Privacy Policy

VNIMLLC (CMEList.com) protects and respects your privacy.

This Privacy Policy (“Policy”) describes and governs the information collection, use, and sharing practices of VNIMLLC and its corporate affiliates, subsidiaries, and divisions as may change from time to time (collectively, with CMEList.com “we,” “us,” and “our”) with respect to VNIMLLC websites, mobile applications, and other digital and interactive services that link to this Privacy Policy (together, the “Services”).

Before you submit any information on or through the Services, please carefully review this Policy together with our Terms and Conditions and any other documents referred to therein to understand our views and practices regarding your information and how we will treat it.

Please note that this Privacy Policy applies only to information collected through the Services and not to information you may provide to any third-party sites to which CMEList.com may link, except as expressly provided herein. This Policy applies regardless of the device used to access the Services (e.g., personal computer, mobile device, consumer electronics device, or any other technology or software known today or developed in the future). Some online services offered by or affiliated with VNIMLLC may be governed by a separate privacy policy. In those instances, the product-specific privacy policy shall apply to that online service.

For the purpose of data protection laws applicable from time to time to you in the location that you provide your information (“Applicable Law”), VNIMLLC , d/b/a CMELIST.com, will be a ‘data controller’ (or such equivalent or replacement terminology as appropriate) for the information you provide through the Services. There may be other controllers as well
(e.g., advertisers), and we encourage you to consult their privacy policies to learn more about their privacy practices.

A. INFORMATION WE COLLECT

We collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from you, such as from your browser or device.

1. Information You Provide Directly to Us

We may collect information from you during your use of or access to the Services, such as when you:

• Register for an account;
• Fill in forms;
• Search for a listing;
• Complete a survey or provide us with feedback;
• Subscribe to a service or request certain features (e.g., newsletters, updates, and other products);
• Communicate with us by phone, e-mail or otherwise;
• Chat with any of our support agents on our chat forum;
• Report a problem with our website; or
• Post user-generated content, including comments, to or on any of our Services, including on discussion boards, community forums, blogs, or other social media functions on our website.

The information you provide directly to us may concern you or others and include, but is not limited to: (i) name; (ii) email address; (iii) age; (iv) home or business address; (v) username and password associated with your account; (vi) information about your business; (vii) phone numbers and other contact details; (viii) demographic information; and (vii) birthdate.

You do not have a statutory or contractual obligation to provide us with your information; however, if you do not provide us with your information, we may not be able to provide you with the Services you have requested or you may be limited in your use of our Services (e.g., if you do not provide us with your email address, we will not be able to send you newsletters).

B. Information that is Passively or Automatically Collected

1. Device/Usage Information

We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Services. As described further below, we may collect and analyze information such as (a) IP addresses, geolocation information, unique device identifiers, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content (such as advertisements) viewed and the order of those pages, statistical information about the use of the Services (such as barcodes scanned through certain of our mobile apps), the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.

We also collect and analyze information from your browser or device, such as, your operating system, plug-ins, system fonts, resolution and other data, for purposes of creating a unique profile or “fingerprint” of your browser or device. We may use this profile or fingerprint to understand and analyze how you interact with the Services, to customize content or advertising to you through the Services, to monitor against fraud or misuse of the Services, or in other ways consistent with this Privacy Policy.

2. Location Information

We and our service providers may automatically collect location information, including general information (e.g., IP address, zip code) from your computer or mobile device. If you access the Services through a mobile device, we may also ask you to share your specific geo-location information with us. The Services use this location information to provide customized location-based services, content, promotional offers and other information that may be of interest to you.  We may also use location information to improve the functionality of the Services and our other products services. We and our service providers may also collect other information based on your location and your device’s proximity to “beacons” and other similar indoor proximity systems, including, for example, the strength of the signal between the “beacon” and your device and the duration that your device is near the “beacon.” If you do not wish to have this location information collected and used by us and our service providers, you may disable the location features on your device. Please note that if you disable such features, you will not be able to access or receive some or all of the services, content, features and/or products made available via the Services. Also see the “Tailored Advertising” section below for more choices regarding the delivery of interest-based content and advertising.

3. Cookies and Other Electronic Technologies

We may also collect data about your use of the Services through the use of Internet server logs, cookies and/or tracking pixels. A web server log is a file where website activity is stored to distinguish you from other users of our website. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv), enhance your user experience by delivering content specific to your interests; (v) perform searches and analytics; and (vi) assist with security administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising, and to access user cookies. As we adopt additional technologies, we may also gather additional information through other methods.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Except for essential cookies, all cookies will expire after thirteen months.

