Privacy Policy

Effective Date: August 1, 2020

California Privacy Notice Jump To Section

Notice for Individuals Located in EU Jump To Section

Incunabulum LLC adopted this Privacy Policy to reflect our commitment to protecting the privacy of your personal information. Please carefully read this Privacy Policy and our related Terms of Service before you provide any personal information.

If you have questions regarding the Services or our privacy practices that are not answered in this Privacy Policy, please email us or Incunabulum LLC, Attn: Privacy Dept., 23055 Sherman Way, Box 5069, West Hills CA 91308. For more information about how to exercise your privacy rights, please see YOUR CHOICES ABOUT YOUR PERSONAL INFORMATION below.

Relating to this Privacy Policy, the following terms are defined as follows:

• “Events” means conferences, festivals, or other events (including virtual events and webinars) organized by us.
• “Magazines” means mg Magazine and CBD Today Magazine.
• “Services” means our Websites and mobile applications that make available the content from our magazines, news, and other information pertaining to the cannabis industry.
• “Suppliers” means suppliers of products and services that help us make the Services available for you, such as web hosting, advertising technology, data analytics, and forensics, virtual event hosting, marketing, and information security.
• “Websites” means inc-media.com, mgmagazine.com, and cbdtoday.com.
• “User” means any individual who accesses and uses the Services.

HOW THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to the Services offered by Incunabulum LLC.

Our agreements with certain customers may contain provisions about the processing of personal information collected through the Services. If a provision of one of these customer agreements conflicts or otherwise is inconsistent with a provision of this Privacy Policy, then the provision of the customer agreement will prevail but solely to the extent of the conflict or inconsistency. If you have a question about whether your personal information is covered by a customer agreement, please contact us.

The Services may include links to websites and services that are not operated by us. A link to a third-party website or service does not mean that we reviewed or endorsed its privacy practices. If you visit a third-party website or service, you are subject to its privacy practices and policies, not ours. This Privacy Policy does not apply to any personal information that you provide to these other websites and services.

CHANGES TO THIS PRIVACY POLICY

The Effective Date at the top of this page indicates when this Privacy Policy was last revised. Unless applicable law prevents or a revision is needed to protect the privacy or security of our Users, we will notify you about any material change that reduces your privacy right in advance so that you have time to review the changes before they are effective. The previous version of this Privacy Policy shall apply before the Effective Date. Your use of the Services after the Effective Date means that you accept the Privacy Policy as revised.

PERSONAL INFORMATION THAT WE COLLECT

The personal information that Incunabulum LLC collects through the Services depends on how the Services are used:

• When a subscription to a magazine is purchased, Incunabulum collects the name, email address, and postal service address of the subscriber. If a subscription is purchased as a gift, we also collect the purchaser’s information.
• If you create an account, Incunabulum collects your name, email address and also may collect business name and title, postal address, and other information requested or required to create the account.
• If you use ad-blocking software, we may require you to register, or whitelist, the relevant Website in order to gain access to our content.
• If you register for an Event through one of our Websites, Incunabulum collects your name, business name and title, email address, postal address, and other information that you are required or choose to provide to complete the registration.
• When you choose to enter a contest or sweepstakes or complete a survey, Incunabulum collects your name, business name and title, email address, postal address, and other information that you provide when you enter or complete a survey.
• If you request customer support, the information that Incunabulum collects depends on your support request but typically includes your name, telephone number, email address, and other information that you provide so that we can troubleshoot.
• When you connect with us through a social media platform, we may, depending on your privacy settings, collect information associated with your social media account.

When you use our provided Services, we automatically collect information about how you access the Services and which Service you use through cookies and other data collection tools. Depending on your privacy and operating system settings, automatically-collected information includes: Internet Protocol (IP) address; MAC address; the make, model and operating system version of the computer or mobile device (“Device”) you use to access the Services; browser type and language; country and time zone in which the Device is located; mobile network information; internet service provider; and metadata stored on the Device. Some of this automatically-collected information is personal information.

We may supplement the information you provide to us with information that is collected from our Suppliers and other sources as described below. All of this information is treated as personal information when it directly or indirectly identifies an individual natural person.

