Privacy Policy
Last Updated: March 12, 2023
This Privacy Policy (“Privacy Policy”) describes how The Langston Co. and its subsidiaries and affiliates (“Langston,” “us,” “we,” or “our”) may collect, use, and share your personal information in connection with thelangstonco.com website and any other websites and platforms we own and operate that link to this Privacy Policy (collectively, the “Website”), our related online and offline services, events, social media pages, and email and other electronic communications (collectively, and together with the Website, the “Services”), and in connection with surveys operated by Langston (each, a “Survey”), and the choices you have with respect to your personal information.
This Privacy Policy applies to (i) individuals who visit the Website or use our Services (including our business customers (“Clients”)) (collectively, “Users”), and (ii) respondents who are referred to a Langston Survey(“Respondents” who, together with Users, may be referred to in this Privacy Policy as “you” or “your”). This Privacy Policy does not apply to personal information that Langston collects through a Client-sourced survey (i.e., respondents are our Client’s customers). In that context, Langston processes the information at the direction and on behalf of the Client and respondents should review the Client’s privacy policy. In some cases, region-specific terms may apply to you, which are indicated in the section headings below.
Langston reserves the right, at any time, to modify this Privacy Policy. If we modify how we collect, use, or share personal information, we will post the updated Privacy Policy on this page. In some cases, we may notify you about an update by sending you an email, posting a notice about the update on the Services, or other means as may be required by applicable law. In all cases, your continued use of the Services following posting or other notification of changes constitutes your acknowledgement of such changes. Please review this Privacy Policy periodically to keep up to date on our most current policies and practices.
This Privacy Policy covers the following topics :
COLLECTION OF PERSONAL INFORMATION
SHARING OF PERSONAL INFORMATION
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
CHOICES ABOUT YOUR PERSONAL INFORMATION
SECURITY OF PERSONAL INFORMATION
NOTICE TO CALIFORNIA RESIDENTS (SHINE THE LIGHT LAW)
COLLECTION OF PERSONAL INFORMATION
Personal Information Collected. We may collect the following categories of personal information about you. We may also collect other personal information that is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Users:
· Contact information, such as first and last name, email address, phone number, and mailing address.
· Professional information, such as company name, job title, company location, email, and phone, and other details we may collect about your business or profession.
· Preferences, such as any marketing or communications preferences.
· Order history, such as records of products and services you have purchased from us.
· Transaction and billing data, such as payment amounts and payment methods used to complete transactions, and other relevant information about the financial institutions you use to conduct business.
· Communications, such as the information associated with your requests or inquiries, including for support, assistance, or order information, and any feedback you provide when you communicate with us.
· Online activity information, such as the website you visited before browsing to the Services, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
· Device information, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city, state, or geographic area.
Respondents:
· Online activity information, such as the website you visited before browsing to the Survey, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
· Device information, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city, state, or geographic area.
· Email address, if you choose to provide it in response to a Survey to participate in a Client-sponsored sweepstakes or other promotion.
· Survey responses, which may include certain demographic information (e.g., sex/gender, age, marital status, education, and occupation). In each such case, you know what information you provide and we collect, because you will actively submit the information.
· Web-based interview recording based on your consent, which recording may include your first name, general location, and the survey responses described above.
Respondents that are routed to a Survey through a third-party site or service should consult the privacy policy of such third parties.
Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, a Survey, or otherwise to us.
Sources of Personal Information. We obtain personal information from a variety of sources, including the following sources:
Personal Information You Provide. Langston collects personal information when you voluntarily submit it to us, such as when you fill out a form on the Website, participate in a Survey, or communicate with us.
Personal Information Automatically Collected. Langston, our service providers, and our advertising partners may automatically log information about you, your computer, or mobile device, and your activity over time on our Services and other sites and online services, such as the online activity information and device information listed above. Like many online services, we use cookies and similar technologies to facilitate some of the automatic data collection described above, such as:
Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
Flash cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.
Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
Session replay technologies, which are third-party software that we may use to record a video replay of users’ interactions with the Website. The video replay may include users’ clicks, mouse movements, scrolls, typing, and other activity taken during the session. We use these replays for research and development purposes, such as to help us troubleshoot problems with the Website, understand how users interact with and use the Website, and identify areas for improvement.
For more information, please visit our Cookie Policy.
Personal Information Obtained from Third Parties. Langston may receive personal information from third parties, such as our service providers, advertising partners, data analytics partners, operating systems and platforms, social media platforms, event sponsors, publicly available sources, or data providers. We may merge or combine such personal information with the personal information we collect from you directly or automatically.
· Referrals. Users of the Services may have the opportunity to refer colleagues or other contacts to us and share their contact information. Please do not provide us with someone’s contact information unless you have their permission to do so.
USE OF PERSONAL INFORMATION
We may use personal information for the purposes set forth below and as otherwise described in this Privacy Policy or at the time of collection.
To Provide the Services to Users. We may use personal information to provide our Services and operate our business. For example, we use personal information to:
process your transactions, including purchasing services;
improve and personalize your experience on or with the Services;
verify your identity or determine your eligibility for offers and promotions;
communicate with you, including providing notices about your transaction and responding to any of your requests, feedback, or questions;
provide maintenance and support; and
fulfill any other purpose for which you provide personal information.
Direct Marketing to Users. We may send Users Langston-related or other direct marketing communications as permitted by law, including materials, updates, information, special offers, and promotional material from us and our business partners. You may opt-out of our marketing communications as described in the “CHOICES ABOUT YOUR PERSONAL INFORMATION” section below.
