PRIVACY POLICY

Introduction

This policy describes the types of information Eban Howell, LLC, d/b/a Santiago Media (“Company” or “We”) may collect from you or that you may provide when you visit www.santiago-media.com (the “Website”) or use our services, and our practices for collecting, using, maintaining, protecting, processing, and disclosing that information.

This policy applies to information we collect:

• On this Website;
• In email, text, and other electronic messages between you and this Website; and/or
• When you sign up for and use our services.

It does not apply to information collected by:

• The Company offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy when using this Website for updates.

Children under the age of 18

Our Website is not intended for children under eighteen (18) years of age. The Website and the services, content, information and programs provided or made available on and/or through the Website may not be accessed or used by any individuals that are not at least 18 years of age. No one under age 18 may provide any information to the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website, or provide any information about yourself to us, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at inquiries@santiago-media.com

Transfer of information to the U.S. and other countries

We are based in the United States, and the information we collect is governed by U.S. law. By accessing or using the Website, or otherwise providing information to us, you consent to collection, processing, transfer and storage of information about you in and to the United States and other applicable territories in which the privacy law may not be as comprehensive as or equivalent to the law in your country of residence. Please use the contact information below if you have a question or concern about the policies or manner in which we treat your personal information.

Information we collect about you, and how we collect it

We collect and process your information for purposes based on legitimate business interests, the fulfillment of our agreements with you, compliance with our legal obligations, and/or your consent. We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, business entity name, and e-mail address, and any other identifier by which you may be contacted online or offline (“personal information”);
• That is about you but individually does not identify you; and
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us;
• Automatically as you navigate through the site (information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies); and/or 
• From third parties, for example, our service providers.

Information you provide to us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website;
• Records and copies of your correspondence (including email addresses), if you contact us; and/or
• Details of your agreement for our services.

Third-party use of cookies and other tracking technologies

Some content or applications on the Website are served by third-parties, including advertisers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services.

• By way of example but not limitation, we use Google Analytics which may collect data automatically. This Website will prompt you to opt-in to allow Google Analytics to use automatic tracking technologies during your visit. You may change your cookie preferences at any time using the link at the footer of every page marked “Set your cookie preferences”. For more information on how Google uses your data through Google Analytics please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners.

We do not control third parties’ tracking technologies or how they may be used.

Some web browsers may transmit “do not track” signals to the websites and other online services with which the browser communicates. There is no standard that governs what, if anything, websites and online services should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard for responding is established, we may revisit our policy accordingly.

Third-party use of cookies and other tracking technologies

Some content or applications on the Website are served by third-parties, including advertisers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services.

• By way of example but not limitation, we use Google Analytics which may collect data automatically. This Website will prompt you to opt-in to allow Google Analytics to use automatic tracking technologies during your visit. You may change your cookie preferences at any time using the link at the footer of every page marked “Set your cookie preferences”. For more information on how Google uses your data through Google Analytics please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners.

We do not control third parties’ tracking technologies or how they may be used.

Some web browsers may transmit “do not track” signals to the websites and other online services with which the browser communicates. There is no standard that governs what, if anything, websites and online services should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard for responding is established, we may revisit our policy accordingly.

How we use your information

We use information that we collect about you or that you provide to us, including any personal information:

• To fulfill or meet the reason you provided the information (for example, if you share your name and contact information to ask a question about our services, we will use that personal information to respond to your inquiry);
• To provide, support, personalize, and develop our Website and services;
• To provide you with information or services that you request from us;
• To help maintain the safety, security, and integrity of our Website and services, databases and other technology assets, and business;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• Onward Transfers:  To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users or customers is among the assets transferred;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• To notify you about changes to our Website or services;
• In any other way we may describe when you provide the information; and
• For any other purpose with your consent.

If you opt-in to receive such correspondence, we may also use your information to contact you about our own goods and services that may be of interest to you. If you do not want us to continue to use your information in this way, you may opt-out at any time by emailing your request to inquiries@santiago-media.com. For more information, see Choices About How We Use and Disclose Your Information.

We retain your information for only as long as we need it to provide our services, for purposes described in this Privacy Policy, for our own administration and internal business purposes, and for any periods that are mandated by law, after which, we take steps to delete or anonymize your information.

Disclosure of your information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or that you provide as described in this privacy policy:

• To our subsidiaries and affiliates;
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
• Onward Transfers:  To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users or customers is among the assets transferred;
• To fulfill the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information; and
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• To enforce or apply our Terms of Use, available at www.santiago-media.com/terms-of-use/ and other agreements, including for billing and collection purposes; and
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

We do not sell you personally-identifiable information to third parties.  The only exception to this is in connection with an onward transfer, which is described above.

Choices about how we use and disclose your information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Promotional Offers from the Company. We will not send you emails or newsletters about our products or services unless you opt in (meaning you consent and choose to “opt in” to receive those advertisements).  If you do not wish to have your email address or contact information used by the Company to promote our own products or services, you can opt-out by emailing your request to inquiries@santiago-media.com. If we have sent you a promotional email, you may unsubscribe when that option is available to you, or you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of using our services, or other transactions.

If you are resident in the European Economic Area and you believe we are unlawfully processing your information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: inquiries@santiago-media.com. However, please note that we do not currently sell data triggering that statute’s opt-out requirements.

Accessing and correcting your information

You may send us an email at inquiries@santiago-media.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may request specific information from you to confirm your identity. We will respond to your verified requests in a reasonable timeframe, and in any event in less than 30 days.

Data security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to our privacy policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify users by posting the date of the changes at the footer of every page of the Website and/or by notice posted on the website requesting click-through consent. The date the privacy policy was last revised is identified at the top of the page. All users are responsible for periodically visiting our Website and this privacy policy to check for any changes.

Contact information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Santiago Media
PO Box 1103
Shelter Island Heights
New York 11965

or via email:
inquiries@santiago-media.com

© 2021 Santiago Media