This Notice is effective as of February 1^st, 2025.

Ibis Public Sector, Inc. (“We,” “Our,” or “Us”) respects the privacy and security of your personal information.  The following describes how we collect, use and disclose information and what rights you have to it.  This Privacy Policy describes our practices in connection with information that we collect from you through our software applications, products, services, websites and mobile applications (“Services”) and from sources other than our Services including, but not limited to, the telephone, e-mail and mail.  By providing information to us and/or using the Services, you acknowledge and agree to the terms and conditions of this Privacy Policy.  If you do not agree to these terms and conditions, please do not submit to us any information or use any of our services.

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us.  

The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act, the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), and the Utah Consumer Privacy Act (“UCPA”) provides residents of their respective states with additional rights with respect to their personal data.  Those rights are explained below in Section 6 (Your Rights). 

This Privacy Notice includes certain disclosures required under applicable U.S. laws. Please note that the rules implementing some of these laws have not yet been finalized. We are committed to continual compliance with these laws and will update our processes and this notice as the rules are finalized and the law requires.

In this Privacy Notice, the term “personal data” has the meaning ascribed to it under applicable U.S. laws and includes the term “personal information” as defined by the California Consumer Privacy Act of 2018, as amended.

Information We May Collect

The type of information we collect will depend on the circumstances and the service you are using. Generally speaking, we will collect information relating to you and/or your use of our services in the following ways:

Contact data

We collect information when you contact us. We may also collect any personal data you provide if you post a comment or make a request.

Commercial and Preference Information

We may collect information about our contact history with you and your preferences.

Marketing and Communications preferences

We may collect information about your preferences in receiving marketing information from us and your communication preferences.

Social Media Platforms

If you post to one of our pages on a social media site or connect to a social media platform from our website, we may receive information, including information contained in your social media profile. You acknowledge and understand that we can access this information even when you are not actively using the services. We may also receive information about you if other users of social media give us access to their profiles and you are one of their “connections.”

How We Use This Information

Except where prohibited by law or court order, we may use your personal data for the following purposes:

• to deliver the specific information or services you have requested;
• to enable the download of our content;
• to send you newsletters and advertising messages (these may contain information relating to our brands and services);
• to respond to your requests and feedback;
• other purposes for which we seek your consent; and
• to protect us, our websites, customers, employees, and business partners from fraud or other malicious activity.

If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with the following additional information about: (1) the purpose for which we use each category of “personal information” (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information. 

As noted above, in this Privacy Notice, the term “personal data” has the meaning ascribed to it under applicable U.S. laws and includes the term “personal information” as defined by the California Consumer Privacy Act of 2018, as amended.

In the table below we set out further information about the purposes for which we may use your personal data and the categories of third parties that the personal data is disclosed. In the second column, we also specify how such personal data is categorized under applicable U.S. laws.

Personal data is “sold” when it is provided to a third-party for monetary or other valuable consideration for purposes that are not a “business purpose,” as set forth in the CCPA or other applicable U.S. state privacy laws.  Personal data is “shared,” as defined under the CCPA and other applicable U.S. state laws, when it is provided to a third-party for personalized advertising purposes.  We do not “sell” or “share” your personal data to any third-party and have not done so in the past twelve (12) months.

We may use personal data to create deidentified or aggregated data which does not identify you or any other individual. We may use and disclose this anonymous or aggregated data as we choose.

Information Sharing and Disclosing

Information shared within our group of companies 

We are a globally operating media group consisting of multiple companies. Therefore, we may from time to time disclose your personal data within our group of companies. 

Information shared with our third-party service providers

We use a number of third parties to perform business functions on our behalf, such as sending our newsletters and hosting our online services and customer relationship management. We will disclose personal data to these vendors and service providers to enable them to provide their services. 

Information shared due to corporate mergers or restructuring

We may disclose personal data with any successor to all or part of our business. For example, if part of our business is sold, we may give our customer list as part of that transaction. 

Information shared with other parties as required by law or to prevent or investigate illegal activities

Where required or permitted by law, personal data may be provided to others, such as regulator and law enforcement agencies, for example in response to a court order or a subpoena, or in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent or take action regarding illegal activities or to protect us, our websites, customers, employees, and business partners from fraud or other malicious activity, and as otherwise required by law. We might share your personal data in order to enforce our agreements and to protect our rights and/or the rights of others. We might share your personal data when we are investigating potential fraud. 

We may use and share personal data as otherwise disclosed to you from time to time when collecting your personal data or as otherwise permitted by law. 

Where and When We Send Information 

We are a globally operating media group consisting of multiple companies. Therefore, we may from time to time disclose your personal data within our group of companies. Some of our group companies are located inside the European Union (“EU”) or European Economic Area (“EEA”), and we implement and maintain policies designed to ensure the security of such disclosures and transfers in accordance with the applicable privacy and data protection laws.

