Website Privacy Policy

LAST UPDATED: August 18th, 2022

 This Privacy Policy describes how Complex Media, Inc., together with its parents, partners and affiliates (collectively, “Complex,” “we”, “us” and “our”) collects, uses, and discloses your personal information when you visit websites (including mobile-optimized versions) and applications which have an authorized link to this Privacy Policy (each a “Site” and collectively, “Sites”). Complex and its global operations have been acquired by BuzzFeed, Inc. and are now part of the BuzzFeed family. Complex’s websites, apps, advertising services, products, services, and technologies are now owned and managed by BuzzFeed and are subject to BuzzFeed’s terms of service and other policies.  

We receive information about you from various sources, including via your use of the Sites and via your use of various third-party websites and social media. When you visit the Sites, you acknowledge that you have read and understand the terms of this Privacy Policy, including regarding the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. Capitalized terms used but not defined in this Privacy Policy have the meaning given to them in our Terms of Use.

What Does This Privacy Policy Cover?
Except as specified in this Privacy Policy, this Privacy Policy does not cover any personal information that you may provide to us via non-online communication methods. In addition, some portions of our Sites may be subject to additional privacy disclosures, which will be posted only on the relevant Site.

This Privacy Policy does not cover the activities of third parties that we do not own or control but that may be linked to or accessible via our Sites (“Third-Party Services”).  This Privacy Policy explains how we collect, use, and disclose data about you and process information that identifies or can be used to identify you (sometimes referred to as “personal data” or “personal information” under applicable privacy and data security laws, and hereinafter “personal data”) when you use our website(s), mobile apps, and other online products or services that link to this Privacy Policy (collectively, the “Services”) or when you otherwise interact with us. From time to time we partner with third parties to provide you with products, promotions or other experiences. We will show you the privacy policies belonging to those third parties when they will receive information in connection with those experiences. Their privacy policy will govern the collection of your personal data, in addition to this Privacy Policy.

Changes to this Privacy Policy
We’re likely to update this Privacy Policy in the future and when we make changes, we will revise the date at the top of the policy and, in some cases, will notify you through the Services, such as on our homepage, or via email or other communication. Please come back and check from time to time for the latest information on our privacy practices.

What Information Do We Collect?

We collect the following types of information from our users:

Information You Provide to Us:
We collect personal information that you choose to provide to us when you interact with our Sites, including the following:

  • Identifiers, contact, or registration information, including name and email address, username and password, such as if you create an account, sign up for our newsletter, send us an email, take a survey, or provide us with feedback.
  • Customer service information such as questions and other messages you address to us directly through online forms, by email, over the phone, or by post.
  • User-generated content such as comments or materials (including photos, videos, audio) you post to any forums on the Sites or information submitted when you participate in social networking features offered on our Sites. This information will be available for others to view. 
  • Transaction and Financial Information including your transactions (such as through the Complex Shop) and your payment method (valid credit card number, type, expiration date or other financial information), which is collected and stored by our third party payment processing company, Shopify Payments (the “Payment Processor”), and use and storage of that information is governed by the Payment Processor’s terms of service and privacy policy. Complex Shop also accepts payment through PayPal (governed by its user agreement and privacy policy) and Amazon Pay (governed by its user agreement and privacy policy)
  • Social media or third-party service (Third-Party Service) information if you creating a user account with us or signing in using a Third-Party Service login. We may also receive other information about you (including contact information, photos, location, user generated content, demographic information, city, friends) if you link your Third-Party Service account (such as a social media account) or access the Site through the Third-Party Service. Any information we receive from the Third-Party Service will be governed by the terms and conditions of the Third-Party Service and by the privacy controls you have set on your account. The Third-Party Service may also have access to information you provide to us or activities that you carry out on our Sites while logged into your account with that Third-Party Service, and this access will be governed by the terms and conditions of the Third-Party Service and by the privacy controls you have set.

 Data that indirectly identifies you and automatically collected data:

  •  Device information and identifiers such as IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers.
  • Internet network and device activity data such as information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our Site, the web sites you visit after this web site; and other web usage activity and data logged by our web servers, whether you open an email and your interaction with email content, access times, error logs, and other similar information. See “Cookie Policy” below for more information about how we collect and use this information.
  • Location information We use your IP address to infer your approximate location. We may also collect the language option or country you choose. When we provide certain services, such as providing you with a version of our Services that is localized to your country, we link location data to other information we have collected about you in order to do so.

