Introduction

Welcome to MELBARR. We are committed to protecting your privacy and ensuring the security of your personal data. Melbarr has created this Privacy Policy to demonstrate our firm commitment to protecting information you submit; we understand that you care about how information about you is used. This privacy policy describes how Melbarr manages personal information collected, received, or maintained.

COLLECTION AND PROCESSING OF DATA

Information you give us

Melbarr collects and stores your registration information, unless you instruct us otherwise. Personal data, such as your name, address, telephone number or e-mail address is not recorded unless you provide this information voluntarily, e.g. in the context of a registration for data sheets, survey, contest or in execution of a contract.

The policy does not apply to any website of any third party, even if the third-party website links to (or is linked from) the website. By accessing, using, and/or submitting information through the Website, you consent to the practices described in this policy with regard to the information collected thereby as described herein. If you do not agree with this policy, you must delete all cookies from your browser cache after visiting the website and refrain from visiting or using the website.

Cookies based information

We use “cookies” whenever we receive and store information you have provided by interacting with us. To find out more about “cookies”, and the interaction dynamics when your browser access our website, and opt-out options, go to “Cookies we use” section.

E-mail Communications:

To help us make e-mails more useful and interesting, we often receive a confirmation when you open or click e-mail from us if your computer supports such capabilities.

COOKIES WE USE

Melbarr may store information in the form of “cookies” on your web browser, to monitor activity, provide a better website experience, optimize our website according to your preferences, to collect information regarding your activities on our website to provide you targeted advertising based upon your interests (pages you visited in our website). Any such information does not include any details pertaining to your personal or any other potentially identifying information. Check your browser’s Help feature to find out how to prevent your browser from accepting new cookies, how to receive new cookie notifications, and how to disable cookies.

We may also derive your approximate location from your IP address. In addition, when submitting information on a website, your submission will be associated with the IP address you are then using, which is automatically assigned to your computer by your Internet Service Provider. If you are using one of the market leading browsers and are uncomfortable accepting cookies from our website, you may erase and/or disable the acceptance of cookies in your browser’s administrative tools. Disabling your browser in this manner may result in a compromised experience of our websites you regularly visit.

The use of cookies by our partners, affiliates, tracking utility company, or service providers is not covered by this Policy. We do not have access or control over these cookies.

Cookies being used for analytics and monitoring website activity:

Google Analytics cookies

We use Google Analytics to analyze user activity to improve our website. For more information about Google Analytics cookies please check the official site

Details Storage

Your Personal data is stored in on-premise CRM which has built in secure Role-based data access. Audit logs are available in order to identify any potential data breaches.

Our clients are also based in the USA, Canada and EU and we ensure that our clients provide an adequate level of data protection as mandated by GDPR.

Apart from this, we at Melbarr have adopted and implemented adequate information system controls and rules as required by GDPR to ensure effective levels of data protection, in particular relating to transfers of personal information outside the EEA.

We generally retain your information for a duration that is reasonably necessary to fulfill the specific business purpose for which it was collected. This may include, but is not limited to, maintaining accurate records of transactions, providing ongoing services, or complying with legal requirements.

Once the necessity for retaining your personal data concludes, we ensure its secure and irreversible deletion. Our data deletion processes adhere to industry best practices and prioritize the protection of your information.

Our website may have links to sites of our partners. Please read the privacy policies of partner websites as they may have different terms of use and privacy policies.

 Advertising and targeting cookies

Melbarr uses advertising networks cookies to deliver user-relevant adverts. We can limit the number of exposures and monitor the effectiveness of an ad campaign by tracking user’s clicks.

Retargeting’ is a particular type of advertising, based on target’s specific interests. It allows our advertising partners to ensure you only see adverts that have a high probability of relevance to you. Screening is based on your online browsing activity.  This enables vendors to advertise to people who have already visited their website. Retargeting cookies are usually placed on your device by third-party advertisers. We provide a link list of such parties we work with.  If you want to opt-out of receiving such ads, follow the listed links, and look for opt-out information.