HOW WE USE PERSONAL INFORMATION

Generally, we use the personal information we collect from or about Users to provide more meaningful editorial and advertising content, to advertise products and services that we think may interest you, to maintain and improve the Services, and for other lawful purposes. More specifically, we use personal information to:

Administer the Services

• Provide you with products and/or customer support
• Respond to your requests and inquiries
• Create and manage your account
• Fulfill orders for the services or merchandise that you purchase through the Services or communicate with the Suppliers that help us complete these transactions

Advertise the magazines and other products and services that we and our customers offer to

• Ensure that our advertising is properly displayed on the Services and other websites
• Identify advertising that we think may interest you
• Track advertising tailored to your interests on the Services and other websites

Perform services for our customers

• Help our customers develop content based on inferred user interest
• Display advertisements in the Magazines and Websites
• Fulfill advertising related requests that our customers purchase

Improve our services and develop new ones

• Administer focus groups and surveys
• Conduct research and analysis of Users’ behavior to improve the Services
• Identify and repair bugs in the Services
• Develop new features

Prevent, detect and fight illegal or unauthorized activities

• Address suspected or detected unauthorized and illegal activity on or through the Services, such as scraping, spam, or fraud
• Analyze data related to fraudulent activities to prevent recurrences and design countermeasures
• Detect security incidents

For legal compliance

• Enforce or exercise our rights, for example, our Terms of Service
• Audit our and our Suppliers’ compliance with applicable law

HOW WE SHARE INFORMATION

With our Suppliers

Our Suppliers help us to operate and improve the Services. Our Suppliers support technical processing operations, such as data hosting and maintenance, virtual event hosting, analytics, customer care, securing our data and systems, marketing, and detecting and preventing spam and intellectual property infringement.

With order fulfillment vendors

For the convenience of our Users, we may provide the opportunity to purchase certain goods and services through the Services. We partner with order fulfillment vendors for payment processing and order fulfillment. These vendors will request information from you and process it according to their own privacy policy and other terms. Some of the vendors also may share your information with us. We are not responsible for the processing of your personal information or the fulfillment of your order when a vendor’s own privacy policy and terms apply.

With advertising technology providers

Third-party advertising technology providers (some of which are Suppliers) help us to serve and track digital advertisements through the Services and on third-party digital services. Advertising technology providers use cookies and other data collection tools to collect information about your interaction with the Services and digital advertisements and combine this information from other sources in order to deliver digital advertisements about goods and services that are targeted to your interests (as inferred from your online activity).

For corporate transactions

We may transfer your personal information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

When required by law

Applicable law may require Incunabulum and Suppliers to disclose your personal information when we believe necessary to (i) comply with a legal process, such as a court order, subpoena or search warrant, government investigation or other legal requirement, (ii) help prevent or detect crime and (iii) respond to lawful requests from law enforcement and government regulators.

To enforce legal rights

We also share information: (i) if we believe that disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our Users or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With your consent or at your request

We may ask for your consent to share your personal information with third parties. When we do, we will make clear why we want to share the personal information.

We use cookies and other data tracking technology to collect and use personal information about you. We also may allow others to use cookies and similar technologies (e.g., pixels) to recognize you and/or your device(s) when you use the Websites.

With your consent or at your request

We may ask for your consent to share your personal information with third parties. When we do, we will make clear why we want to share the personal information.

OUR USE OF COOKIES AND TRACKING TOOLS

We use cookies and other data tracking technology to collect and use personal information about you. We also may allow others to use cookies and similar technologies (e.g., pixels) to recognize you and/or your device(s) when you use our hosted Websites.

What are cookies?

Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the lifetime of the cookie (i.e., when it expires), and a randomly generated unique number or similar identifier. A cookie also may contain information about your computers, such as User settings, browsing history, and activities conducted while using these websites and certain Services.

Incunabulum also uses “pixels” (also known as web beacons). Pixels are transparent images that are used in collecting information about website usage across websites and over time.

Cookies that Incunabulum sets on the Websites are called first-party cookies. Cookies set by any other party are called third-party cookies. Third-party cookies enable third party features or functionality on or through the Websites, such as analytics, marketing automation, and customer support. The parties that set third-party cookies can recognize your computer both when it visits the Websites and also when it visits certain other websites.

Most browsers accept cookies automatically but allow you to disable them. You also can opt-out of certain cookies using this link. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Some features of the Websites may not work properly without cookies. To learn more about cookies generally, visit www.allaboutcookies.org and http://optout.aboutads.info/?c=2&lang=EN .

Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) incorporate a “Do Not Track” (” DNT”) or similar feature that signals to websites that a User does not want to have online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s User. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Incunabulum, do not respond to DNT signals.