Interest-Based Advertising to Users. We work with third-party advertising companies and social media companies to help us advertise our business and to display ads for our services to Users and prospective Users. These companies may use cookies and similar technologies on our Website to collect information about you (including the online activity information and device information described above) over time across our Services and other websites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. In addition, some of these companies may use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms. You can learn more about your choices for limiting interest-based advertising in the “CHOICES ABOUT YOUR PERSONAL INFORMATION” section below.
Research and Development. We use personal information from Users and Respondents for research and development purposes, including to study and improve the Services and our business, understand and analyze the usage trends and preferences of our Users and Respondents, and develop new benchmarks, features, functionality, and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.
To Comply with Laws and Regulations. We will use personal information of Users and Respondents as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For Compliance, Fraud Prevention, and Safety. We may use personal information of Users and Respondents and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the Services and our business, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Services and Surveys; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With Your Consent. We will disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.
SHARING OF PERSONAL INFORMATION
In addition to the specific situations discussed elsewhere in this Privacy Policy or at the point of collection, Langston may share your personal information with the following entities or persons:
Related Companies. We may share your personal information with our affiliates, subsidiaries, and other related companies.
Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of our business. For example, we work with service providers that help us perform Website and Survey hosting, maintenance services, database management, analytics, fraud protection, marketing, customer relationship management, finances, and other purposes.
Clients. We may share Respondent survey response data with Clients to help them understand consumer trends, identify new audiences and markets, and guide investment or media spend.
Advertising Partners. We may share User personal information with third parties who we partner with for advertising campaigns or that collect information about your activity on the Services for the purposes described in the “Interest-Based Advertising” section above.
Professional Advisors. We may share personal information with persons, companies, or professional firms providing Langston with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.
Law Enforcement. Under certain circumstances, we may be required to disclose personal information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
Authorities and Others for Compliance, Fraud Prevention, and Safety. We may disclose personal information in the good faith belief that such action is necessary to comply with a legal obligation or for the purposes described above in the section titled “Compliance, Fraud Prevention, and Safety.”
Business Transaction Participants. We may disclose personal information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
Langston is based in the United States, and we have service providers in the United States and potentially other countries. Your personal information may be collected, used, and stored in these countries or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein.
Users located in Europe can view more information about cross-border transfers in the section below titled “NOTICE TO EUROPEAN USERS.”
CHOICES ABOUT YOUR PERSONAL INFORMATION
You can make the following choices regarding your personal information:
Review and Request Changes to Your Personal Information. Users may update or correct certain personal information by submitting a request to us using the contact information listed at the end of this Privacy Policy.
Marketing Emails. Users may opt-out of Langston-related emails by clicking the “unsubscribe” link at the bottom of the email or by contacting us as described at the end of this Privacy Policy. You may still receive service-related communications.
Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Services, and our Website or the Survey may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
Analytics. The Website uses Google Analytics to help us analyze how the Website is being accessed and used. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on, available here.
Advertising Choices. You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp) and the Digital Advertising Alliance (https://optout.aboutads.info). Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here.
Many of the opt-out preferences described in this section must be set on each device and/or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Do Not Track. Some browsers may be configured to send “Do Not Track” signals to the online services that you visit. The Website currently does not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
SECURITY OF PERSONAL INFORMATION
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information.
OTHER SITES AND SERVICES
The Services may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.
NOTICE TO CALIFORNIA RESIDENTS (SHINE THE LIGHT LAW)
Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Langston are entitled to ask us for a notice describing what categories of personal information we share with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like a copy of this notice, please submit your request to the email address listed at the end of this Privacy Policy with “Shine the Light” in the subject line.
NOTICE TO NEVADA RESIDENTS
Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us using the contact information listed at the end of this Privacy Policy.
NOTICE TO EUROPEAN RESIDENTS
The information provided in this section applies only to individuals in the European Economic Area and the United Kingdom (collectively, “Europe”). Except as otherwise specified, references to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
Controller. The controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation is The Langston Co., 17th Street
Suite 2800, Denver, CO 80202.
The personal information we collect through a Survey pursuant to your opt-in consent may be shared by Langston with our Clients, and as such, our Clients then become separate and independent controllers of that personal information.
Legal Bases for Processing. The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact us at privacy@thelangstonco.com.
Processing Purpose (as described above in the “Use of Personal Information” section)
Legal Basis
To Provide the Services or Survey
Processing is necessary to perform the contract governing our operation of the Services, or to take steps that you request prior to engaging our services, or to provide Respondents with the requested Survey. Where we cannot process your personal information as required to operate the Services or provide you with the Survey on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interests as further described in this Privacy Policy or, for Surveys, based on your consent.
Research and Development
Processing is based on our legitimate interests in performing research and development as described in this Privacy Policy.
Direct Marketing to Users
Processing is based on your consent where that consent is required by applicable law. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consented or via the relevant Services.
Where such consent is not required by applicable law, we process your personal information for this purpose based on our legitimate interests in promoting our business and providing you with tailored, relevant content.
Interest-Based Advertising to Users
To Comply with Laws and Regulations
Processing is necessary to comply with our legal obligations.
For Compliance, Fraud Prevention, and Safety
Processing is necessary to comply with our legal obligations or based on our legitimate interests in protecting our or others’ rights, privacy, safety, or property.
With Your Consent
Processing is based on your consent. For example, we rely on Respondents’ consent to process their responses. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or via the relevant Services.
Use for New Purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Retention. We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your Rights. European data protection laws may give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information.
Port. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Restrict. Restrict the processing of your personal information.
Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by contacting us at privacy@thelangstonco.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. In the European Economic Area, you can find your data protection regulator here. In the United Kingdom, you can find your data protection regulator here.
Cross-Border Data Transfer. If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us at privacy@thelangstonco.com for further information about any such transfers or the specific safeguards applied.
CONTACTING US
If you have any questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at privacy@thelangstonco.com.