we collect and also to inform you of the specific practices and guidelines that protect the security and confidentiality of your personal data. Please read this Privacy Policy carefully. Please note that this Privacy Policy is incorporated into our Terms of Use, which also applies when you visit or use Services related to our Sites. If any term in this Privacy Policy is unacceptable to you, please do not use the Sites or provide any personal data. By accessing or using the Sites or the Services, you signify your acknowledgment of this Privacy Policy and consent to our practices as described herein.

This Privacy Policy may change from time to time. Visiting the Sites or using our Services after we make any changes to this Privacy Policy will be considered to be an acceptance of and consent to those changes. Please check this Privacy Policy periodically for updates. If Pulpo materially changes its practices regarding collection or use of your personal data, your personal data will continue to be governed by the Privacy Policy under which it was collected unless you have been provided notice of, and have not objected to, the change.

We adhere to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising and the Code of Conduct of the Network Advertising Initiative (NAI).

TYPES OF INFORMATION WE COLLECT AND HOW WE COLLECT IT

We collect several types of information from and about users of our Sites, which may include information defined as personal data or personally identifiable information under an applicable law (“Personal Data”). For example, we may collect information such as your name, birth date, gender, county, zip code, e-mail address, telephone number, address, job title, company/organization name, current supplier status, social media credentials (including profiles when you subscribe to specific websites), and information related to inquiries and requests. We also may collect information about the internet connection and equipment you use to access our Sites. As you navigate through the Sites, we may automatically collect information such as your usage details, IP addresses, and information collected through cookies.

Information You Give to Us. The information we collect on or through our Sites may include:

Information you voluntarily provide when submitting an order form or other request to receive information, products, or Services on our Sites or a third party website or platform. The order form will ask you to give us contact information (like name or email address), financial information (like account or credit card numbers), and demographic information (like zip code or age).

Information you submit to us when/if you get in touch with our customer service, technical, or legal team, or any other employee at Pulpo, via contact form, email, chat or through other means.

Information you provide when you download any software or application made available to view and/or download in connection with Services that is owned or controlled by Puplo and/or its licensors, affiliates and suppliers.

Information you provide us for registering for or using any of our Services.

Information that you provide by filling in forms and applications on our Sites, including your username, password, your name, birth date, gender, county, zip code, e-mail address, telephone number, address, job title, company/organization name, current supplier status, social media credentials (including profiles when you subscribe to specific websites), and information related to inquiries and requests.

Information you provide when interacting with one of our Services, including participating or communicating in any public chat rooms, blogs, forums, message boards, news groups, or any form of communication in connection with the Sites. Please note that submitting an online comment is public and generally accessible to, and may be collected and used by, third parties. Pulpo is not liable for the distribution of your Personal Data that is put on a public forum.

Information given to us when you apply for career opportunities through the Sites. If you choose to apply online with Pulpo, Pulpo will collect any Personal Data provided in your application materials, for the purposes of reviewing and responding to your application, if appropriate.

Information you provide when signing up for newsletters and other types of informational material when you inquire about products, technical support, and customer service; and when you provide feedback about our Sites.

Records and copies of your correspondence with us (including e-mail addresses).

Information that you provide us by voluntarily conducting an online survey, contest, sweepstakes, or other online promotional activity administered by us. These activities may ask you for contact information (like name or email address) and demographic information (like zip code or age).

Information you provide us when you request information about an offer advertised through our network.

Information you provide us when you enter into a transaction through an offer delivered through our network or Sites.

Information you provide us when you request services from advertisers on whose behalf we provide fulfillment services or place online advertisements.

If you give us the Personal Data of a third party, you represent that you have provided notice to, and received authorization to provide such information from, that third party. Please note that in some cases, if you choose not to provide Personal Data you may not be able to engage in these services.

Information We Collect About You. As with many other websites, as you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Information about your computer and internet connection, including your IP address, operating system, host domain, and browser type. This may include data considered to be Personal Data in some jurisdictions, such as IP address or Device ID.

Details of your visits to our Sites, including the resources that you access and use on our Sites, traffic data, location data, logs, language, date and time of access, frequency, and other communication data.

Details of referring websites (URL).

The information we collect automatically is statistical data that helps us improve our Sites and deliver a better and more personalized service, including by enabling us to:

Determine website traffic patterns.

Count web visits.

Manage and improve the Services.

Track usage.

Conduct security and monitoring practices.

Determine traffic sources so we can measure and improve the performance of our Sites.

Help us to know which pages and content are the most and least popular.