1. Opting out from receiving targeted advertising does not mean your exposure to advertising will be reduced, but the ads will be less customized to your interests.

• Facebook:https://www.facebook.com/policies/cookies/
• LinkedIn:https://www.linkedin.com/legal/cookie-policy
• Google:https://policies.google.com/technologies/ads

You have the option to  opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. All you have to do is visit the opt-out pages on the NAI website and DAA website and follow opt-out instructions.

SECURITY

Melbarr uses technical and organizational security measures in order to protect the data we have under our control against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.

USE AND DISCLOSURE OF PERSONAL DATA

Melbarr uses any personal data for the sole purpose of technical administration of the websites, customer fulfillment and administration, services surveys and marketing, only to the extent necessary in each specific case. Melbarr does not pass any personal information to outside organizations and/or individuals. We will only disclose your data to governmental authorities in cases where Melbarr in good faith believes that it is required by law.

Disclosures of Public Profiles

We may make any Business Information that our users contribute for inclusion in our Directory, that we collect from public web sources or that we license from third parties available to users of the Site, to our strategic partners and to our customers.

Disclosures to Service Providers

Melbarr may from time to time disclose Business Information or other collected information to service providers, solely for providing functions related to our operation of the Site and for no other purpose. For example:

Melbarr uses software hosted by a service provider to provide us with information regarding our visitors’ activities on our Site. When you visit our Site, that service provider may set cookies on our behalf and may receive information about your browsing activity on our Site.

Disclosures for Legal Reasons

We may disclose collected information, including Business Information, to a third party if we believe in good faith that such disclosure is necessary or desirable: (i) to comply with lawful requests, subpoenas, search warrants or orders by public authorities, including to meet national security or law enforcement requirements, (ii) to address a violation of the law, (iii) to protect the rights, property or safety of Melbarr, its users or the public, or (iv) to allow Melbarr to exercise its legal rights or respond to a legal claim.

Disclosures to a Buyer of the Company

If our company or substantially all of our assets are acquired, or in the event of a merger or bankruptcy, information about you and/or information you provide to Melbarr may be among the transferred assets. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Other Disclosures

If you register for a Melbarr event with a third-party speaker, your information will generally be shared with the speaker.

LEGAL BASIS TO PROCESS YOUR PERSONAL DATA

We have chosen Legitimate Interests as the legal basis for processing personal data due to the following reasons:

Legitimate Interests

• Empowering Better Decision-Making: Our services are designed to assist individuals, specifically B2B decision makers and influencers, in making informed decisions regarding potential collaborations and selecting optimal services for their organizations.
• Publicly Available Non-Sensitive Data: Respecting the privacy of individuals, the information we process is primarily sourced from publicly available data sources and is non-sensitive in nature,
• Focused Marketing in the IT/B2B Space: Our data processing is focused to marketing information related to information technology and B2B solutions exclusively to individuals who fall within these relevant sectors.
• Relevance through Classification: We take a diligent approach to classify organizations and the roles of individuals within them, ensuring that our communications are highly relevant to their professional responsibilities.
• Targeted Selection for Relevance: Individuals are selected for our clients based on a careful assessment of their potential interest in the products and services being offered.
• Easy Opt-Out Mechanisms: We prioritize user control by making it effortless for anyone we communicate with to unsubscribe from future communications via email, phone, or post. We actively encourage third parties we supply data to adopt the same approach.
• Suppression Files and Respect for Preferences: Regular maintenance of suppression files ensures that individual preferences are respected, contributing to a more personalized and respectful communication approach.
• Low Unsubscribe Rates: Our commitment to relevance is reflected in the remarkably low unsubscribe rates from the communications we disseminate, indicating that our content is well-received and not perceived as disruptive or irrelevant.
• Zero Complaints Record: To date, we have not received any complaints from individuals whose data we process, attesting to the ethical and responsible handling of personal information.
• Decade-Long Adherence to Best Practices: With a track record spanning over a decade, Melbarr has consistently adhered to direct marketing best practices, demonstrating our commitment to ethical data processing.

