CATENA MEDIA PRIVACY AND COOKIES POLICY

Last Updated: July 2023

Catena Operations Ltd., with a registered address at Quantum Place, Triq ix-Xatt, Ta´Xbiex, Gzira, Malta GZR 1052 (“Catena Media”, “we”, “us”), processes personal data about our customers, visitors on our websites and when you communicate with us or use our services (“you”). We make efforts to handle  your personal data with care, keep it secure and comply with data protection laws.

Catena Media is engaged in performance marketing, lead generation online and content publishing regarding financial information and services, with headquarters in Malta and subsidiaries in a number of other countries.

How this Privacy Policy Works

The purpose of this Privacy and Cookie Policy (“Policy”) is to explain to you how we collect, use, and share data that identifies you (“Personal Data”) that we obtain through your use of the websites, applications, and online services that are operated by Catena Media and from which you are accessing this Policy, including without limitation FrontDeskTip.com (collectively, the “Sites”). This Policy does not apply to information that we collect offline, such as over the telephone or in person. By using the Site, you agree to the terms and conditions of this Policy.  If you do not agree with any part of this Policy, you are not authorized to use the Site.

Click on a topic in the list below to find out more on individual topics in more detail by following the various links. We have labeled sections of the Policy to make it easy for you to navigate to the information most relevant to you.

Contents

1. What Personal Data do we process?
2. What do we use your Personal Data for and when do we process you Personal Data?
3. Who do we share your Personal Data with?
4. How long do we keep your personal data?
5. What are your rights?
6. Links to Third Party Sites
7. Children
8. California privacy rights
9. Do-Not-Track Policy
10. Updates to This Policy
11. How to contact us
12. Cookie Policy

1. What Personal Data do we process?

Catena Media may collect Personal Data from you if you voluntarily submit it to us through the Site. Some parts of the Site may ask you to submit Personal Data in order to benefit from a specified feature or to participate in a particular activity. For example, if the Site contains a “Contact” page and you contact us through that page or through an email address provided on the Site, we collect the information that you provide in your message. 

Through your use of the Site, we may also gather information about your use of the Site that does not identify you directly but may identify your computer or device. We may collect and store such data automatically whenever you interact with the Site. This data is used to analyze and improve the Site and to provide you with a better experience on the Site. Please see our Cookie Policy in Appendix A of this Policy below for more information about our collection and use of this data through the use of cookies and other technologies.

2. What do we use your Personal Data for and when do we process your Personal Data?

We use Personal Data collected through the Site for the purposes described in this Policy and as otherwise described to you at the point of collection. Generally, we use the information we collect to:

• Requests and Inquiries:  We may use your Personal Data to process, evaluate, and respond to your requests or inquiries.  For example, if you request certain information from us, we will use your Personal Data to process and respond to your request. 
• Manage Our Relationship with You: We may use your Personal Data to send you information regarding our relationship with you or regarding the Site, such as information about changes to our terms, conditions, policies, and other administrative information.
• Internal Business Purposes:  We may use your Personal Data for internal business purposes, including without limitation, to help us operate, evaluate, and improve the quality of the Site, to better understand the individuals that use the Site, and to generally manage our business. 
• Analytics:  We may use Personal Data to perform data analytics. To learn more, see the Cookie Policy in Appendix A of this Policy.  
• Legal Requirements:  We may use your Personal Data as necessary to comply with our legal obligations.

We may use non-Personal Data or aggregate information that does not identify an individual without restriction.

3. Who do we share your Personal Data with?

We may share your Personal Data only as described in this Policy or as otherwise described to you at the point of collection.  Generally, we may share your Personal Data with the following:  

• Affiliates: We may share your Personal Data with our affiliates for purposes consistent with this Policy. 
• Service Providers:  We may share your Personal Data with individuals or companies that we hire to provide services to us, such as website hosting services. 
• Business Transfers:  We may transfer your Personal Data in the event of a business sale, merger, consolidation, change in control, transfer of substantial assets, bankruptcy, liquidation, or reorganization. We may also disclose your Personal Data in the course of due diligence of such a transaction. 
• Legal Requirements:  We disclose Personal Data as we believe to be necessary or appropriate: (i) to comply with applicable law or legal process; (ii) to respond to requests from government authorities; (iii) to enforce our terms and conditions; (iv) to protect our operations or those of any of our affiliates; (v) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (vi) to allow us to pursue available remedies or limit the damages that we may sustain.

4. How long do we keep your personal data?

We will retain your personal data for as long as reasonably necessary for the purposes listed in Section 2 of this Policy. We maintain a data retention policy for personal data in our care. Where your personal data is no longer required we will delete it or anonymize it.

5. What are your rights?

You can opt out from certain cookie-related processing as described in the Cookie Policy in Exhibit A to this Policy. 

If you have any questions or concerns regarding our processing of your Personal Data, you may contact us as by sending an email to [email protected] or in writing to Catena Media at the address set out in Section 11 below.

6. Links to Third Party Sites.

The Site contains links to other websites for the convenience of users in locating information or services that may be of interest.  For example, the Site may provide links to websites or services controlled and operated by third party business partners.  If you access a third-party website from a link on the Site, any information you disclose on that website is not subject to this Policy.  