Observe website search patterns to provide more intuitive navigation cues.

Determine the frequency of user visits and last date of visit.

We may share this information, and other non-Personal Data, with advertisers or other third parties that are not part of the Pulpo family on an aggregate or other basis that does not disclose your identity or contact information. We may also obtain Personal Data and make it Non-Personal Data by, for example, removing personally identifiable elements (such as your name) or by aggregating Personal Data with information about other individuals in order to “anonymize” or “de-identify” the information. We may also augment the Personal Data and Non-Personal Data we collect with information from other sources, including, for example, zip code, age, gender, language preference or income range in order to generate aggregate information that reflects activities, habits, preferences, or interests about our users as a group. We do not knowingly collect, use or share any financial account numbers or social security numbers for purposes of online behavior advertising without your specific consent.

How we use your information

Pulpo will only use your Personal Data you provide in a manner that is consistent with this Privacy Policy. If Pulpo obtains Personal Data from a third party, such as a business partner, our use of that information is also governed by this Privacy Policy. To enhance Pulpo’s ability to tailor the Sites to your preferences, we may combine information that you provide us on registration and other online sign-up forms with other information about you that we may obtain. Except where it is required by law, we may use non-Personal Data without restriction.

Below please find information about how we process information collected about you (including Personal Data). We may process information about you, including Personal Data, where the processing is:

Necessary to personalize your experience. We may use the Personal Data you give us to better tailor your Sites experience to your interests, and to send you information about Pulpo and its Services as well as promotional material on behalf of some of our partners. We use other information, including Personal Data, that you provide to us to show you content in which you may be interested and to display the content according to your preferences. We will also share this information within the Pulpo family in order to enhance your experience on the Sites and other Pulpo websites.

Necessary to advertise and market products and services of third-parties outside Pulpo with whom we do business (“Business Partners”), including to present content that is tailored to your interests, including online behavioral advertising and to analyze the effectiveness of advertising, promotions, and offers.

Necessary to conduct research and analysis, product development and reporting, including to better understand our audience; produce data analytics, statistical research, and reports; and to review and change our products and services.

Required by law.

Necessary to provide access to certain features on the Sites and receive information suited to their interests.

Necessary to contact you with information about the Pulpo family and promotional material on behalf of some of our partners, and to contact you when necessary.

Necessary to administer our Sites, help diagnose problems with our servers, to analyze trends, to track users’ webpage movements, to help identify you and your shopping cart, and to gather broad demographic information for aggregate use.

Necessary for us to comply with a legal obligation.

Necessary for entering into or the performance of a contract with you. For example:

To carry out our obligations arising from any contracts entered into between you and us.

To provide you with the information, products, and Services that you request from us.

To process your supplier application and registration form, and to create online accounts for your organization and its authorized agents.

To communicate with you about our contracts or your account.

Necessary for the purposes of the legitimate interests pursued by a third party or us (to the extent it does not infringe on any data subject’s fundamental rights and freedoms). For example:

To make sure that content from our Sites is presented in the most effective manner for you and for your computer.

To allow you to participate in interactive features of our Sites and Services (when you so choose).

To keep our Sites safe and secure (for example, security protection and fraud prevention).

To provide you with technical support and to improve our Sites and Services.

To provide you with information that you have requested and respond to your inquiries.

To notify you about changes to our Services or our Sites.

To manage our everyday business needs, such as auditing, administration of our Services, analytics, and the enforcement of any corporate reporting obligations, or other policies.

Necessary to investigate and enforce, if necessary, a user’s legal requests, including, but not limited to, potential copyright or intellectual property infringements.

Pursuant to valid consent provided by you, in order to provide you with information about goods or Services we feel may interest you. If you do not want us to use your Personal Data in this way, simply do not opt-in when we ask for your consent on the relevant forms where we collect your data.

Allowed for any other purpose where you have provided valid consent where it is legally required.

disclosure of your information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. Anonymous click stream, number of page views calculated by web beacons, and aggregated demographic information may also be shared with Pulopo’s advertisers and business partners. Subject to applicable law and regulations, we may disclose Personal Data that we collect or you provide as described in this Privacy Policy:

When you provide any Personal Data to any of our “special relationships” that are not owned by Pulpo. These special relationships may include “powered by” partners, business partners, sponsors, and co-branded sites (referred to here as “co-branded pages”). These might include, for example, pages that share our name and that of another entity, such as TicketMaster. You should look for a specific Privacy Policy on any such co-branded page. Any Personal Data that you provide when signing up at one of those co-branded pages may be shared with our third party partner. Check our partners’ websites for information regarding their privacy policies.

