Mullins Media Co. (“Mullins Media,” “we,” “us,” or “our”) provides marketing, advertising, website, communications, customer relationship management, ecommerce, analytics, automation, artificial intelligence, technology, content, and related services for ourselves and for businesses, organizations, individuals, brands, and other customers (“Clients”).
This Privacy Policy describes how personal information may be collected, used, processed, stored, analyzed, disclosed, shared, licensed, transferred, or sold when you interact with Mullins Media or with a Client through a website, form, landing page, advertisement, campaign, promotion, event, application, purchase, communication, or other service operated, managed, hosted, supported, or facilitated by Mullins Media.
“Applicable Client” means the business, organization, individual, brand, or other entity whose website, campaign, product, service, promotion, or other offering you are interacting with.
Depending on the circumstances and applicable law, Mullins Media and an Applicable Client may each act independently or jointly as a controller, business, processor, service provider, contractor, joint controller, or other legally recognized participant in the processing of personal information.
1. Information We Collect
Mullins Media and our Clients may collect information including:
names, email addresses, telephone numbers, mailing addresses, and other contact information;
account, profile, demographic, business, employment, preference, and interest information;
information submitted through forms, applications, surveys, contests, promotions, registrations, or questionnaires;
purchase, transaction, subscription, order, billing, and customer-history information;
receipts, invoices, photographs, screenshots, proof-of-purchase materials, documents, and uploaded files;
emails, text messages, calls, chats, support requests, and other communications;
IP addresses, device identifiers, browser information, approximate location, referring URLs, and traffic-source information;
website, application, advertising, email, and communication activity;
cookies, pixels, advertising identifiers, analytics data, and similar tracking information;
social media and publicly available information;
information received from Clients, service providers, advertising platforms, data providers, business partners, public sources, and other third parties;
information inferred or derived from other information, including interests, preferences, behaviors, likely characteristics, audience segments, marketing attributes, and predicted interests; and
other information voluntarily provided or lawfully obtained in connection with our or a Client’s activities.
We may combine information obtained from different interactions, Clients, platforms, devices, databases, public sources, service providers, or third parties where permitted by law.
You should not submit sensitive information that is unnecessary for the transaction, campaign, or service involved.
2. How We Use Information
To the fullest extent permitted by applicable law, Mullins Media and the Applicable Client may independently or jointly collect, access, organize, combine, enhance, analyze, derive, store, process, and use personal information for purposes including:
providing products, services, downloads, offers, promotions, or requested information;
processing purchases, registrations, transactions, applications, and requests;
verifying identity, eligibility, purchases, receipts, registrations, or submitted information;
customer service and communications;
operating websites, applications, forms, CRM systems, databases, ecommerce systems, and other technology;
email, SMS, telephone, direct-mail, and other marketing;
newsletters, promotions, advertising, recommendations, announcements, surveys, and offers;
lead generation, lead management, sales, and customer relationship management;
advertising, targeted advertising, retargeting, remarketing, and audience creation;
audience segmentation, personalization, profiling, and recommendation systems;
cross-promotion of Mullins Media, Clients, affiliates, partners, products, services, brands, and offers;
analytics, attribution, reporting, research, measurement, and market analysis;
data enhancement, matching, enrichment, verification, and audience analysis;
improving and developing products, services, websites, campaigns, technology, advertising, and business strategies;
developing, evaluating, testing, training, improving, or operating technological and automated systems where permitted by law;
security, fraud prevention, compliance, quality assurance, and risk management;
enforcing agreements and protecting legal rights;
internal administration and business operations;
business development and identifying potential customers, markets, products, services, partnerships, and opportunities;
corporate transactions such as financing, mergers, acquisitions, restructuring, or sales of businesses or assets; and
any other lawful business or commercial purpose that is compatible with the circumstances in which the information was collected, disclosed at the time of collection, subsequently authorized, or otherwise permitted by applicable law.
Where applicable law requires a particular lawful basis, notice, opt-out opportunity, or consent for a specific use, the applicable requirement controls.
Aggregated and De-Identified Information
We may create aggregated, statistical, anonymized, or de-identified information from personal information.
To the extent such information is no longer treated as personal information under applicable law, Mullins Media and our Clients may use, retain, analyze, license, disclose, commercialize, or otherwise process it for any lawful purpose.
Where required by law, we will not attempt to re-identify information maintained as de-identified information except as permitted for testing, security, compliance, or another legally permitted purpose.
3. Marketing, Email, Telephone, and SMS
Where permitted by law, Mullins Media and/or the Applicable Client may use contact information for commercial, promotional, informational, transactional, or marketing communications.
These communications may include email, SMS or text messages, telephone calls, direct mail, newsletters, advertisements, promotions, offers, announcements, recommendations, surveys, event information, product information, and similar communications.
Where applicable law requires separate consent, written consent, affirmative consent, or another authorization for a particular communication channel, that authorization will be obtained separately.
Agreeing to this Privacy Policy or to general Terms of Service does not by itself constitute consent where applicable law requires separate consent.