Why do we use cookies and other tracking technology?

Some cookies are required for the Websites to operate. Other cookies enable us to track the interests of Users, enhance the experience of the Websites, and target advertising.

The types of cookies used on the Websites and why they are used is as follows:

• “Strictly necessary” cookies are required to allow us to deliver the Websites to you.
• “Performance” or “Analytics” cookies help us to collect information about how Users interact with the Websites and help us analyze and improve the Websites. The performance or analytics cookies remain on your computer after you close your browser until you delete them.
• “Advertising” cookies are used to make advertising messages more relevant to you. They help to display advertisements that are based on your inferred interests, prevent the same ad from appearing too often and ensure that ads are properly displayed.

Pixels and similar data collection technology enable Incunabulum to monitor the traffic patterns of visitors from one page of the Website to another, to deliver or communicate with cookies, to understand whether you visit the Websites after seeing our online advertisement displayed on a third-party website, to improve performance of the Websites and to measure the success of our email marketing campaigns.

Incunabulum serves targeted advertisements on the Websites and may use information about your visits to the Websites to provide relevant advertisements on other websites about goods and services that may interest you. Incunabulum and its providers also may deploy technology that monitors the effectiveness of advertisements by using cookies or web beacons to collect information about your visits to the Websites and other websites to provide relevant advertisements on other websites about goods and services that may interest you. The information collected through this process does not enable us or the third parties to identify your name, contact details, or similar directly-identifying details unless you choose to provide them.

HOW WE PROTECT AND RETAIN INFORMATION

We use physical, technical, and organizational measures designed to protect your personal information against unauthorized access, theft, and loss. We restrict access to your personal information to those employees who need access to service your account or perform their job functions. We have procedures to manage personal data breaches and will notify you and any applicable regulator when we are required to do so.

Although we take precautions intended to help protect the personal information that we process, no system or electronic data transmission is completely secure. Any transmission of your personal information is at your own risk and we expect that you will use appropriate security measures to protect your personal information.

We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. You understand and agree that we may deliver electronic notifications about breaches of security to the email address that you provided to us.

If you create an account, you are responsible for maintaining the security of and the information in your account.

If you believe that your account or personal information is no longer secure, please notify us immediately.

We will retain your personal information for the period necessary to fulfill the purposes for which it was collected and as outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

The criteria used to determine our personal information retention periods include:

• The length of time we have an ongoing relationship with you and provide Services to you (for example, for as long as you have an account with us or keep using the Websites);
• Whether we have a legal obligation to retain the personal information (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them);
• Whether retention is advisable considering our legal position (such as for statutes of limitations, litigation or regulatory investigations).

The criteria used to determine our personal information retention periods include:

• The length of time we have an ongoing relationship with you and provide Services to you (for example, for as long as you have an account with us or keep using the Websites);
• Whether we have a legal obligation to retain the personal information (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them);
• Whether retention is advisable considering our legal position (such as for statutes of limitations, litigation or regulatory investigations).

CROSS BORDER DATA TRANSFERS

Sharing of personal information sometimes involves transfers to or from the United States of America and other jurisdictions. For example, certain Services are available to Users in the European Economic Area (“EEA”) and we transfer personal information to the United States for processing. We use the EU-US standard contractual clauses approved by the European Commission to validate transfers of personal information from the EEA to other countries. (Standard contractual clauses are commitments between companies transferring personal information of EEA residents to protect the privacy and security of the transferred personal information.)

CHILDREN’S PRIVACY

Incunabulum respects the privacy of your child and we want to share with you our policies regarding children under the age of eighteen (18). Although Users of all ages may navigate through the Services, we do not knowingly collect personal information from anyone under age eighteen (18). If we learn that a child under age eighteen (18) has improperly provided us with information, we will notify the child’s parent or legal guardian and thereafter delete the child’s personal information from our records.

YOUR CHOICES ABOUT YOUR PERSONAL INFORMATION

California Privacy Notice

This California Privacy Notice applies to the processing of Personal Information of residents of the State of California (California Consumers) as required by the California Consumer Privacy Act of 2018 (CCPA).

If you are a California Consumer, this California Privacy Notice explains your privacy rights and is intended to inform you at or before the time that you provide us with your Personal Information how and why we process your Personal Information. In this California Privacy Notice, Personal Information means information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular California Consumer or household.