If you reside in the EU or EEA, we will only transfer your personal data outside the EU or EEA where we are satisfied that adequate levels of protection are in place designed to protect the integrity and security of any information being processed in compliance with applicable privacy and data protection laws. These measures may include, as applicable, the use of standard contractual/data protection clauses adopted by the European Commission and where transfers are to the United States of America, the EU-US Privacy Shield, Swiss-US Privacy Shield or your consent. Where we transfer personal data between our group companies we have covered these transfers by entering into standard contractual clauses adopted by the European Commission.  

You may request further information on the measures used for such transfers via the contact details given in this Privacy Notice.

Retention of your Information

We retain information for different periods of time depending on the purposes for which we collect and use it, as described in this Privacy Notice. We will delete or de-identify information when it is no longer needed to fulfill these purposes unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing your information.

Your Choices

You have certain choices about how we use your information. 

You may choose not to receive marketing communications from us. You can ask us to stop such messages at any time by clicking on the “unsubscribe” link at the bottom of the message.  Please note that even if you choose not to receive marketing communications from us, you still may receive non-marketing communications, such as responses to your inquiries or notices regarding your account or our relationship with you.

Notice Concerning Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our websites for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above, and in our Cookies Notice. Some web browsers offer users a “Do Not Track” privacy preference setting in the web browser. We do not currently recognize or respond to browser initiated Do Not Track signals. 

Your Privacy Rights

The California Consumer Privacy Act (“CCPA”), as amended, the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), and the Utah Consumer Privacy Act (“UCPA”) provides residents of their respective states with additional rights with respect to their personal data. 

Depending on where you live and what you are asking us to do, we may or may not be obligated to comply with your request, and/or the time required to complete a request may vary.  Based on how we collect and utilize your personal data, you may have the following rights:

• Right to Access – You have the right to request that we provide you with a copy of the specific pieces of personal data we collected about you over the past 12 months.
• Right to Delete – You have the right to request that we delete your personal data that we maintain about you, subject to certain exceptions.
• Right to Correct – You have the right to request that we correct inaccurate personal data that we maintain about you, subject to certain exceptions.
• Right to Non-Discrimination – You have the right to not receive discriminatory treatment for the exercise of your private rights.

You can submit these requests by emailing us at info@ibispublicsector.com or calling (+1) (312) 529-3500. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal data as permitted by law, such as for record keeping purposes, to maintain an active account, and to process facilitate customer requests. Note that for purposes of these requests under this Privacy Notice, personal data does not include information we have collected as a service provider to our clients. Finally, please note that we are required by California Civil Code section 1798.105(d) to keep a record of your request. 

Only you, or a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above. You may also make a request on behalf of your minor child.

The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information (including information that reasonably enables us verify the identifying information we currently maintain about you) that allows us to reasonably verify that you are the person about whom we collected the personal data or an authorized representative.

We will respond to consumer requests in a reasonably timely manner. If we require extra time to respond, we will inform you of the reason and extension period in writing. In order to protect the security of your personal data, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. The method used to verify your identity will depend on the type, sensitivity and value of the information, including the risk of harm to you posed by any authorized access or deletion. Generally speaking, verification will be performed by matching the identifying information provided by you to the personal data that we already have.  

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request (and will not be made more than twice in a 12-month period). If we cannot comply with a request, or cannot fully comply with a request, the response we provide will also explain the reasons we cannot comply. If we deny your request in whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with information regarding the appeals process. 

How We Protect Your Personal Data

We have reasonable security measures in place to help protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

We have implemented reasonable, industry-standard security policies, standards and practices designed to protect information from internal and external threats. The degree of protection for each piece of information is based on the risk and consequences associated with having that information compromised. While no security measures will provide for absolute security, all of our employees responsible for the management of information have the responsibility to adhere to our documented security controls, which are developed commensurate with the understood risk.

Our Responsibility for Website Links

This Privacy Notice is limited to the personal data collected by us. We do provide links within this site to other websites, including social media sites, such as LinkedIn. If you follow these links, your use of these sites will be governed by their applicable user and privacy notices since their data practices fall outside the scope of this Privacy Notice. Further, we can have no responsibility for or control over the information collected by any third-party website and we cannot be responsible for the protection and privacy of any information which you may provide on such websites.

Children 

This website is not intended for children aged 16 or under. We do not actively seek to collect personal data about children aged 16 or under. If you have any concerns about your child’s privacy in relation to our services, or if you believe that your child under the age of 16 may have entered personal data onto our website, please contact us at info@ibispublicsector.com. We will delete such personal data from our records or seek verifiable parental or legal guardian consent to retain such information within a reasonable time.

Updates

This Privacy Notice may be updated from time to time to reflect changes in law, best practice or a change in our practices regarding the treatment of personal data.  The date of the most recent revision will appear at the top of this page. If you do not agree to the changes, please do not continue to use our services and please refrain from sharing your personal data with us. You should check this notice frequently for updates.

Contact Us

We welcome your questions, comments, and concerns about this Privacy Policy and our privacy practices.  Please give us feedback by contacting us at (312) 529-3500 or by writing to the following address:

Ibis Public Sector, Inc.

106 N. Lee Street, Suite 203

Alexandria, VA 22314

Or by email at:  info@ibispublicsector.com