By relying on Legitimate Interests and Consent, we aim to strike a balance between providing valuable services and respecting the privacy rights of individuals, ensuring a trustworthy and mutually beneficial relationship.

Consent

• Transparency and Trust: Obtaining explicit consent from individuals ensures they are fully aware of how their personal data will be used. This builds trust between the organization and its clients or users.
• Individual Control: Consent empowers individuals to have control over their data. They can choose what data to share and how it will be processed, which aligns with the principles of autonomy and self-determination.
• Compliance with Legal Requirements: In certain jurisdictions or for specific types of data (e.g., sensitive data), consent is a mandatory requirement. Using consent as a legal basis helps organizations comply with these regulatory requirements.
• Flexibility in Processing: Consent allows organizations to process data for a variety of purposes, provided these are clearly communicated to the data subject. This flexibility is beneficial when processing involves multiple or evolving purposes.
• Legitimizing Marketing Activities: For activities such as direct marketing or sending promotional content, obtaining consent is often necessary. This ensures that communications are compliant and welcomed by the recipients.
• Mitigating Risks: By relying on consent, organizations can demonstrate that they have taken proactive steps to mitigate the risks of data processing, such as unauthorized access or misuse of personal data.
• Revocability: Consent provides a clear mechanism for individuals to withdraw their agreement to data processing, giving them the ability to change their preferences at any time. This revocability is a strong aspect of individual rights protection.
• Ethical Considerations: Using consent as a legal basis aligns with ethical practices in data handling, showing respect for the individual’s choices and ensuring that data processing is carried out with their explicit permission.

CASL COMPLIANCE

Canadian Anti-Spam Policy (CASL): CASL is an anti-spam law that applies to all electronic messages (i.e. email, texts) organizations send in connection with “commercial activity.” Its key feature requires Canadian and global organizations that send commercial electronic messages (CEMs) within, from or to Canada to receive consent from recipients before sending messages.

Note- CASL does not apply to CEMs that is simply routed through Canada.

Melbarr is committed to compliance with Canada’s Anti-Spam Law (“CASL”). We take important steps to ensure our customers and others who receive communications from us do not encounter spam. We only send Commercial Electronic Messages (CEMs) in compliance with the Anti-Spam Policy. Melbarr ensures our internal policies and procedures address and adhere to CASL compliance.

A CEM sent by Melbarr is an electronic message that encourages participation in a commercial activity.

How does Melbarr protect you from receiving spam?

CEMs sent, or caused to be sent, from Melbarr do not:

• Use or contain invalid or forged headers or non-existent domain names;
• Employ any technique to otherwise misrepresent or obscure the sender of the message, the point of origin or the transmission path for the message;
• Contain false or misleading information in the subject line or otherwise contain false or misleading content;
• Use a third party’s Internet domain name, or relay from or through a third party’s equipment, without permission of the third party; or
• Attempt to surprise or confuse you. Melbarr makes best efforts to ensure that you have either directly provided consent, or that implied consent has been established via providing us your email, publicly disclosing your email and/or establishing a business relationship via requesting our products (print or digital). All CEM’s are verified for relevance to your job title and/or industry.

Melbarr does not knowingly do business with any company that participates in sending spam. Melbarr will not directly provide or exchange your email address information with any other organization.

In the unlikely event that you receive any messages from Melbarr that may be considered spam, please contact us at info@mel-barr.com and the matter will be investigated. All Melbarr staff are aware of this Anti-Spam Policy, are appropriately trained, and are required to ensure that CEMs receive appropriate approval from the Compliance Officer before being sent to any of our lists. Appropriate disciplinary action will be taken in the event that this procedure is not followed.