Your usage of the website without changing your browser cookies settings will indicate your consent to usage of cookies in accordance with this section of this Policy. You can change your cookie settings at any time. Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g.,  Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including cookies and local storage objects with the Flash management tools available at Adobe’s website. Please note that by blocking any or all cookies, you may not have access to certain features or services offerings.

C. Information Collected by and from Social Media and Other Content Platforms

If you access the Services through a third-party connection or log-in (e.g., through a social network), you may allow us to have access to and store certain information in your social network profile. This may include your first name, last name, gender, general location, a link to your profile, your time zone, birthday, profile picture, your “likes” and your list of friends. If you do not wish to have this information shared, do not use a social networking connection to access the Services. For a description on how social networking sites handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings. If you signed up using a social media log-in by mistake, you may be able to delete your account through your account settings at any time, or you can contact us as described below.

When you “like” or “follow” us on Facebook, Instagram, LinkedIn, Twitter or other social media sites, we may collect some information from you including your name, e-mail address, and any comments or content you post relevant to us. We may also collect your information if you sign up for one of our promotions or submit information to us through social media sites.

D. Information from Affiliates and Non-Affiliated Third Parties

We may also obtain information about you if you use any other websites that we operate or may operate from time to time or other services we provide. We may share information amongst members of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries. We may also obtain information, such as demographic information, from our affiliates or from third parties, such as marketers, partners, researchers, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies and others.

2. HOW WE USE YOUR INFORMATION

We may use your information for the following purposes:

• For the purposes for which you provided it;
• To carry out our obligations arising from any contracts entered into between you and us including the provision to you with information, products and services that you request from us, online content and dealing with your requests and inquiries;
• To process a transaction you initiate or to provide the features, services and products available through the Services;
• To send you information about your relationship or transactions with us, account alerts, or other communications, such as newsletters to which you have subscribed;
• With your consent, to send you SMS messages;
• To notify you about new features, changes and/or offerings of the Services, including, but not limited to, updates, products, and/or special offers;
• To process and respond to your inquiries or to request your feedback;
• For internal research and reporting;
• To analyze and improve the content and features of the Services or develop new Services;
• To ensure that content from our website is presented in the most effective manner for you and on the device or browser from which you are accessing our Services;
• To personalize the content and advertising that you see on the Services or on other websites, including across difference devices and browsers (see “Personalized Content and Advertising” section below);
• To measure or understand the effectiveness of advertising we serve to you and others;
• To allow you to participate in interactive features of our service, when you choose to do so;
• To enforce the legal terms that govern your use of the Services;
• To keep our website safe and secure;
• To use IP addresses to identify the location of users, to block disruptive use, to establish the number of visits from different countries and to determine the jurisdiction in which you are accessing the Services; and
• To administer and troubleshoot the Services.

Please note that we may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties and use such combined information in accordance with this Policy.

We may aggregate and/or de-identify information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.

If you ever provide to us any information that classifies as ‘sensitive personal information’ (for example racial or ethnical origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offenses), we will only use this information to provide the Service you require in accordance with this Policy and we will ask for your explicit consent to such processing.

3. WHEN WE DISCLOSE YOUR INFORMATION

VNIMLLC may disclose and/or share your information between members of the VNIMLLC corporate group, and to or with any non-affiliated third parties under the following circumstances:

• Consent.  We may disclose your information to any third parties based on your consent to do so.
• Service Providers.  We may provide access to or share your information with select third parties who perform services on our behalf and for any other legitimate business purpose. These third parties provide a variety of services to us, including without limitation billing, sales, marketing, advertising, market research, customer support, fulfillment, data storage, analysis and processing, and legal services.
• Business Partners.  We may provide your information to individuals and companies with whom we have business relationships to provide you with special coupons, discounts, or promotions, or to offer products and services to you for purchase. We encourage these partners to adopt and post privacy policies. However, the use of your Information by such parties is governed by the privacy policies of such parties and is not subject to our control.
• Protection of VNIMLLC and Others. By using the Services, you acknowledge, consent and agree that we may access, preserve and disclose your information, including, but not limited to, any user content, if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) enforce our Terms of Use, this Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of VNIMLLC , its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
• Business Transfers. As we continue to develop our business, we may buy, merge or partner with other companies. In such transactions, (including in contemplation of such transactions, e.g., due diligence) user information may be among the transferred assets. If a portion or all of VNIMLLC ’s assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets.
• Public Forums. Our Services offer publicly accessible blogs and community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Please also remember that if you choose to provide information on public features of the Services, individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about what you choose to disclose publicly and make sure it’s information you want to share with the public.