Information We Collect from Third Parties:

 We may obtain certain data from third-party companies who specialize in collecting such consumer information. We use this data and combine it with other information we have about you to help us predict your preferences, to better direct the marketing efforts of us and our business partners, to improve our product development, and to help us better analyze user information for internal business purposes.

How Do We Use Information We Collect?

 We use information we collect to:

  • Provide you with access to the Sites and with other services and features 
  • Maintain and improve Site operations and service and content offerings hosted on the Site
  • Personalize and optimize the content shown to you when you visit the Sites, including:
    • Delivering advertising content shown on the Sites and managing the type of advertising content you see and the frequency with which you see it; and
    • Assessing and tracking effectiveness of our advertising campaigns and the campaigns of our business partners
  • Administer advertising, marketing, and promotional campaigns (run by us or by our business partners) for which you sign up or otherwise consent to participate in, such as sweepstakes, surveys, and special offers or announcements offered by us or by our business partners
  •  Respond to user feedback and other user inquiries, such as employment applications or informational inquiries
  •  Process a transaction that you initiate with us or with our business partners through the Sites (for example, a purchase from the Complex Shop)
  •  Internal uses such as market and content offering analysis
  •  Participate in affiliate marketing programs via links to third-party retailers which you can learn more about from their sites: Skimlinks | Impact | RakutenCommission Junction | ShareasaleAscend | Pepperjam / Partnerize | Amazon
  •  Conduct security, fraud, and legal compliance activities, including by detecting, protecting against, and prosecuting security incidents, fraud, and illegal activity for example to: 
    • Monitor prevent, and detect fraud, such as through verifying your identity
    • Combat spam or other malware or security risks
    • Monitor, enforce, and improve the security of our Sites
    • Comply with any applicable procedures, laws, and regulations, subpoenas, governmental requests or legal process, or in connection with a legal investigation, if in our good faith opinion such is required or permitted by law; and/or
    • Enforce our Terms of Use, any other legal agreements, and this Privacy Policy

How Will We Share the Information We Receive?

 We share your information as follows:

  • Our Corporate Parents and Affiliates.  We may share your information with our Affiliates and with our parent companies and any of their affiliates. 
  • Third-Party Services. As discussed above, you may connect certain Third-Party Services to our Sites. If you do so, information collected while you are logged into your account is no longer under our control and is subject to the terms of use and privacy policies of such third parties.
  • Third-Party Campaigns. We may carry out advertising, marketing, or promotional campaigns with third party companies that invite you to participate in the campaign. The campaigns may involve third-party goods or services. You may participate in such a campaign via our Sites or on a different website that is linked to/from our Sites. If you participate in the campaign, we may share your personal information with these third-party companies. 
  • Service Providers. We use service providers to provide certain products, services, and Site features on our behalf (such as sending emails or processing credit cards) and need to share your information with them to provide those products, services, or features to you. We require that our service providers maintain the confidentiality of your personal information (as appropriate for the service) and not use it for any reason except to carry out the functions that we task them to carry out.
  • Third Parties Conducting Contests and Sweepstakes. If you have entered a contest or sweepstakes sponsored by a third party, we may share the information you provide with that third party for any purpose that you have consented to under the terms of the contest or sweepstakes. You should read the terms for participating in the contest or sweepstakes carefully, and should not enter the contest or sweepstakes if you do not agree to how your information will be shared or used under those terms. In addition, the privacy policies of such third-party companies may apply to their use and disclosure of your information.
  • Third Parties Providing Ad Services: In addition to ads and content that we serve you directly, we use third-party advertising companies and marketing services companies to serve ads and other content when you visit our Sites. Both we and these companies may collect and use information about your visits to our Sites and your use of our applications to serve ads and other content to you. We and they may target advertising towards you by tailoring advertising to interests that we or they infer from your interactions on our Sites. 
  • Third Parties Involved in a Business Transfer. If we sell, merge, or otherwise transfer all or part of our business (or of our business interests in the Sites), or acquire new businesses, your information and other information collected by us under this Privacy Policy may be transferred as part of or in connection with the transaction or for due diligence in contemplation of such transaction.
  • Third Parties Involved in Protecting Us and Others. We may disclose your personal information when we believe in good faith that the disclosure is necessary to: comply with a law, regulation, legal or regulatory process (including investigations), subpoena, warrant, or other legal order; to enforce or apply our Terms of Use and other Site policies; or protect the rights, property, or safety of us, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction, and for debt collection.
  • We may share or disclose your aggregated, anonymized, or de-identified data with our service providers and business partners or third parties for any purpose including business and marketing uses and the development of business and marketing reports and strategy. These service providers and business partners may also share with us aggregated, anonymized or de-identified information about you so that we can develop business and marketing reports and strategy for them.