When you apply on the Sites for a job, we may, in our sole discretion, forward the information you submit to our parent, subsidiaries and affiliates for legitimate business purposes.

To companies that are affiliated with Pulpo, that is, are controlled by, or under common control with, Pulpo.

Subject to applicable law and regulations, if the Pulpo Sites is sold to, or merges with, another company not owned by Pulpo, you should expect that some or all of your Personal Data collected from the Sites may be transferred, sold to, or assigned to the buyer/surviving company. If so, Pulpo will seek to obligate the acquiring company to use any Personal Data transferred by the Pulpo Sites in a manner consistent with this Privacy Policy, but cannot guarantee that it will be able to impose that requirement or that the acquiring company will comply.

To companies that are affiliated with us, that is, are part of Pulpo.

To our Business Partners so that they may market and advertise their products and services, administrate and manage transactions and relationships with audiences, and personalize user experiences for audiences.

To advertisers and business partners that are not affiliated with Pulpo, but would like to send you information about their products and services. For example, some of the companies who supply prizes for Pulpo’s contests may have special offers or promotions that might be of interest to users of the Pulpo Sites. We will not share your Personal Data with such third parties without your permission.

To perform tasks (such as order fulfillment and payment processing) required to complete purchases you make through Pulpo. Pulpo must disclose your credit card information with such third-parties to complete any payment transaction on our Sites.

To third parties who assist us in operating our Sites, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.

For any other purpose disclosed by us when you provide your information or with your consent when required by applicable law and regulations.

To enforce or apply our Terms of Use and/or other agreements, including for billing and payment collection purposes, or to protect the rights, property, or safety of Pulpo or our customers, or others. This may include an exchange of information, including your Personal Data, to other companies and organizations for the purposes of fraud protection and credit risk reduction.

With outside contractors, vendors, or agents who help us manage our information activities (i.e., message boards, sweepstake administration, order fulfillment, sweepstakes and prizes, storage, market research, reporting, hosting, technical support, statistical analyses, data processing, and other purposes), or with outside contractors, agents, vendors, or sponsors who help us with administration, judging and prize fulfillment aspects of contest, promotions, and sweepstakes. These outside contractors, agents, vendors, or sponsors may only use your Personal Data to provide Pulpo with a specific service and not for any other purpose without your consent. Pulpo may only provide your Personal Data to a third party in those instances where you have chosen to receive certain information and have been notified that the fulfillment of such a request requires the sharing of your Personal Data.

With third parties where you have chosen to receive certain information and have been notified that the fulfillment of such a request requires the sharing of your Personal Data.

With third parties who help us customize our advertising and marketing messages you receive on our Sites, or may work with outside companies to do so. Your non-Personal Data may be shared with these companies so this customization can be accomplished. Pulpo prohibits these companies from sharing your information with any third party or from using it for any purpose other than targeting advertising.

To protect the safety or security of individuals, such as to: (1) comply with the law or legal process or cooperate with law enforcement; (2) protect the safety and security of users or members of the public; (3) protect or defend the legal rights of the Company, its employees, agents, advertisers, publishers or other contractors (including enforcement of agreements); (4) protect against fraud or for risk management purposes; (5) protect or enforce our Sites policies; or (6) protect the rights, property or safety of the Company or the public. Except where required by law, we may share non- Personal Data in other ways without restriction.

With third-parties regarding specific registration modules, like survey, contests or sweepstakes. We will post a conspicuous statement on the registration module to the effect that we will be sharing with third parties the Personal Data and information collected.

When necessary to support certain functions and features of our Sites. For example, this may occur at a feature that enables you, via our Sites, to ask questions of persons or entities that are not part of the Pulpo family. By responding to those features of the Sites, whether by email or direct entry of information on our Sites, you are consenting to our transferring that information to such persons or entities.

To comply with the law or a legal process, such as a court order or any regulatory proceeding.

JURISDICTION AND CROSS-BOARDER TRANSFERS OF PERSONAL DATA

The Sites and Services are intended for use in North America and Latin America. The data that we collect from you will be transferred to, and stored and processed in, the United States. Please note that the data protection and privacy laws of the United States may not be as protective as the laws in your country.