4. LEGAL BASIS FOR PROCESSING PERSONAL DATA

The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds for processing your personal data are as follows:

• To Honor Our Contractual Commitments to You. Much of our processing of personal data is to meet our contractual obligations to our customers, or to take steps at customers’ request in anticipation of entering into a contract with them.
• Legitimate Interests In many cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:

• • Customer service
  • Marketing
  • Protecting our customers, personnel and property
  • Analyzing and improving our business
  • Managing legal issues

We may also process personal data for the same legitimate interests of our customers and business partners.

• Legal Compliance. We need to use and disclose personal data in certain ways to comply with our legal obligations.
• Consent. Where required by law, and in some other cases, we handle personal data on the basis of consent. Where we handle your personal data on the basis of consent, you have the right to withdraw your consent.
  

5. PERSONALIZED CONTENT AND ADVERTISING
   
   A. Online and Email Analytics

We may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology previously described in the “Cookies and other electronic technologies” section to help us analyze how users use the Services, including by noting the third-party website from which you arrive, and provide certain features to you. For example, the Google Trusted Store badge displayed on some of the Services is served to you through the use of cookies. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

If you receive email from us, we may use certain tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

          B. Tailored Online and Mobile Advertising

We may personalize the content and advertising that you see when using the Services through the use of third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you provide such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.

In connection with the foregoing, we work with online vendors to set a first-party cookie in your browser to enable us and our partners to collect web viewing data that includes visits to the Services and non-affiliated websites over time. This data may be used to infer whether you share interests with other users, and deliver advertising relevant to those inferences. Also, third parties whose products or services are accessible or advertised via the Services may place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (i) inform, optimize, and serve ads based on past visits to our websites and other sites and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites and use of our Services. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to serve tailored ads to you on the Services, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. We also may share with third-party advertisers a hashed version of your email address, solely in non-human readable form and content that you share publicly when using the services (e.g., user-generated content) for purposes of delivering tailored advertising. We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below. You may receive tailored advertising on your computer through a web browser. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the  Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, the opt-out page of the European Interactive Digital Advertising Alliance, or  TrustArc’s Preference Manager  to opt-out of receiving tailored advertising from companies that participate in those programs. You may also use the links available in advertisements that appear in the Services and learn more about our advertising practices through the About Our Ads link available through the Services.

You can learn more about how Google manages data in its ads products here, through which you can learn how to opt out of Google Analytics for display advertising or customize Google display network ads by visiting the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored.

When using a mobile application you may also receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems to opt-out of tailored in-app advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator. We do not control how the applicable platform operator allows you to control receiving personalized in-application advertisements; thus, you should contact the platform provider for further details on opting out of tailored in-application advertisements. We also may use third-party service providers to deliver advertisements on mobile applications or for mobile application analytics. You can opt-out from third-party interest-based advertising on some Android devices and Google apps by visiting Google Settings, Ads and then click on ‘Disable ads based on interests.’ 

Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out. In that case, the advertising will not be tailored to your interests. Also, we do not control any of the above 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.

       C. Notice Concerning Do Not Track Signals

 Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform online services that they do not want certain information about their webpage visits collected over time and across websites or services. We are committed to providing you with meaningful choices about the information collected on the Services for third party purposes, and that is why we provide links to the Network Advertising Initiative and the Digital Advertising Alliance opt-out pages, as well as choices provided by Google Ads, Google Analytics, and TrustArc. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.

6. YOUR RIGHTS AND CHOICES

You may review and update certain information through your relevant account settings on the Services. For additional assistance with reviewing or modifying information provided to us, contact us as described below.

If you have provided contact information through the Services and decide that you do not want VNIMLLC to use that information for marketing purposes in accordance with this Policy, you can opt out of future use at any time by: (a) going to the link provided at the bottom of any email you receive and opting out of receiving future information; or (b) contacting us as described below. Please note that you may not be able to opt out of emails about your transactions and relationship with us, such as emails regarding your account, requests or inquiries, and purchases of products and/or services.