Online Tracking & Advertising
We, our service providers, and third parties that provide content, advertising, or functionality or measure and analyze ad performance on our Services, may use cookies, web beacons, mobile ad identifiers, and similar technologies to facilitate administration and navigation on the Site, to better understand and improve our Sites, to determine and/or improve the advertising shown to you here or elsewhere, and to provide you with a customized online experience. For more information regarding how we use cookies and similar technologies, please see our Cookie Policy below.

Analytics

 We automatically collect certain types of information about activities on our Sites, such as the numbers and frequency of visitors to our Sites. This information is aggregated and anonymized or de-identified, and does not identify individual users such as yourself. We use Google Analytics to collect this type of information, so Google may also have access to this information.  You may read Google’s Privacy Policy (including any opt-out mechanisms that Google offers) here and here. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

 Advertising

 We use third-party advertising companies to serve ads and other content when you visit our Sites. Both we and these companies may collect and use information about your visits to our Sites and your use of our applications to serve ads and other content to you.

If you would like more information about this practice and to know your choices about having your information used in this manner by our partners, you may visit https://optout.networkadvertising.org/?c=1, https://optout.aboutads.info/?c=2&lang=EN or https://youradchoices.com/token. You may also opt out of data collection related to the affiliate marketing programs in which we participate here.

For mobile devices, you can limit the use of information for this type of advertising using options presented in your device setting controls which limit ad tracking or reset your advertising identifier.

Please note that some of the opt-outs described above use browser cookies or device controls, and are specific to the browser or device you are using to access our Sites. If you buy a new device, change browsers, or delete browser cookies, these actions can change your previous opt-out settings and you may need to opt out again. In addition, disabling all cookies may prevent you from using certain features on our Sites that require cookies to function.

Is Information About Me Secure?

 We use industry-standard security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure.  However, no method of transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee absolute security of your personal information.

If you use the login of a Third-Party Service to access the Sites, you may have additional or different sign-on protections via that Third-Party Service, which will be governed by the Third-Party Service’s terms of service or other agreement governing use of that service. We are not responsible for the protection practices of Third-Party Services, and you should read the policies of the Third-Party Service before using your login with that Third-Party Service to access our Sites.

Children’s Privacy
If you are below the age of consent under applicable law in the country in which you reside, then your parent or legal guardian must read and accept the terms and conditions of this Terms of Service in your name and on your behalf.

In the U.S., you must be at least 16 years of age to use the Sites. By using the Sites, you represent and warrant that you are at least 16 years of age. If you are under age 16, you may not, under any circumstances or for any reason, use the Sites. Our Sites are not targeted to nor meant for anyone under 16 years of age. If you become aware of anyone using the Sites who is under the age of 16, please report this to: . We do not knowingly collect information from anyone under the age of 16.

We may, in our sole discretion, refuse to offer the Sites to any person or entity for any reason. We may also change this eligibility criteria at any time, in our sole discretion. You are solely responsible for ensuring that your use of the Sites is in compliance with all laws, rules and regulations applicable to you. If you are a minor, you may wish to consult your parents about what portions of the Sites are appropriate for you.

Further, the Services are offered only for your personal use, and not for the use or benefit of any third party.

What Choices Do I Have?
The local laws where you live (e.g., laws of the E.U. and California) may permit you to make certain requests.  See the section applicable to the place of your residency below.