We will take all steps reasonably necessary to ensure that your data is treated securely and subject to appropriate safeguards in accordance with this Privacy Policy and applicable legislation.

data security

Pulpo employs commercially reasonable security measures consistent with standard industry practice for information collected through the Sites. We believe that we have adequate security measures in place in our physical facilities to protect against the loss, misuse, or alteration of the information we collect on our Sites. We also use internal protections to limit access to users’ Personal Data to only those employees who need the information to perform a specific job. You should be aware that the Internet is inherently susceptible to security failures beyond Pulpo’s control, and you should keep this in mind when communicating any information.

third party links

This Pulpo Sites may contain links to websites operated by third parties. Pulpo does not monitor or control these sites and makes no representations regarding these links. Pulpo is not liable or responsible for the accuracy, completeness, timeliness, reliability or availability of any of the content uploaded, displayed, or distributed, or products or services available at these sites. If you choose to access any third-party site, you do so at your own risk. The presence of a link to a third-party site does not constitute or imply Pulpo’s endorsement, sponsorship, or recommendation of the third party or of the content, products, or services contained on, or available through, that site.

cookie Policy

This Pulpo Sites may use a standard technology called a “cookie” to collect information about how you use the Sites. Cookies are small bits of information that Pulpo places on your computer. Pulpo uses the cookies to identify your Internet browser, store your preferences, and to determine whether you have installed the enabling software needed to access certain material on the Services. Cookies also help our Sites to recognize your computer’s browser as a previous visitor. This information allows us to customize delivery of information. We use cookies only to gather information as indicated in this Privacy Policy. We may use cookies, for example:

To save and remember registration information or preferences that you may have set while browsing the Sites.

To deliver content specific to your interests.

To save your password so you don’t have to re-enter it each time you visit our Sites.

We may also use “session cookies” which helps us administer the Sites. The session cookie expires when you close your browser and does not retain any information about you after it expires.

Third-party advertisements displayed on the Services may also contain cookies set by Internet advertising companies or advertisers. Pulpo does not control these cookies and users of the Services should check the privacy policy of the Internet advertising company or advertiser to see whether and how it uses cookies.

You can program your computer to warn you each time a cookie is being sent, block third party cookies or block all cookies. However, by blocking all cookies you may not have access to certain features on the Services.

This Pulpo Sites may be linked to Internet sites operated by other companies. Some of these third-party sites may be co-branded with the Pulpo logo or an affiliated entity, even though they are not operated or maintained by Pulpo (for example, co-sponsored chat pages, or advertising sponsor pages). The Pulpo Sites may also carry advertisements from other companies. Pulpo is not responsible for the privacy practices of websites operated by third parties that are linked to or integrated with the Pulpo Sites or for the privacy practices of third parties or Internet advertising companies. Once you’ve left the Pulpo Sites by such a link or by clicking on an advertisement, you should check the applicable privacy policy of the third parties or advertiser website to determine how they will handle any Personal Data they collect from you.

Some of the advertisements that appear on Pulpo are delivered to you by third party Internet advertising companies. These companies utilize certain technologies to deliver advertisements and marketing messages and to collect anonymous information about your visit to or use of our Services, including information about the ads they display, via a cookie placed on your computer that reads your IP address. To opt out of information collection by these companies, or to obtain information about the technologies they use or their own privacy policies, see their individual websites.

Google analytics

Pulpo uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your computer, to help the Sites analyze how users use the Sites. The information generated by the cookie about your use of the Sites will be transmitted to and stored by Google on servers in the United States. Google will use this information on behalf of us as the operator of the Sites for the purpose of evaluating your use of the Sites, compiling reports on Sites activity for Sites operators and providing them other services relating to Sites activity and internet usage. The data collected through these tools is not tied to any Personal Data about you.

In case IP anonymization is activated on the Sites, your IP address will be truncated within the area of Member States of the European Union (“EU”) or other parties to the Agreement on the European Economic Area (“EEA”). Only in exceptional cases, will the whole IP address be first transferred to a Google server in the United States and truncated there. The IP anonymization is active on the Sites. The IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of the Sites.

By using the Sites, you expressly consent to the use of Google Analytics on your activities on the Sites. You also can opt-out from being tracked by Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: (click here).

OPTING OUT OF INFORMATION COLLECTION

You can opt-out of having the Company collect or use information about you for online behavior advertising by clicking here or going to the website www.tentaculos.net/opt-out/ and following the instructions, and we will place an opt-out cookie on your computer. You may also use the NAI opt out tool by clicking here or going to the website www.networkadvertising.org/choices. The opt-out process is computer, device and browser specific and therefore must be repeated on each computer, device and browser that you use (for example, from within INTERNET EXPLORER AND FIREFOX). Please note that deleting, blocking or otherwise restricting cookies on your computer or device may delete our opt-out cookie and require you to renew your opt-out choice.