Individuals in the European Economic Area (“EEA”) and many other jurisdictions have certain legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them, and to obtain its correction, update, amendment, or deletion in appropriate circumstances. You may also have rights to object to our handling of your personal data, restrict our processing of your personal data, and to withdraw any consent you have provided. To exercise these rights, please contact us as described below with the nature of your request. Our security procedures mean that we may request proof of identity before we reveal information. This proof of identity will typically take the form of your e-mail address and any password submitted upon registration. While we strongly encourage you to first raise any questions or concerns about your personal data with us, you also have a right to contact the relevant supervisory authority.

Many of the rights described here are subject to significant limitations and exceptions under applicable law (e.g., objections to the processing of personal data, and withdrawals of consent, typically will not have retroactive effect). 

7. SECURITY

We have implemented administrative, technical, and physical security measures to protect against the loss, misuse and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using Secure Sockets Layer (SSL) technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or our service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure, and although we will do our best to protect your information, we cannot and do not guarantee that the measures we take will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, as no Internet and/or other electronic transmissions can be completely secure and any transmission is at your own risk.

It is important for you to protect against unauthorized access to your password and to your computer so we advise that you sign off when you have finished using a shared computer and strongly recommend that you do not use the browser’s password memory function as that would permit other people using your device to access your information. It is important for you to protect against unauthorized access to your password and to your computer so we advise that you sign off when you have finished using a shared computer strongly recommend and that you do not use the browser’s password memory function as that would permit other people using your device to access your information. We recommend that you change your password periodically.

You are responsible for maintaining the security of your account username and password. You may not provide these account credentials to any third party. If you believe that your account username and/or password have been stolen or been made known to others, you must contact us immediately as described below and change your password immediately. We are not responsible if someone else accesses your account through information that they have obtained from you. To the fullest extent permitted by law, we disclaim all liability and responsibility for any damages you may suffer due to any loss, unauthorized access, misuse or alterations of any information you submit to the Service.

8. DATA RETENTION

We will keep your information only for as long as is reasonably necessary for the purpose that it has been processed, taking into account any legal requirements under Applicable Law. For the avoidance of doubt, we will retain your information to continue offering the Services to you. If you terminate your account, any association between your account and information we store will no longer be accessible through your account. However, if you have engaged in any public sharing prior to termination, that information will remain on our services and accessible to the public. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Information may persist in copies made for backup and business continuity purposes for additional time.

9. INTERNATIONAL USERS

 The Services are operated in the United States and are governed by United States law. If you are a resident of the European Union or other location outside the United States, please be advised that any information you provide through the Services will be transferred to the United States or other designated locations outside of the EEA, which may not have a similar standard for data protection as the laws of your jurisdiction for processing, hosting, and storage by us or our service providers. Where you are accessing Services from an EEA member state, we will take all steps reasonably necessary to ensure that your information is treated securely in accordance with this privacy policy always and at least to the standards required by Applicable Law in the jurisdiction of access.

      10. THIRD PARTY LINKS AND SERVICES

The Services may contain links to third-party websites, applications and other services. Please be aware that we are not responsible for the privacy practices of such other sites and services. We encourage our users to be aware when they leave our Services and to read the privacy statements of each and every site they visit that collects their information. Some of these links may be affiliate marketing links encoded by third parties. This means that we may earn a commission when you click on or make purchases via affiliate links, and affiliate partners may use cookies to understand your use of the Services.

The Services may also include widgets and social media features such as the Facebook “Like” button, which are interactive mini-programs that provide specific services from another company (e.g., displaying the news, opinions, music, etc.). Information such as your email address may be collected through these features. These features may collect your IP address and set cookies to enable them to function properly. We are not responsible for nor do we endorse the privacy practices or the content of such third-party services. Any information you provide via those services is subject to their applicable privacy policies and is not covered by this Policy.

11. YOUR CALIFORNIA PRIVACY RIGHTS

 California Law permits visitors who are California residents to request a list of the third parties to which we have disclosed “personal information” (as that term is defined under applicable California law) for such third parties’ direct marketing purposes.  You are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. You may request the information in writing at [email protected].

12. INFORMATION FROM CHILDREN

The Services are not directed to children under the age of 13 and such children are not permitted to use the Services. If we discover we have received any “personal information” (as defined under the Children’s Online Privacy Protection Act) from a child under the age of 13 in violation of this Policy, we will take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about anyone under the age of 13, please contact us as described below.

13. CHANGES TO THIS POLICY

We reserve the right to change this Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Policy will mean you accept those changes.

14. QUESTIONS ABOUT THIS POLICY

If you have any questions about our Policy, to exercise any of your rights, or for any other privacy-related inquiries, you can contact us at [email protected].