  • Account Information: If you have provided personal information as part of setting up an account and login for the Sites, you can change or access your personal information via your account settings. You can also use many of the features of the Site without registering or signing into a user account.
  • Third-Party Services (Including Social Media) If you have provided personal information as part of using your social networking account with a Third-Party Service, you must change or access your personal information via that account with that Third-Party Service. You will not be able to access or change such personal information via our Sites.
  • Online Analytics and Ads: If you want to limit the types of data that we collect about you for analytics or online advertising please review the options identified in the section on Online Tracking & Advertising.
  • Email Communications: If you do not want to receive commercial email communications from us, you can unsubscribe from specific email communications or all email communications from us by clicking the “unsubscribe” link in any email we send to you. Please note that if you do not want to receive legal notices from us, such as this Privacy Policy, those legal notices will still govern your use of the Service, and you are responsible for reviewing such legal notices for changes. Please note that you cannot unsubscribe to certain administrative communications about the Site.
  • Information You Provided to Third Parties: If you have provided personal information directly to third-party companies with whom we conduct business, you should also consult the privacy policies of these third-party companies for how your personal information may be used and how you may restrict its use or opt out of receiving communications from these third-party companies.
  • SMS: If you do not want to receive communications to your mobile device from us (such as text or SMS messages), you must reply “STOP” or follow the instructions provided in the message to opt out of such text or SMS messages.
  • Push Notifications: If you do not want to receive push notifications on your mobile device about our Sites, you can go to your device’s settings and opt out of receiving push notifications from us.
  • Location: If you are accessing our Sites via a mobile device and do not want us to collect your location information, you can go to your device’s settings and opt out of providing your location information to us.

 Please note, if you have used an opt-out mechanism described in this Privacy Policy, but then decide to use a service or to participate in an activity that requires us to contact you or share your information with a third party, then your previous opt-out will not apply to that service or to your participation. 

Please note that some of the opt-outs described above use browser cookies or device controls, and are specific to the browser or device you are using to access our Sites. If you buy a new device, change browsers, or delete browser cookies, these actions can change your previous opt-out settings and you may need to opt out again. In addition, disabling all cookies may prevent you from using certain features on our Sites that require cookies to function.

Links to Other Websites and Services
The Site may contain links to third-party websites or services. 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-party websites or services.

California Information and Privacy Rights. 
The following information applies to California residents regarding “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).  This information and the rights discussed below do not apply to information collected from or about our employees, former employees, candidates, contractors, service providers, or business contacts. 

Additional Information for California Residents
Throughout this Policy, we discuss in detail the specific types of information we collect from you and other users (as described in What Information Do We Collect? above) and discuss how we use (as described in How Do We Use Information We Collect? above) and share (as described in How Will We Share the Information We Receive? above) such information. The CCPA requires us to provide additional information about this collection, use, and disclosure. 

  • We may collect, use, and disclose for our business and commercial purposes, the following categories of information about you or your use of the Services: Identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information collected by our payment processor); user-generated content; device information and identifiers (such as IP address); internet or other network or device activity (such as browsing history or app usage); location data; audio or visual information (such as if you participate phone survey or submit a photo); characteristics of potentially protected classifications (such as gender); inference data; and other information that identifies or can be reasonably associated with you.  

California Privacy Rights
CCPA Rights. California residents can make certain requests about their personal information under the CCPA. Specifically, beginning January 1, 2020, if you are a California resident, you may request that we:

  • Provide you with information about: the categories of personal information we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we share personal information. Such information is also set forth in this Privacy Policy.
  • Provide access to and/or a copy of certain information we hold about you;
  • Delete certain information we have about you;
  • Opt out of the sale of personal information; and/or
  • Provide you with information about the financial incentives that we offer to you, if any.

 Please note that certain information may be exempt from such requests under applicable law.  For example, we may retain certain information for legal compliance and to secure our Site. We may need certain information in order to provide the Site to you; if you ask us to delete it, you may no longer be able to use the Site.

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights under the CCPA. 

If you would like information regarding your rights under applicable law or would like to exercise any of them, please click here or email us at legal@complex.com. To protect your privacy and security, we take reasonable steps to verify your identity and requests before granting such requests, including by verifying your account information, residency or the email address you provide.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal data. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or deletion twice within a 12-month period.