Consent to marketing is not a condition of purchasing goods or services unless otherwise permitted by law.
Message and data rates may apply to SMS communications, and message frequency may vary.
Users may unsubscribe, revoke consent, or opt out using the mechanism provided with the applicable communication or another legally recognized method. Withdrawal of marketing consent does not prevent transactional, security, administrative, legal, or other non-marketing communications where permitted.
4. Sharing, Licensing, Transfer, and Sale of Information
To the fullest extent permitted by applicable law, Mullins Media and/or the Applicable Client may disclose, provide, exchange, transfer, share, license, rent, or sell personal information for monetary or other valuable consideration or for other lawful business or commercial purposes.
Recipients may include:
Mullins Media and the Applicable Client;
affiliated or related businesses;
other Clients where legally permitted;
advertising, marketing, lead-generation, and business-development partners;
business partners and promotional partners;
data, audience, verification, analytics, and technology providers;
advertising platforms, advertising networks, and social media platforms;
CRM, communications, email, SMS, telephone, and automation providers;
hosting, website, cloud-storage, ecommerce, payment, and fulfillment providers;
artificial-intelligence and technology providers;
contractors and service providers;
professional advisers;
purchasers, investors, lenders, successors, or transaction participants;
government authorities where required or permitted by law; and
other third parties where the disclosure, transfer, licensing, sharing, or sale is permitted by applicable law.
Personal information may be shared for advertising, audience creation, lead generation, data enhancement, analytics, cross-promotion, customer acquisition, business development, marketing, research, commercialization, or other lawful purposes.
Where applicable law requires notice, consent, identification of a recipient, or an opportunity to opt out before information may be sold, shared, transferred, licensed, or otherwise disclosed, those requirements apply.
Nothing in this Privacy Policy overrides privacy rights or restrictions that cannot legally be waived.
5. Cookies, Analytics, and Advertising Technologies
Mullins Media, our Clients, and third parties may use cookies, pixels, tags, scripts, advertising identifiers, local storage, software development kits, and similar technologies to:
operate websites and services;
remember preferences;
measure and analyze usage;
attribute conversions;
understand visitor behavior;
personalize content;
create and enhance advertising audiences;
deliver targeted or interest-based advertising;
retarget users on other websites or platforms;
measure advertising effectiveness;
identify potential customers;
detect fraud and security issues; and
improve products, services, advertising, and technology.
Information collected through these technologies may be combined with information obtained from other sources where permitted by law.
Where applicable law requires consent before non-essential cookies, pixels, or similar technologies are activated, the applicable website or service will provide the required consent mechanism.
6. Artificial Intelligence, Automated Processing, and Uploaded Content
Mullins Media and our Clients may use artificial intelligence, machine learning, algorithms, computer vision, automated systems, and third-party technology to process information.
These systems may be used for document and receipt review, eligibility and purchase verification, classification, fraud detection, content analysis, customer service, data organization, personalization, marketing optimization, analytics, audience development, system improvement, and other lawful purposes described in this Policy.
For example, a receipt, photograph, screenshot, or proof-of-purchase document may be automatically analyzed to identify names, dates, order numbers, products, merchants, transaction information, text, images, or other relevant information.
Uploaded materials may contain information beyond what is requested. By uploading a file, you understand that the entire submitted file may technically be accessible during processing. You should remove unnecessary sensitive information before submitting it.
Where applicable law provides rights concerning automated decisions that produce legal or similarly significant effects, those rights will be honored.
7. Service Providers and Other Platforms
Mullins Media and our Clients use third-party platforms and service providers for functions including websites, hosting, CRM systems, communications, payments, advertising, analytics, automation, artificial intelligence, ecommerce, file storage, fulfillment, and security.
Information may be processed by those providers in accordance with their agreements, privacy practices, and applicable law.
Third-party websites, platforms, and services may have their own privacy policies and practices. Mullins Media and our Clients are not responsible for independent third-party practices except to the extent responsibility is imposed by applicable law.
8. Retention, Security, Legal Disclosures, and Business Transfers
Personal information may be retained for as long as reasonably necessary or permitted for the purposes described in this Policy, including business operations, marketing, analytics, contractual obligations, recordkeeping, dispute resolution, security, legal compliance, fraud prevention, and enforcement.
Retention periods may vary according to the information, purpose, Client, service, and applicable legal requirements.
We may retain suppression and opt-out records as necessary to honor communication and privacy preferences.
Mullins Media and our Clients use reasonable administrative, technical, and organizational safeguards appropriate to the circumstances. No electronic system, transmission, database, or security measure can guarantee absolute security.
Information may be preserved, used, or disclosed where reasonably believed necessary to comply with law or legal process, respond to governmental requests, investigate fraud or unlawful conduct, protect persons or property, enforce agreements, or establish, exercise, or defend legal claims.
Information may also be disclosed or transferred in connection with an actual or proposed merger, acquisition, financing, investment, restructuring, bankruptcy, sale of assets, sale of a business, or similar transaction.