THE GENERAL DATA PROTECTION REGULATION GDPR FOR EU RESIDENTS

Melbarr is committed to ensuring compliance with the EU GDPR and UK DPA in accordance with business requirements. Our organization processes data  in strict adherence to the necessary norms and guidelines outlined by these regulations. We prioritize the protection and privacy of personal data, implementing robust measures to safeguard information and uphold the rights of individuals. Under GDPR there are six grounds to process personal data, these are equally valid. There are two of these which are relevant to our business (direct B2B marketing) they are: consent or legitimate interest. As Recital 47 of the GDPR states that “The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest.” Using legitimate interest as the basis for B2B marketing involves ensuring key conditions are met:

“The processing must relate to the legitimate interests of your business or a specified third party, providing that the interests or fundamental rights of the data subject do not override the business’ legitimate interest.”

“The processing must be necessary to achieve the legitimate interests of the organization.”

Along with the above compliance, Melbarr DOES NOT share personal data with customers / partners, RECORDS all data processing activities, DON’T SOURCE any sensitive information such as religion, political inclinations, gender, age etc., has an EXPLICIT OPT-IN, OPT-OUT process.

Melbarr operates with a dual role, acting as data controller and as a data processor, adapting to the specific nature of our collaborations. This flexible approach demonstrates a commitment to tailoring roles to specific collaborative requirements, ensuring transparency, compliance, and trust in all data processing activities.

As a ‘data processor’, Melbarr follows the following data privacy requirements honoring the GDPR law (Article 13 and 14). Melbarr provides notice to all data subjects as required by GDPR Article 13 or 14, as appropriate, and honors the rights of data subjects provided in Articles 12-23, including the right to be forgotten.

CALIFORNIA CONSUMER PROTECTION ACT CCPA FOR CALIFORNIA RESIDENTS

The CCPA applies to any business, including any for-profit entity that collects consumers’ personal data, which does business in California, and satisfies at least one of the following thresholds:

• Has annual gross revenues in excess of $25 million;
• Buys or sells the personal information of 50,000 or more consumers or households; or
• Earns more than half of its annual revenue from selling consumers’ personal information.[10]

Organizations are required to “implement and maintain reasonable security procedures and practices”[11] in protecting consumer data.

Melbarr complies with the recent CCPA act by processing data along the CCPA norms as follows

Under CCPA the following are the rights of the consumers:

• Right to Know: Consumers can request that businesses disclose the categories and specific pieces of personal information they have collected, the sources of that information, the purposes for collecting it, and the third parties with whom it is shared.
• Right to Delete: Consumers can request the deletion of personal information that a business has collected from them, with some exceptions.
• Right to Opt-Out: Consumers can direct businesses not to sell or share their personal information.
• Right to Non-Discrimination: Consumers have the right to receive equal service and pricing from businesses, even if they exercise their privacy rights under the CCPA.
• Right to Correct: Consumers can request the correction of inaccurate personal information that a business holds about them.
• Right to Limit Use of Sensitive Personal Information: Consumers can limit the use and disclosure of their sensitive personal information.

 

FREEDOM OF CHOICE

Melbarr would like to get in contact with you to provide you information about products we represent and marketing services. If you register yourself on our websites, we will request that you state whether you would like to receive this kind of information from us. Additionally, you can inform us at any time that you do not want to receive this kind of information, so that we can specifically prohibit the use of your data accordingly.

FREEDOM OF INFORMATION AND CONTACT

You have the right to know the personal data we hold about you and the right to have your data corrected or deleted. Please address all your requests or queries to our web manager at info@mel-barr.com

CHANGES TO THIS PRIVACY POLICY

We may modify, alter, or update this Privacy Policy at any time, so we encourage you to review this policy frequently. We will not provide individual notice to you of changes to this Privacy Policy.

CONTACT US

In case of any query, questions the consumer is requested to contact Melbarr via email at info@mel-barr.com.