Please note that the verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
 

We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Making a verifiable consumer request does not require you to create an Account with us. We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Sale of personal information.  California law broadly defines “sale” in a way that may include the delivery of targeted advertising on the Site or other sites, including allowing third parties to receive certain information, such as cookies, IP address and/or browsing behavior.  We may share the following categories of information for such advertising which may be considered a “sale” (as defined by California law):

  • Device information and identifiers, such as IP address, and unique advertising identifiers and cookies; usage information, such as browsing history or app usage; location information, such as city; and inference data.
 

If you are a California resident and would like to opt out of our use of your information for such purposes (to the extent this is considered a sale), beginning January 1, 2020, you may do as outlined on the following page: Do Not Sell My Personal Information. You can also control certain of this sharing through the choices outlined in Online Tracking & Advertising.
Note for non-California residents
We will seek to honor requests to exercise the above rights made by non-California residents to the extent required by applicable law.

Statistics on California Consumer Requests We Receive
The CCPA requires us to provide metrics on the number of requests we have received each year from California consumers and how they have been fulfilled. This information can be found in the chart below. 

Applicable Period: January 1, 2021 – December 31, 2021 
 

Requests Submitted # Requests Received # Complied with in whole or in Part # of Requests Denied* Mean # of days to Respond to Request
Requests to Access 22 22 11 13
Requests to Delete 141 141 6 13
Requests to Opt Out 1049 1049 0 1

*This includes requests where users did not confirm their identity, where provided verification information did not match the information on file for that account, where users did not provide all required verification information, and where requests were denied on other grounds.

California Shine the Light Disclosure. Under California Civil Code sections 1798.83- 1798.84, California residents are entitled to ask for a notice identifying the categories of personal customer data which we share with our affiliates and/or third parties for their own direct marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 111 E. 18th Street, New York, NY 10003, Attn: Legal.    *This includes requests where users did not confirm their identity, where provided verification information did not match the information on file for that account, where users did not provide all required verification information, and where requests were denied on other grounds.

Information for Certain Users Outside the United States 

EEA and UK Visitors/Users

If you are a visitor or user from the European Economic Area or UK, we will only collect and use your personal data (as defined under Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”)) when we have a legal basis for doing so. 
The legal basis on which we rely will depend on the type of personal data we collect and the specific context in which we are collecting it. 

We will use your personal data only for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal data for another purpose, we will explain the legal basis we rely on.

The table below shows what we use your personal data for and the lawful basis for processing it in each case.

 

Purpose

Type of data

Lawful basis

Recognize you and analyze how you, and other users, navigate the Services and apps and what type of content you’re interested in, and to manage and improve the Services by testing new features of our sites and apps. We do this by using cookies or similar technology as explained in our “Cookie Policy” section.

Data that indirectly identifies you such as your IP address, mobile device ID and location data. This data does not include anything that allows us to identify you by name or contact details.

Legitimate interest.

 

Recognize you and analyze how you, and other users, interact with ads on our Services and what type of ads you’re interested in. We do this by using cookies or similar technology as explained in our “Cookie Policy” section.

 

Data that indirectly identifies you such as your IP address, mobile device ID and location data. This data does not include anything that allows us to identify you by name or contact details.

 

Consent.

Communicate legal information to you.

Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address and information you include in your user profile).

Legitimate interest.

 

Analyze comments and feedback you have given us including comments, feedback and reviews you have posted on our Services in order to use the information to carry out journalistic activities, to improve our services and content offerings, and to enforce our Terms of Use.

 

Data that directly identifies you (such as your name, username, and email address) and data that indirectly identifies you (such as your IP address or mobile device ID and location data).

 

Legitimate interest.

Provide you with communications and services you’ve signed up, for such as our newsletters.

Data that directly identifies you such as your name, username, email address and location data.

Consent.

Register you as a user of our Services and other products and services and administer your Account.

Data that directly identifies you (such as your name, username, and email address and other information included in your user profile).

Creation or performance of a contract.

 

Publish content on our Services including articles, feedback, reviews and user comments about our posts.

 

Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address and information included in your user profile).

 

Creation or performance of a contract.

 

Fulfill orders for subscriptions, products or services placed through our Services.

 

Data that directly identifies you including your name and address, email address, other contact details, financial and transactional data.

 

Creation or performance of a contract.

 

Collect money you owe us.

 

Data that directly identifies you including your name and address, email address, other contact details, financial and transactional data.