It is possible that these links may be used by third parties or others to collect personal or other information about you.  However, we are not responsible for the privacy practices of our business partners or other third parties, which may use your information for their own purposes.  Regardless of appearance or shared branding, Catena Media does not endorse and is not responsible for the privacy practices of such websites, advertisers, or third parties or the content of such websites.  Catena Media does not control these third parties’ use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other websites, advertisers, and any third parties. 

7. Children

We do not knowingly collect or maintain Personal Data from anyone under the age of 18, unless or except as permitted by law. Any person who provides personal data through the Site represents to us that he or she is 18 years of age or older. If we learn personal data has been collected from a user under 18 years of age on or through the Site, then we will take the appropriate steps to cause this information to be deleted. 

8. California privacy rights

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personal Data that were shared and the names and addresses of all third parties with which we shared Personal Data in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy team as listed below.

9. Do-Not-Track Policy

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Site currently does not respond to DNT browser signals or mechanisms. 

10. Updates to This Policy

The business and operations of Catena Media may change from time to time.  As a result, at times it may be necessary for us to make changes to this Policy to reflect changes in the law, our data handling practices, or the features of our Site. We reserve the right, in our sole discretion, to update or modify this Policy at any time. Modifications to this Policy will be posted on the Site and the new Effective Date will be displayed at the top of this Policy. Where required by applicable law, we will apply changes only with your consent. 

Please review this Policy periodically, and especially before you provide any Personal Data. 

11. How to contact us

If you have any questions regarding this Policy or the use of your Personal Data under this Policy, you can contact us at: 

Catena Operations Ltd. 

Attention: Data Protection Officer

Quantum Place

Triq ix-Xatt Gzira, GZR 1052 

Malta 

Email: [email protected]

 

Cookie Policy – Appendix A

We use Cookies

To offer you a full range of functions when you visit our Site, recognize your preferences, and make the use of our Site more comfortable and convenient, we use “cookies.”

What are Cookies?

A cookie, pixel or similar technology is a small file or information saved on your computer or device when you visit the Site. It enables the Site to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

Your options

By using our Site, you agree to the use and storage of cookies on your computer or device.

You can generally view our Site without cookies, but certain parts of the Site may not work properly, or navigating be slower.

If you do not wish cookies to be stored on your computer or device, you can deactivate the relevant option in the system settings of your browser. You can also delete stored cookies in the system settings of your browser at any time.

More information on how to deactivate or delete cookies can be found here: https://www.aboutcookies.org/cookie-faq/. However, please keep in mind that if you do not accept any cookies this may restrict the functionality of our offerings.

Categories of cookies

We use cookies for different purposes and with different functions.

Some cookies are:

necessary in technical terms (technical necessity)
stored and used for a certain time period (storage duration)
placed and stored by us or a third party (cookie provider).

Technical necessity

Cookies that are technically:

• Necessary: We use certain cookies because they are strictly necessary in order for the Site and its functions to work properly. These cookies are automatically placed on your computer or device when you access the Site or a certain function, unless you have set your browser to reject cookies.
• Not necessary: Cookies that are not strictly necessary are placed on your computer or device to improve convenience and performance of our Site or save certain settings that you have made. We also use cookies that are not strictly necessary in technical terms to get information on the frequency of use of certain areas of our Site, so that we can adapt to your needs and requirements on a more targeted basis.

Storage duration

Session cookies: Some cookies are only needed for the duration of your website session, so called “session cookies”. They will be erased or become invalid as soon as you leave our Site or your current session expires. Session cookies are used, for example, to retain certain information during your session.

Permanent cookies: Some cookies are stored for a longer period. For example, it allows to recognize you when you access our Site again at a later time and access saved settings. As a result, you can access webpages faster or with greater convenience, for example that you do not need to set certain options again, such as your chosen language. Permanent cookies are automatically deleted after a predefined period.

Flow cookies: These cookies are used for communication between our internal servers within our company group. They are placed on your computer or device when you start navigating the Site and deleted after the end of your navigation on the Site. Flow cookies are given a unique identification number but does not allow us to draw any conclusions regarding the actual customer or user.

Cookie providers

Provider cookies: These are cookies are placed by us or the operator of our Site, who is commissioned by us.

Third-party cookies: “Third-party cookies” are stored and used by other organizations or websites, for example Web analytics tools. External providers may also use cookies to display advertising or to integrate content from social networks, such as social plugins. For further information on Web analytics tools and measurement of reach, please see below in this cookie policy.

Use of cookies for Web analytics and reach measurement

We use Google Analytics, a Web analytics service of Google Inc. (“Google”). Google Analytics uses cookies to identify the frequency of use of certain areas of our Site and to identify preferences. The information regarding your use of this Site that is generated by the cookie (including your truncated IP address) is transferred to a Google server in the United States and stored there. Google will use this information to analyze your use of the Site, compile reports on Site activity for us, and perform further services associated with Site use and Internet use. Google may also transmit this information to third parties where required by law or to the extent third parties process these data on behalf of Google.

You can deactivate Google Analytics using a browser add-on if you do not wish the website analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=.

This add-on stores “opt-out” information on your device that serves to match up your deactivation of Google Analytics. Please note that this kind of “opt out” only leads to the deactivation of Google Analytics for the device and browser from which the opt out was activated. In addition, you may need to reactivate it if you delete cookies from your device.