Many browsers can be modified to prevent automatic acceptance and notify you every time a cookie is sent to you or to allow you to choose not to receive cookies at all. If you wish to change the settings on your browser to block cookies, please follow the instructions applicable to the web browser that you are using.

banner advertising

We may license ad-server software from another company to place banner advertising on our Sites. All of the data provided and generated by the ad-server software remains in our possession and no data is transferred to the licensor of the software. This feature of our Sites may, on occasion, set “cookies” on your computer. Any information collected or stored by the ad-service or the cookies is treated in the same manner as other information as described in this statement.

Choices about how we use and disclose your information

Pulpo strives to provide you with choices regarding the Personal Data you provide us. We have created mechanisms to provide you with the following control over your information:

Cookie Settings: If you do not wish for us to install cookies on your device for the purposes described above, you may change the settings on your browser to block or limit cookies. For more information, please see http://www.aboutads.info/consumers. Please note that if you block or limit cookies, you may not be able to use all of the features of the Sites.

Do Not Track Signals: We do not currently respond to “do not track” signals.

Opt Out of Receiving Email Message: This Pulpo Sites provides you the opportunity to opt-out of receiving email communications from us and our special relationship partners. To opt-out of receiving email communications, you:

May use the unsubscribe link provided in promotional communications;

May modify your registered user information on our Sites; or

May send an email to privacy@pulpomedia.com.

Opt Out of Receiving Promotional Materials: If you receive promotional materials from Pulpo, and want to stop receiving such materials, click the unsubscribe link at the bottom of each promotional email.

children under the age of 16

Our Sites is not intended for children under 16 years of age, and Pulpo does not knowingly collect or use any Personal Data from children under the age of 16. No one under the age of 16 may provide any information to or on the Sites. If we learn we have collected or received Personal Data from a child under the age of 16, we will delete that information. If you believe we might have any information from or about a child under the age of 16, please contact us at privacy@pulpomedia.com.

California privacy rights

Under California Civil Code section 1798.83, California residents who have an established business relationship with us are entitled to ask us for a notice describing the types of Personal Data we have shared with third parties for those parties’ direct marketing purposes during the preceding calendar year. That notice will identify the categories of information shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you are a California resident and would like to request a copy of this notice, please submit a written request to:

General Counsel

c/o Legal Department

Entravision Communications Corporation

2425 Olympic Boulevard

Suite 6000 West

Santa Monica, CA 90404

SECURITY AND RETENTION

We employ reasonable measures to protect the security of information that we collect. Unfortunately, no transmission of information and no data storage can be guaranteed to be completely secure and unauthorized access to data, hardware or software failure, and other factors may compromise data security. As a result, while we strive to protect your Personal Data, we cannot guarantee or warrant the security of any such information, and you provide any information, including Personal Data, at your own risk.

We retain Personal Data for a maximum of six months from the last time a user is tracked to fulfill the delivery of advertising; administer transactions; conduct research and analysis, product development and reporting; comply with the law or legal process; protect or defend the legal rights of the Company, its employees, agents, advertisers, publishers or other contractors (including enforcement of agreements); protect against fraud or for risk management purposes; protect the rights, property or safety of the Company or the public; or as required or permitted by law or with your consent. We may retain Non- Personal Data indefinitely.

We retain user-level data for Personalized Advertising or Ad Delivery and Reporting for a maximum duration of 90 days.

REVISIONS TO OUR PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time. Any changes we make will be posted on this page. If we make material changes to how we treat your Personal Data, we will notify you by e-mail to the e-mail address provided by you or through a notice on Pulpo websites. The date of this Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically monitoring and reviewing any updates to this policy. Your continued use of our Sites after such amendments will be deemed your acknowledgement and consent of these changes to this Privacy Policy.

PUBLISHER SOURCING DISCLOSURE

Paid traffic sources percentage in Entravision/Pulpo Properties: Q1 2017 less than 1% of total visitors; Q2 2017 less than 1% of total visitors; Q3 2017 less than 1% of total visitors. A visit is considered “acquired through paid sources” if the first page view is from a paid source. A visit is determined to be from a paid source based only on attributes collected during that visit.

CONTACT US

If you have any questions or comments regarding this Privacy Policy, please contact us by e-mail at: privacy@pulpomedia.com or by mail at: OR BY MAIL AT: PULPO MEDIA, INC., 2425 OLYMPIC BLVD., SUITE 6000 WEST, SANTA MONICA, CALIFORNIA 90404.

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