Last Revised: September 19, 2024
This Privacy Policy (“Policy”) is designed to help you understand the types of personal information we at Gamma Media Holdings, LLC d/b/a gamma., and our affiliates and subsidiaries (collectively, “gamma.”, “us”, “we”, or “our”) collect, how we use it, how and when it may be shared, and the rights and choices you have with respect to your personal information. It also explains how we communicate with you and how you can make requests or submit inquiries to us about your personal information. Personal information is typically data that identifies an individual or relates to an identifiable individual. The definition of personal information (used interchangeably with “personal data”) depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Policy. We appreciate you taking the time to read this Policy and understand our data and privacy related practices.
This Privacy Policy applies to all personal information that we collect during any written, electronic, and oral communications online or offline when you:
By continuing to use our Services, you acknowledge this Privacy Policy, and agree to our Terms and Conditions (“Terms”). If you are not comfortable with any part of this Policy or do not agree with the Terms, please immediately discontinue access or use of our Services.
We may make changes to this Policy from time to time. We will notify you of any material changes to this Policy and will update the Last Revised date at the beginning of this Policy. We encourage you to look for updates and changes to this Policy when you access our Services.
gamma. collects certain personal information about you and your use of our Services. The personal information that we collect depends on your interactions with us, and the choices you make.
Information You Voluntarily Provide to Us. We may collect your email address, name, and any other information you choose to provide when sign up for our marketing communications, or would like to get in touch with us for other matters. Personal information that you provide by web forms will be used only for such purposes as are described at the point of collection.
Information We Automatically Collect. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as when you interact with the Sites or use the Services. We may collect the following types of information automatically from you:
We use your personal information for the following business and commercial purposes, unless restricted by applicable law:
To Provide Our Services. We may use your personal information to provide you with our Services that you request.
To Maintain Legal and Regulatory Compliance. Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to fulfill our business obligations, ensure compliance with education and student information protection laws, to manage risk as required under applicable laws and regulations, or to respond to requests by judicial process or governmental agency.
To Enforce Compliance with Our Terms, Agreements and Policies. When you access or use our Services, you are bound to our Terms. We may process your personal information for compliance purposes, such as carrying out our obligations and enforcing our Terms or other legal rights.
To Detect and Prevent Fraud and Security Risks. We may process your personal information to help monitor, prevent and detect fraud and abusive use of our Services, monitor unauthorized access, enhance system security, and combat spam, malware, malicious activities or other security risks.
To Provide Marketing Communication. We may collect your email address or other electronic addresses that you voluntarily provide to us when you subscribe to our marketing communications. We will send you information on products, services and promotions. When you no longer wish to receive these marketing messages from us, you can opt out at any time by unsubscribing or following the instructions contained within such messages or contacting us via the methods specified in the “How to Contact Us” section below.
To Research and Develop of Our Services. We may process your personal information and derive analytical and statistical data to better understand the way you use and interact with our Services. For instance, analyzing where, on which types of devices and how our Sites are used, how many visitors we receive, and where they click on the Sites may help us improve our existing Services and to build new Services. Please see our Cookies and Other Similar Tracking Technologies section for more information.
To Personalize Your Experience. We may process your information to personalize your experience. By personalization, we enable you to more easily interact with our Services across platforms and devices.
To Facilitate Corporate Acquisitions, Mergers and Transactions. We may process any information regarding your account and your use of our Services as is necessary in the context of corporate acquisitions, mergers or other corporate transactions.
With Your Consent. For any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the services or other related services requested, with your permission or upon your direction.
We may share personal information about you with third parties in the following circumstances:
Within Our Corporate Organization. We may share your personal information within our organization, such as with our subsidiaries, corporate affiliates, joint venturers, or other companies under common control with us, to provide you with the Services and to take actions based on your request. We may permit these entities to use your information for their own marketing purposes.
With Our Service Providers. We may share your personal information with third-party service providers acting on our behalf to help us operate our Services. Service providers provide us with support services such as website hosting, data analytics, market consulting, and network maintenance. These third-party service providers may have access to or process your personal information for the purpose of providing services for us.
During Business Transaction or Other Asset Transfers. We may disclose and transfer information about you to buyers, service providers, advisors, potential transactional partners or other third parties in connection with the advisors, potential transactional partners or other third parties of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our business or assets. By engaging with us or using our Services, you understand and agree to our assignment or transfer of rights to your personal information.