 

Legitimate interest.

 

Verify or obtain payments due to us when you buy something from a third party after clicking on an “affiliate” link in our content, measure the performance of affiliate links, analyze and develop this part of our business.

 

Data that indirectly identifies you (such as your IP address or mobile device ID) or data that directly identifies you (such as your name, username, email address and location data).

 

Legitimate interest.

 

Communicate our terms, notify you about changes to them and communicate with you about non-compliance.

 

Data that indirectly identifies you (such as your IP address or mobile device ID and location data) or data that directly identifies you (such as your name, username and email address).

 

Creation or performance of a contract.

 

Communicate our Privacy Policy and notify you of changes to them

 

Data that indirectly identifies you (such as your IP address or mobile device ID and location data) or data that directly identifies you (such as your name, username, and email address).

 

Compliance with a legal obligation.

 

Conduct surveys or undertake similar types of research so that we can improve and develop our business, our Services.

 

Data that directly identifies you (such as your name, username, name, email address and location data)

 

Consent.

 

Allow you to take part in a prize draw, sweepstake, or other competition or other promotional activity.

 

Data that directly identifies you such as your name, username, and email address.

 

Creation or performance of a contract.

 

Administration and protection of our business including troubleshooting, data analysis, testing, system maintenance, user support, reporting and hosting data, administration and IT services, network security, fraud prevention, customer services and business reorganization, including exchanging information with third parties for fraud protection and spam/malware prevention.

 

Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address).

 

Legitimate interest.

 

Send marketing communications to you if you subscribe to our newsletters or other products and services. We explain how we comply with the law under “What Choices do I have?”.

 

Data that directly identifies you such as your name and email address.

 

Consent

 

Communicate with you about our services that you sign up to receive when you create an Account and transactions that you conduct using our services, including published content you visit, content you submit for publication on our properties.

 

Data that directly identifies you such as your name and email address.

 

Creation or performance of a contract

 

Comply with applicable laws, regulations and legal and regulatory processes.

 

Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and/or data that directly identifies you (such as your name, username, and email address).

 

Creation or performance of a contract

 

Legal Rights for EEA and UK users
If you are an EU or UK resident, you have certain rights in respect of the information that we hold about you. Below is a short overview of those rights:

  • Access. With some exceptions designed to protect the rights of others, you have the right to a copy of the personal data that we hold about you. Where the data is data that you have given to us, you have the right to receive your copy of it in a common electronic format, and to provide copies of it to other people if you wish.
  • Correction. You have the right to have the personal data we hold about you corrected if it is factually inaccurate. This right does not extend to matters of opinion, such as views expressed in editorial content.
  • Deletion. In some limited circumstances, you have the right to have personal data that we hold about you erased (the “right to be forgotten”). This right is not generally available where we still have a valid legal reason to keep the data (for example, because we are obliged to do so by law).
  • Objection. You have the right to object to our processing of your personal data where we rely on “legitimate interests” as our legal basis for processing, but we may be able to continue processing if our interest outweighs your objection.
  • Withdrawing consent. If we are processing your personal data on the basis of your consent, you have the right to withdraw that consent at any time, in which case we will stop that processing unless we have another legal basis on which to continue.

How to exercise your rights
To exercise your rights, email legal@complex.com. In order to protect your privacy and that of others, we will ask you to prove your identity before we take any steps in response to a request you have made. If a third party is making a request on your behalf, we will ask them to prove that they have your permission to act for you.

We may contact you to ask you for further information to help you exercise your legal rights or to speed up our response. We will try to respond to requests within one month and we will let you know if we need to take longer, for example because your request is complicated. We may have an overriding lawful basis for processing your personal data, or certain exemptions may apply. If we refuse your request, we will explain why.

Complaints
You have the right to complain about data privacy matters to the Information Commissioner’s Office (www.ico.org.uk), or the relevant data protection regulator in your country of residence. You can contact the ICO on 0303 123 1113. We invite you to raise your concerns with us first, so that we can try to resolve them.

 

EU Representative 
We have appointed IT Governance Europe Limited to act as our EU representative. If you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR) or have any queries in relation to your rights or general privacy matters, please email our Representative at eurep@itgovernance.eu. Please ensure to include our company name in any correspondence you send to our Representative.