If this California Privacy Notice and any provision in the rest of our Privacy Policy conflict, then this California Privacy Notice controls the processing of Personal Information of California Consumers.

Please note:

• We may (and in some cases are required to) verify your identity before we can act on your request to exercise your privacy rights.
• We may not honor part or all of a request you make to exercise your rights under CCPA – for example, certain information we collect is exempt from this California Privacy Notice, such as publicly-available information collected from a government agency. When this occurs, we will explain why in a written response.

California Privacy Rights

California consumers have the following rights:

• You have the right to request information about the categories and specific pieces of Personal Information we have collected about you (see table below), as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information.
• You have the right to opt-out of Incunabulum sale of your Personal Information if and when Incunabulum determines the purpose and means of processing your Personal Information. (In CCPA, the sale means transferring or making available Personal Information to third parties for monetary or other valuable consideration.) Please click here (insert link for opt-out ^[g] ) for details about how to opt out of sale.
• You have the right to request information about our disclosure for business purposes of your Personal Information to third parties.
• You have the right to request the deletion of your Personal Information.
• You have the right to not be discriminated against for exercising any of these rights.

The following tables categories of Personal Information that generally match the categories in the definition of Personal Information in CCPA. We indicate for each listed category the specific types of Personal Information in the category that we collected within the last 12 months. We use all of this Personal Information for the purposes described in this Privacy Policy.

Category of Personal Information in CCPA	Specific Personal Information We Collect from Users
A. Identifiers	Name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Name, signature, address, telephone number, and employment history.
C. Protected classification characteristics under California or federal law	Age (40 years or older), race, color, national origin, citizenship, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status.
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information	Not collected from or about Users.
F. Internet or other similar network activity	Browsing history and search history on the Websites and information on a consumer’s interaction with the Websites, Events, and our mobile applications and digital advertisements.
G. Geolocation data	General location information collected through IP address and WiFi.
H. Sensory data	Not collected from or about Users.
I. Professional or employment-related information	Current or past job history, job title.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99))	Not collected from or about Users.
K. Inferences are obtained from other Personal Information	Preferences, characteristics, and online behavior used to create a User Profile.

We provide information about how we use and disclose personal information above in this Privacy Policy. Since we share most of this Personal Information with other businesses and this sharing enables Incunabulum to generate valuable consideration.

How to Submit Your Request to Exercise Your California Privacy Rights

If you are a California resident and would like to exercise one or more of your privacy rights, please:

1. Complete our Online Form
2. Call us at 1-310-421-1860. Please tell our customer service team that you are a California resident and would like to exercise your online privacy rights.
3. Send us an email. Please include California Privacy Rights in the subject line.

A different California law permits California residents to request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request by mail: Incunabulum LLC, Attn: Privacy Dept., 23055 Sherman Way, Box 5069, West Hills CA 91308 or by email. Please include “California Privacy Rights” in the subject line.

Notice for Individuals Located In EU

The data controller for the information you provide or that we collect pursuant to this Privacy Policy is: Incunabulum LLC, Attn: Privacy Dept., 23055 Sherman Way, Box 5069, West Hills CA 91308

To process your personal data as described in this Privacy Policy, we rely on the following legal bases:

• Legitimate interests: We may use your information where we have legitimate interests to do so that is not overridden by your fundamental rights. For example, we analyze our Users’ behavior to improve the Services, to prevent and detect fraud and misuse, and to market the magazines to you.
• Consent: From time to time, we may ask for your consent to use your information. You may withdraw your consent at any time by contacting us using the contact information provided above.
• Processing is necessary for the performance of our contract with you.

If you would like to review, correct, update, suppress, restrict or delete personal data that you have previously provided to us or if you would like to receive an electronic copy of your personal data for purposes of transmitting it to another company (where this right to portability is provided to you by law), please submit your request to us at [email protected] or by mail: Incunabulum LLC, Attn: Privacy Dept., 23055 Sherman Way, Box 5069, West Hills CA 91308.

In your request, please make clear what personal data you would like to have changed, whether you would like to have your personal data suppressed from our database, or other limitations you would like to put on our use of your personal data. For your protection, we only fulfill requests for the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable and within the time periods required by applicable law.

Please note that we often need to retain certain personal data for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the personal data provided until after the completion of such purchase or promotion). Our databases and other records may have residual personal data which will not be removed. We also may not allow you to review certain personal data for legal, security, or other reasons.