For Legal Compliance & Safety. We may access, preserve, and disclose information about you if we believe doing so is required or appropriate to (a) comply with law enforcement requests and legal processes, such as a court order or subpoena; (b) comply with requests from auditors, examiners or other regulators; (c) exercise, establish or defend our legal rights; (d) respond to infringement notification in accordance with the process set forth in our Terms and Conditions in order to investigate and address the potential infringement, or (e) protect your, our, or others’ rights, property or safety.
With Your Consent. We may share your personal information with other companies if you give us permission or direct us to share your information.
We and third parties on our behalf, may use cookies or similar tracking technologies, such as cookies and other similar technologies (collectively, “Tracking Technologies”) to collect personal information automatically as you interact with our Sites, to help us customize your experience and better manage content on our Sites, including to:
Managing Cookies. If you want to exercise your rights regarding personal information collected via cookies and similar tracking technologies, please see the “Your Choices and Privacy Rights” section below.
Analytics. We may use third-party service providers to monitor and analyze the use of our career website, such as Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports website traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. We maintain our Services and all associated information with technical, administrative, and physical safeguards to protect against the loss, unauthorized access, destruction, misuse, modification and improper disclosure of your personal information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the internet. If you feel that the security of any account you might have with us has been compromised, you should contact us immediately as described in the “How to Contact Us” section.
We will retain your information for as long as your account is active, as needed to provide you Services or for other purposes stated in this Policy. We will cease to retain your personal information or remove the means by which the personal information can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal information was collected and is no longer necessary for legal or business purposes. If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us as described in the “How to Contact Us” section. Please note that, we may still retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We maintain strict privacy policies to protect the personal information of our users obtained for text message communications. This information is never sold, rented, released, or traded to others without prior consent or legal obligation. Any sharing of information with third parties is solely for the purpose of fulfilling the organization's obligations to the user. We guarantee that it will never be shared with third parties for marketing purposes.
If you are receiving text messages from us and wish to stop receiving them, simply respond with "STOP" to the number from which you received the message. Once we receive your message, you will no longer receive further text messages from us.
Our Services are not directed to, and we do not knowingly collect personal information from, children under the age of 16. If you are under 13, please do not attempt to fill out our forms or send any personal information about yourself to us. If you are a parent or guardian and wish to review information collected from your child, or have that information modified or deleted, you may contact us via the method identified in the “How to Contact Us” section below. If we become aware that a child under 13 has provided us with personal information, we will terminate the user’s access to our Service and take steps to delete such information from our systems, unless we have a legal obligation to keep it.
Our business operates on a global scale. When you access or submit information to us, your personal information may be transferred to, processed, maintained, and used on computers, servers and systems located where the data protection laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we may transfer your personal information to the United States for further processing. We will take appropriate contractual or other steps to protect the relevant personal information in accordance with applicable laws.
Choices
Privacy Rights
Depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your personal information. If any of the rights listed below are not provided to you under the law that governs the processing of your personal information, we have absolute discretion in providing you with those rights. Please refer to the “What Rights Apply” section to determine the rights you have in the state you reside.
Please note, your rights in relation to your personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of the request is required or authorized by law; (b) when granting the request would have a negative impact on another's privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.
What Rights Apply
To determine which rights you have, please refer to the table below that references the rights as described above. U.S. States not listed either do not have a law providing such rights, or it does not apply to our operations.
| Jurisdiction | Applicable Rights |
|---|---|
| European Economic Area, United Kingdom and Switzerland (for individuals located in these jurisdictions when their personal information is collected) | (a) Right to Know/Access; (b) Right to Correct/Rectification; (c) Right to Delete/Erasure; (d) Right to Portability; (f) Right to Opt-Out of Automated Decision-making or Profiling; (g) Right Not to Provide Consent or to Withdraw Consent; (h) Right to Restriction; and (i) Right to Object to Processing |
| California Residents | (a) Right to Know/Access; (b) Right to Correct/Rectification; (c) Right to Delete/Erasure; (d) Right to Portability; (e) Right Against Discrimination; and (f) Right to Opt-Out of Automated Decision-making or Profiling (upon issuance of regulations by the California Privacy Protection Agency) |
Submitting a Request to Exercise Your Rights
To assert your privacy rights, please email [email protected]. Please note that to protect your privacy and security, we must be able to verify your identity before we can process your request to exercise any of the privacy rights that you may be entitled to under the applicable law. We may conduct the verification process by email or phone, and we may ask you to provide information such as your name, contact information, and any additional relevant information based on your relationship with us. You may also use an authorized agent to submit a request to opt out on your behalf if you provide the authorized agent signed written permission to do so.
