Madison Performance Group Privacy Policy
Effective on: July 30, 2024
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Introduction and Scope
488 Performance Group Inc. d/b/a Madison Performance Group (“Madison”, “we”, “us”, “our”) takes the protection of personally identifiable information (“Personal Data”) very seriously. This Privacy Policy (the “Policy”) addresses data subjects whose Personal Data we may process on behalf of our customers in the course of providing, implementing, and supporting our Maestro web application, including our merchandise catalog (collectively, the “Services”). This Policy does not apply to Personal Data we collect by other means, such as Personal Data that we receive directly through our marketing website(s) or the Personal Data of our employees.
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Controllership
Madison acts as an agent, also known as a data processor, for the Personal Data we process for our customers when providing our Services. This means that our customers determine the type of Personal Data they provide for us to process on their behalf. We typically have no direct relationship with the individuals whose Personal Data we receive from our customers.
Basis of Processing
Within the scope of this Policy, we process Personal Data based on the instructions of our customers.
How We Receive Personal Data
We may receive your Personal Data when:
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you provide it directly to us as part of using our Services;
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our customers (including their employees, contractors, and other representatives of the company) provide it to us; or
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our service providers provide it to us.
Categories of Personal Data
We may process the following types of Personal Data:
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Log-in information, such as username and password;
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Profile information;
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Contact information, such as email address and postal addresses;
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Professional information, such as employer company and position; and
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Shipping information.
Purposes of Processing
We may process your Personal Data for the purposes of:
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Allowing users to log on to and use the Service;
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Populating and modifying profiles;
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Allowing users to enter contests;
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Tracking points and allowing users to spend points;
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Tracking various milestones; and
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Tracking and establishing incentive, reward, and recognition programs.
Data Retention
We retain Personal Data for as long as instructed by the respective customer (who typically acts as a data controller). We delete the Personal Data submitted to us within six months of the end of our service agreement with the customer, unless applicable laws or the specific agreement with that customer require otherwise.
Sharing Personal Data with Third Parties
We may share Personal Data with our service providers, who process Personal Data on our behalf, and who agree to use the Personal Data only to assist us in providing our Services or as required by law. Our service providers may provide:
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Internet hosting services;
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cloud storage services;
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call center services; and
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merchandise vendor services.
Some of these third parties may be located outside of the United States. However, before transferring your Personal Data to these third parties, we will either ask for your explicit consent or require the third party to maintain at least the same level of privacy and security for your Personal Data that we do. We remain liable for the protection of your Personal Data within the scope of our Data Protection Framework certification that we transfer to third parties, except to the extent that we are not responsible for the event that leads to any unauthorized or improper processing.
Other Disclosure of Your Personal Data
We may disclose your Personal Data to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). We may also disclose your Personal Data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring. Finally, we may disclose your Personal Data to our subsidiaries or affiliates, but only if necessary for business purposes, as described in the section above.
We reserve the right to use, transfer, sell, and share aggregated, anonymous data for any legal business purpose. Such data does not include any Personal Data. The purposes may include analyzing usage trends or seeking compatible advertisers, sponsors, and customers.
If we have to disclose your Personal Data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your Personal Data.
Cookies
A “cookie” is a small file stored on your device that contains information about your device. We may use cookies to provide basic relevant ads, website functionality, authentication (session management), usage analytics (web analytics), and to remember your settings, and generally improve our websites and Services.
We use session and persistent cookies. Session cookies are deleted when you close your browser. Persistent cookies may remain even after you close your browser, but always have an expiration date. Most of the cookies placed on your device through our Services are first-party cookies, since they are placed directly by us.
If you would prefer not to accept cookies, you can change the setup of your browser to reject all or some cookies. Note, if you reject certain cookies, you may not be able to use all of our Services’ features. For more information, please visit https://www.aboutcookies.org/.
You may also set your browser to send a Do Not Track (DNT) signal. For more information, please visit https://allaboutdnt.com/. Please note that our Services do not have the capability to respond to “Do Not Track” signals received from web browsers.
Data Integrity & Security
We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect Personal Data from unauthorized processing. This includes unauthorized access, disclosure, alteration, or destruction.
Access & Review
If we process your Personal Data, you may have the right to request access to (or to update, correct, or delete) such Personal Data.
If we have received your Personal Data in reliance on the Data Protection, you may also have the right to opt out of having your Personal Data shared with third parties and to revoke your consent to our sharing your Personal Data with third parties. You may also have the right to opt out if your Personal Data is used for any purpose that is materially different from the purpose(s) for which it was originally collected or which you subsequently authorized. To submit these requests or raise any other questions, please contact us by using the information in the “Contact Us” section below.
EU-U.S., UK Extension, and Swiss-U.S. Data Privacy Frameworks
Madison complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Madison has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Madison has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.
To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
Dispute Resolution
Where a privacy complaint or dispute cannot be resolved through our internal processes, we have agreed to participate in the VeraSafe Data Privacy Framework (DPF) Dispute Resolution Procedure. Subject to the terms of the VeraSafe Data Privacy Framework Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Data Privacy Framework Dispute Resolution Procedure, please submit the required information here: https://verasafe.com/privacy-solutions/data-privacy-framework-dispute-resolution-program/
Binding Arbitration
If your dispute or complaint can’t be resolved by us, nor through the dispute resolution program established by VeraSafe, you may have the right to require that we enter into binding arbitration with you under the Data Protection Framework’s “Recourse, Enforcement and Liability Principle” and Annex I of the Data Protection Framework.
U.S. Regulatory Oversight
Madison is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
Changes to this Policy
If we make any material change to this Policy, we will post the revised Policy to this web page. We will also update the “Effective” date. By continuing to use our Services after we post any of these changes, you accept the modified Policy.
Contact Us
If you have any questions about this Policy or our processing of your Personal Data, please write to our Privacy Department by email at privacy-madison@madisonpg.com or by postal mail at:
Privacy Department
Madison Performance Group
315 Madison Avenue, Suite 4056
New York, NY 10017
USA
Please allow up to four weeks for us to reply.
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European Union Representative
We have appointed VeraSafe as our representative in the EU for data protection matters. While you may also contact us, VeraSafe can be contacted on matters related to the processing of Personal Data. To contact VeraSafe, please use this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative/ or via telephone at: +420 228 881 031.
Alternatively, VeraSafe can be contacted at:
VeraSafe Ireland Ltd
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland
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VeraSafe Netherlands BV
Keizersgracht 555
1017 DR Amsterdam
The Netherlands
VeraSafe Czech Republic s.r.o.
Klimentská 46
Prague 1, 11002
Czech Republic
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Data Protection Officer
We have appointed VeraSafe as our Data Protection Officer (DPO). While you may contact us directly, VeraSafe can also be contacted on matters related to the processing of Personal Data. VeraSafe’s contact details are:
VeraSafe
100 M Street S.E., Suite 600
Washington D.C., 20003
USA
Email: experts@verasafe.com