9. United States Privacy Rights
Residents of certain U.S. states may have additional rights under applicable privacy laws.
Depending on the jurisdiction and whether the applicable law applies to Mullins Media or a Client, those rights may include the right to:
confirm whether personal information is being processed;
access or obtain information about personal information;
correct inaccurate personal information;
delete certain personal information;
obtain a portable copy of information;
opt out of the sale of personal information;
opt out of sharing for certain advertising purposes;
opt out of targeted advertising;
opt out of certain profiling;
limit certain uses or disclosures of sensitive personal information;
withdraw consent where processing is based on consent;
use an authorized agent where permitted;
appeal certain privacy-request decisions; and
receive equal service and treatment for exercising applicable privacy rights.
Where legally required, websites or campaigns may provide additional mechanisms such as a “Do Not Sell or Share My Personal Information” option, cookie controls, privacy-preference controls, or recognition of legally required opt-out preference signals.
If an applicable law requires a specific disclosure concerning categories of information collected, sold, shared, retained, or disclosed during a particular period, the Applicable Client or campaign may provide a supplemental notice containing that information.
Privacy requests may require identity verification. Requests involving information controlled primarily by a Client may be referred to or handled in cooperation with that Client.
Where an appeal right applies, instructions for submitting an appeal will be provided with the applicable decision or upon request.
If a business offers a financial incentive, loyalty program, discount, prize, or difference in price or service that requires a separate privacy notice under applicable law, additional terms or notices may apply.
10. European Economic Area, European Union, and United Kingdom
If the GDPR, UK GDPR, Privacy and Electronic Communications Regulations, or another European or UK privacy law applies, additional protections and requirements apply.
Depending on the particular processing activity, Mullins Media and/or the Applicable Client may process personal data on the basis of:
consent;
performance of a contract or steps requested before entering a contract;
compliance with a legal obligation;
legitimate interests pursued by Mullins Media, the Applicable Client, or another party where permitted;
protection of vital interests;
performance of a task in the public interest where applicable; or
another lawful basis recognized by applicable law.
Legitimate interests may include operating and improving businesses and services, customer relationships, analytics, security, fraud prevention, marketing where permitted, business development, administration, and protecting legal rights.
Where consent is the required lawful basis, consent may be withdrawn as permitted by law. Withdrawal does not affect processing lawfully performed before withdrawal.
Individuals covered by applicable European or UK law may have rights including access, correction, deletion, restriction, objection, data portability, withdrawal of consent, and rights concerning certain automated decision-making.
Individuals also have the right to object to processing for direct marketing where applicable and may have the right to lodge a complaint with the appropriate supervisory authority.
Mullins Media is based in the United States. Personal data may therefore be transferred to or processed in the United States or other countries. Where applicable law requires safeguards for an international transfer, legally recognized safeguards or transfer mechanisms will be used.
Where European or UK law requires specific consent for marketing communications, cookies, advertising technologies, transfer of marketing information to another organization, or another processing activity, such processing will be conducted subject to the required consent or another legally available basis.
A generalized acknowledgment of this Privacy Policy does not replace specific consent where the law requires consent to identify particular purposes, organizations, or processing activities.
11. Children and Sensitive Information
Our general services are not intended to knowingly collect personal information from children in violation of applicable law.
Where a particular Client, website, campaign, product, or service is directed toward children or minors, additional notices, age verification, parental authorization, restrictions, or other safeguards may apply.
Additional legal requirements may also apply to certain categories of information, including health information, biometric information, precise geolocation, financial account information, information concerning children, and other legally defined sensitive information.
Such information will be processed subject to applicable restrictions.
This general Privacy Policy does not replace any sector-specific privacy notice, such as a legally required health-information or other specialized privacy notice.
12. Supplemental Notices
A Client, website, campaign, form, promotion, application, or service may provide additional privacy disclosures or consent requests concerning a particular activity.
Those supplemental disclosures are incorporated into this Privacy Policy for the applicable activity.
If a supplemental notice provides greater rights or imposes more specific restrictions because of applicable law, those provisions control for that activity.
13. Changes to This Privacy Policy
We may update this Privacy Policy as business practices, Clients, services, technologies, or laws change.
The “Last Updated” date identifies the most recent revision.
Changes may apply to information already held to the extent permitted by law. Where applicable law requires additional notice, consent, or another action before a materially different use may be made of previously collected information, that requirement will be followed.
14. Contact and Privacy Requests
Privacy requests should identify the individual making the request and, when possible, the Client, website, campaign, purchase, promotion, or service involved.
We may take reasonable steps to verify identity and authority before fulfilling a request.
Where Mullins Media processes information primarily on behalf of a Client and does not have authority to independently resolve a request, we may refer the request to the Applicable Client or assist that Client in responding.
Mullins Media Co. Lynchburg, Virginia, United States
Privacy questions and requests may be submitted through the contact methods provided on the Mullins Media website or through the Applicable Client.