Other non-US users
If you have questions about or need further information concerning the legal basis on which we collect and use your information, please contact us using the contact details provided under the “Questions or Concerns” section below.

Your local laws may permit you to request that we:

  • Provide access to and/or a copy of certain information we have about you;
  • Prevent the processing of your information for direct-marketing purposes;
  • Update information which is out of date or incorrect;
  • Delete certain information which we have about you;
  • Restrict the way that we process and disclose certain of your information;
  • Transfer your information to a third-party provider of services; and
  • Revoke your consent for the processing of your information.

 We will consider all requests and provide our response within the time period stated by applicable law. Certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us at legal@complex.com. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

 Data Retention
We generally retain information for so long as it may be relevant to the purposes for which we collected it and in compliance with applicable law. To dispose of any personal data, we may anonymize it, delete it, or take other appropriate steps. Information may persist in copies made for backup and business continuity purposes for an additional period of time.

Cookie Policy

Cookies are small data text files that are sent from a server during a browsing session. Cookies are typically stored on your computer’s hard drive and are used by web sites to simulate a continuous connection to that site. The use of cookies automatically identifies your browser whenever you interact with a site. A “web beacon,” also known as a tag, pixel tag, or clear GIF, is used to transmit information back to a web server. When we talk about “cookies” in this Privacy Policy, we mean not just cookies, but web beacons and similar technologies.

Cookies and similar technologies allow us to collect the following types of personal data: a unique ID assigned to your device; IP address; device and browser type; operating system; referring URLs; content viewed or other actions taken through our Services; time and date of those actions; country and language selected.

Browsers and devices have tools that allow you to disable cookies on sites and apps. If you disable cookies you may not be able to access all the features of our services. We suggest that you keep our essential cookies (described below) active for a better user experience and to help us keep improving and developing our products and services.

Our Services use our own cookies to recognize you and remember you as a unique user.

  • Session cookies remember you during your session on our Services. They are deleted when you log out of the Services and when you close your web browser. Session cookies are used to ensure you are served content correctly, to balance and monitor load on our servers, and for other technical matters essential to the operation of our Services. You can configure your device to reject these cookies, but our Services will probably not work correctly, or at all, if you do.
  • Consent cookies are used by our consent management platform we employ to record your preferences about third party cookies described below, and to store and share your preference with those third parties. These cookies are essential for compliance with the legal obligations imposed on us and on third parties with whom we have a business relationship to ensure we request your consent, record your consent preferences, and act on such consent preferences.
 

Analytics cookies

Analytics cookies are used by us and by third parties who process data for us for data analytics purposes (for example Google Analytics) so that we can manage and improve the performance and design of our Services and for monitoring, auditing, research and reporting.

We have activated Google’s IP anonymisation function on our Sites. This will cause your IP address to be cut by Google within Member States of the European Union or in other countries party to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the Sites, to compile reports on Site activity and to provide us with other services relating to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.

With respect to Google Analytics, you can read about how Google uses data gathered for that purpose here.

 

Third party cookies: advertising and affiliate links

Our ad partners and our affiliate links partners collect personal data from you for the purposes they disclose through our cookie consent management platform.

  • Ad partners include ad networks such as third party ad servers, ad agencies, ad technology vendors and research firms.
  • Affiliate links partners pay us when you buy things from them or another third party after clicking on an affiliate link in our content.

Our ad partners use third party cookies to serve ads to you and to target you with tailored (or personalized) ads when you are using the Services and when you visit Third-Party Sites. They also use cookies to measure traffic on the Services (for example to track ad views).

Ad partners and affiliate links partners may view, edit or set their own cookies on your mobile device or web browser when you interact with our Services. They use cookies to track your use of our Services and your activities elsewhere online. We are not responsible for the privacy practices of these third parties and we encourage you to read their privacy policies so that you understand how they process information about you. 

You can decide who you will allow to set these third party cookies on your browser or device by going to our Privacy Preference Center. You can change your mind and revisit your consent choices at any time by returning there.

 Questions or Concerns
If you have any questions or concerns regarding privacy while using the Sites, you may contact us at legal@complex.com.  We will make every effort to resolve your concerns.

bell icon
Sign up for Complex notifications for breaking news and stories.