Effective Date 3/3/2022
Applicability of this policy
This policy applies to visitors to the www.Affiliatedmonitors.com website (the “Site”). If you are present in the European Union, Switzerland or Canada when you access the Site, please refer to the European Union, Switzerland & Canada Privacy Addendum.
Information We Collect and How We Use It
“Personal Information” means any information by which you can be identified, including name, postal address, e-mail address, location IP address and telephone number.
AMI gathers Personal Information about you in order to respond to your requests and provide you with appropriate information about AMI services. The information is collected and used in the following ways:
Contacting Us By E-mail: When you send AMI an e-mail, you may be required to provide some or all of the following Personal Information: name, email address, company name and address, title, telephone contact information. AMI may use this information to respond to your requests, including retaining the information you provide, the content of your e-mail, our response, and any follow-up questions and further requests and inquiries you may have. Please be advised that e-mail and other communications to or from AMI are collected via technology that automatically captures certain personal contact information contained in the signature blocks of the e-mail received by AMI professionals and stores that information in AMI systems.
Contacting Us In Our Capacity As A Monitor To Another Entity: When you submit information to AMI in an e-mail specific to AMI’s role as a Monitor to a third-party, you may be required to provide some or all of the following Personal Information: name, email address, company name and address, title, telephone contact information, nature of complaint, details of your allegation against the third-party to whom AMI is the appointed Monitor, and in some instances, financial data related to claims against the third party. AMI may use this information to respond to your requests, including retaining the information you provide, the content of your e-mail, any supporting documentation, our response, and any follow-up questions and further requests and inquiries you may have. Please be advised that e-mail and other communications to or from AMI are collected via technology that automatically captures certain personal contact information contained in the signature blocks of the e-mail received by AMI professionals and stores that information in AMI systems.
In the course of administering Monitoring of third-parties at the direction of the courts or a regulatory agency, AMI may collect personal information that either identifies an individual or may be used together with other information to identify an individual.
AMI may collect personal information directly from claimants through complaint forms submitted to AMI via a postal service or via websites developed and maintained for clients in connection with its duties as a Monitor (the “Websites”). AMI may also collect personal information when it communicates with claimants by telephone or email. Such personal information may include names, email addresses, postal addresses, telephone numbers, social security numbers, health related information, legal representation information, and/or financial account information. AMI may also collect personal information necessary to verify an individual’s standing to bring a complaint against a Monitored client, such as transactional account data, documentation substantiating the purchase of an item or service, or verification of past or present contractual agreement. Additionally, as discussed below, AMI may collect internet or other electronic network activity information associated with the use of the Websites.
AMI may also collect personal information from its clients, as well as authorized third-parties or publicly available sources. For example, AMI may collect personal information from third-parties engaged to assist AMI in effectuating a Monitorship, to comply with applicable reporting requirements, or to otherwise fulfill AMI’s responsibilities for a particular matter as directed by a client under Monitoring, or ordered by a court or regulator. With respect to the Websites, AMI’s clients and/or any courts that may be supervising a matter are ultimately responsible for determining whether it is reasonably necessary for AMI to collect certain types of personal information in connection with the administration of a matter.
AMI retains personal information only so long as is necessary to accomplish the purposes for which it was provided subject to, as applicable, orders of the court, AMI’s document retention policies, contractual provisions, and the direction of AMI’s clients. All personal information provided to AMI relating to AMI’s role as a Monitor to a client is disposed of or destroyed in a manner that prevents loss, theft, misuse, reconstitution, or unauthorized access to the information.
Cookies & Tracking Technologies Policy
We also use other tracking technologies on our sites such as social plugins. The social plugins used on the Site are hosted by a social media network such as Facebook, Twitter, LinkedIn, and Pinterest. and your Your browser therefore sends this cookie data to that social media network when loading the social plugin inside your browser. These data contain information on your use of the Site. In case you are registered with the social media network, the data will be associated with your data already stored in the social media network.
We use both session and persistent tracking technologies. Tracking technologies (e.g., cookies) can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). We also use first– and third-party cookies. First– party cookies are used and controlled by us to provide services on the Site.