The California Consumer Privacy Act, as amended by the California Privacy Rights Act (“California Privacy Laws”) requires us to disclose the following additional information related to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of this Privacy Policy.
Categories of Personal Information Collected, Used, and Disclosed
In the preceding 12 months, depending how you interact with our Services, we may have collect the following categories of personal information (as defined under Cal. Civ. Code §1798.140(v)(1)):
Identifiers, such as your name, unique personal identifier, email, or similar identifiers.
Internet or other electronic network activity information, such as technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and information about your visit, including your browsing history, search history, the webpage visited before you came to our Sites, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, and system configuration information.
For more information about the personal information we collect and how we collect it, please refer to Section 1 above, “Personal Information We Collect.”
For more information about the business purposes for which we collect your personal information, please refer to Section 2 above, “How We Use Your Personal Information.”
For more information about the categories of third parties with whom we may share your personal information, please refer to Section 3 above, “How We Disclose Your Personal Information.”
We do not sell your personal information or share your personal information with third parties for cross-contextual behavioral advertising purposes.
We do not process any sensitive personal information to infer characteristics about you without your consent.
If you are a California resident, you have the right to ask us for a notice describing what, if any, categories of personal information we share with third parties or corporate affiliates for those third parties’ or corporate affiliates’ direct marketing purposes. That notice will identify the categories of personal information shared with third parties and used for direct marketing purposes and the name and address of the third parties that received such personal information.
Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.
This section only applies to individuals using or accessing our Service while located in the European Economic Area (“EEA”), the United Kingdom, and Switzerland (collectively, the “European Countries”) at the time of data collection. Pursuant to the European Union’s General Data Protection Regulation, and the UK General Data Protection Regulation (collectively, the “GDPR”), for the sake of clarity, references to personal information in this section concern personal data in the sense of the GDPR.
We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in European Countries.
The Controller for the processing described in this Privacy Policy is: gamma., 2953 Lincoln Blvd Santa Monica, CA 90405 United States, [email protected].
Legal Bases for Processing Your Personal Information
The legal bases under the GDPR for our processing of personal data of individuals, which are located in European Countries at the time of collection, for each of the processing activities described above in Sections 2 and 3 is identified in the chart below.
| Processing Activity | Legal Bases for Processing |
|---|---|
|
Section 2(b) To Maintain Legal and Regulatory Compliance Section 2(d) To Detect and Prevent Fraud and Security Risks Section 3(d) For Legal Compliance & Safety |
Based on our legal obligations. Article 6(1) lit.(c) GDPR. |
|
Section 2(a) To Provide Our Services Section 2(c) To Enforce Compliance with Our Terms, Agreements and Policies Section 3(a) Within Our Corporate Organization Section 3(b) With Our Service Providers Section 3(e) With Third Party Marketing Partners |
Based on our contract with you or to take steps at your request prior to entering a contract. Article 6(1) lit.(b) GDPR. |
|
Section 2(f) To Research and Develop Our Services Section 2(g) To Personalize Your Experience Section 2(h) To Facilitate Corporate Acquisitions, Mergers and Transactions Section 3(c) During Business Transaction or Other Asset Transfers |
Based on our legitimate interest to operate our business and not overridden by your data protection interests or fundamental rights and freedom. Article 6(1) lit.(f) GDPR. |
|
Section 2(e) To Provide Marketing Communication Section 2(i) With Your Consent Section 3(e) With Your Consent |
Based on your consent. Article 6(1) lit.(a) GDPR. |
Right to Lodge a Complaint to Your Local Data Protection Authority
If you reside in certain territories (such as the European Economic Area, Switzerland, the United Kingdom), you may have the right to lodge a complaint with your national data protection authority or equivalent regulatory body. You can find details of EEA Supervisory Authorities here: https://edpb.europa.eu/about-edpb/board/members_en. The Supervisory Authority in the UK is the Information Commissioner’s Office (ICO).
International Transfer of Your Personal Information
We rely primarily on the European Commission’s Standard Contractual Clauses to facilitate the international and onward transfer of personal information collected in the European Economic Area (“EEA”), the United Kingdom and Switzerland (collectively “European Personal Information”), to the extent the recipients of the European Personal Information are located in a country that the European Countries consider to not provide an adequate level of data protection. We may also rely on an adequacy decision of the relevant regulatory body confirming an adequate level of data protection in the jurisdiction of the party receiving the information, or derogations in specific situations.
We welcome your questions, comments and concerns about privacy. You can contact us by email at [email protected] or by postal mail at gamma., 2953 Lincoln Blvd Santa Monica, CA 90405 United States.