In particular, our Site uses the following categories of cookies:
(b) Performance and Functionality Related Cookies: We use performance cookies to assess the performance of our Site, for example which pages you go to most often, how long it takes for certain pages to load and similar information in order to improve how the Site works. These cookies may also be used to prevent fraudulent activity and improve security. We use functional cookies to tell us, for example, whether you have visited the Site before or if you are a new visitor and to help us identify the features in which you may have the greatest interest. We use these performance and functionality related cookies only if you have consented.
We are not responsible for third-party sites and their privacy practices as it relates to opt-outs from tracking activities.
Other Web Technologies
AMI uses additional technologies, including through the use of third– party analytics providers that lets us know what type of browser you are using, the website from which you enter our Site, the type of device you are using, the pages you view as you visit the Site, and other information related to your technology or use of the Site. This technology does not identify you personally – it simply helps us compile aggregate statistics about our guests and their use of our Site. We use these statistics and analytics services to improve our Site design and content, to evaluate how the Site is used, analyze traffic patterns, and to prepare and deliver our marketing programs and materials.
To Whom We Disclose Information
AMI will not share your Personal Information with third- parties, except as follows:
The extent and type of Personal Information AMI collects depends on the information you provide to us through our e-mail and/or through other online communication channels via the Site. You may choose not to provide us with any Personal Information.
YOUR COOKIE CHOICES & HOW TO OPT-OUT
Controlling the HTML5 local storage on your browser depends on which browser you use. For more information regarding your specific browser please consult the browser’s website (often in the Help section).
Most browsers are initially set up to accept HTTP Cookies. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, and how to disable existing cookies. For more information about HTTP cookies and how to disable them, you can consult the information at http://www.networkadvertising.org/choices/ and http://www.allaboutcookies.org/manage-cookies/.
Some web browsers have a “Do Not Track” preference that transmits a “Do Not Track” message to the websites you visit with information indicating that you do not want your online activity to be tracked. At this time, JND AMI does not respond to browser “Do Not Track” signals.
We are not responsible for the effectiveness of any opt-out options referenced in the links provided above.
The effect of an opt-out, if successful, will be to stop tracking for certain purposes (e.g., marketing), but it will still allow the collection of usage data for certain purposes (e.g., research, analytics, and internal Site operation purposes).
If you wish to view more details on (the type of) cookies used on AMI’s Site, see below.
California residents are be entitled to specify they do not wish to be tracked, under the “California Online Privacy Protection Act,” California Business & Professions Code Section 22575(b)(7). AMI does not track your activities online over time and across third– party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.
Individuals who reside in California and have provided their Personal Information to AMI may request information about our disclosures of certain categories of Personal Information to third parties. Such request must be submitted to us at the following address: P.O. Box 961791, Boston, Massachusetts 02196, Attn: Chief Privacy Officer or Privacy@AffiliatedMonitors.com. Within 30 days of receiving such a request, we will provide a list of the categories of Personal Information disclosed to third during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.
Just in Time Notice for Mobile Users
AMI and/or third parties collect the following types of information about you when you use our Site from a mobile device. You either enter this information into the Application or agree to its collection automatically by the Application. We may share the information collected with third parties. If you do not consent to our collection and sharing of the data as indicated below, please do not use this Application.
Further information about the third– parties we share your information with:
To learn more about LinkedIn’s Widgets, Performance/Functional and Advertising/Target Social Networking Analytics and Advertising tools see:
To learn more about Meta Company’s Facebook’s Performance/Functional and Advertising/Target Social Networking Analytics and Advertising tools see: https://www.facebook.com/help/111814505650678.
To learn more about Twitter’s Performance/Functional and Advertising/Target Social Networking Analytics and Advertising tools see: https://twitter.com/en/privacy
To learn more about Pinterest’s Performance/Functional and Advertising/Target Social Networking Analytics and Advertising tools see: https://policy.pinterest.com/en-gb/privacy-policy
Our Commitment to Children’s Privacy
AMI understands the importance of protecting children’s privacy. For that reason, we do not collect and maintain information from those we actually know are under 13 years of age, and no part of the Site is structured to attract anyone under 13 years of age.
AMI will take reasonable precautions to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. However, these measures, standing alone, are not sufficient to ensure the security of your Personal Information. It is also important for you to guard against unauthorized access to your passwords and the unauthorized use of your computer.
Updates to this Policy
For any queries in relation to this Cookies and Tracking Technologies Policy please contact us at Privacy@AffiliatedMonitors.com or Chief Privacy Officer, AMI, P.O. Box 961791, Boston, Massachusetts 02196, United States.
Compliance with the European Union General Data Protection Regulation and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA)
Additional Information requirements pursuant to Art. 13 GDPR (General Data Protection Regulation)
Full name of legal entity: Affiliated Monitors, Inc.
Name of Chief Data Privacy Officer: Mikhail Reider-Gordon
Email address: Privacy@Affiliatedmonitors.com
Postal address: P.O. Box 961791, Boston, Massachusetts, 02196, United States
Telephone: (617) 275-0620
Fax: (617) 345-0102
The data we collect about you on or through the Site
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
How is your personal data collected?
As noted above, we use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by corresponding with us by email using one of the email addresses posted to our Site, or contact us via VOIP, such as Skype. This includes personal data you provide when you:
Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about you, your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies, if any. A list of cookies we use on our Site is available upon request.
We use the following analytics providers to help us understand traffic and manage our Site. Depending on the Site or Service you are using, the answer varies. While we do our best to keep this table updated, please note that the number and names of cookies, pixels and other technologies may change from time to time:
Provider Name (company name)
Type of Data Collected
_ga – 2 years
_gid – 24 hours
_gat – 1 minute
_gac – 90 days
_utma – Persistent
_utmb – Session only
_utmc – Session only
_utmz – 6 months
_utmv – Persistent
Match user visits, origin, and targeting
Google Tag Manager
Technical Data; Tracking; Analytics
Meta Platforms, Inc.
1601 Willow Road
Menlo Park, CA 94025
fr – 3 months
Persistent 3rd “Targeting” cookie
Twitter share button
1355 Market Street, Ste 900
San Francisco, CA 94103
LinkedIn share button
Attn: Legal (Privacy)
1000 W. Maude Avenue
Sunnyvale, CA 94085
Pinterest “Pin It” button
651 Brannan Street
San Francisco, CA 94107
101 Townsend St.,
San Francisco, CA 94107, Attn: Data Protection Officer
New Relice, Inc.
188 Spear Street, Suite 1200, San Francisco, CA 94105
Monotype Imaging Holdings Inc. Attn.
Better Business Bureau Boston Site Seal
Better Business Bureau
290 Donald Lynch Boulevard, Suite 102
User tracking link to the vendor.
GoDaddy Site Seal
United States: Attn: Office of the Data Protection Officer, 2155 E. GoDaddy Way, Tempe, AZ 85284 United States
User tracking link to the vendor.
The Rocket Science Group LLC d/b/a Mailchimp
675 Ponce de Leon Ave NE
Atlanta, GA 30308
By using our Site, you consent to our use of such service providers and services, and the collection of your personal data.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data. We do not share your personal data with third– party direct marketers. You have the right to withdraw consent to marketing at any time by contacting us or using the ‘unsubscribe’ link in our e-mails to you.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register your interest in our services
Performance of a contract with you
(a) Performance of a contract with you
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re-organization or group restructuring exercise)
To deliver relevant website content to you.
Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Disclosures of your personal data
We may share your personal data with certain third parties, as required for the operation of our business, which includes processors and sub-processors.
We require all third– parties to respect the security of your personal data and to treat it in accordance with the law. We contract with our third-party service providers to require that they do not use your personal data for their own purposes and to authorize them to process your personal data for specified purposes and in accordance with our instructions.
We may share your personal data within AMI and its European Partners, which may involve transferring your data outside the European Economic Area.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We are developing a data retention policy which will dictate how long we retain your personal data collected through or on our Site, with the intent that we will retain your personal data only for so long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data to:
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third– Parties
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third– party. We will provide to you, or a third– party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.