Demand Media’s Privacy Policy

Demand Media is committed to protecting your privacy and respects the privacy of individuals who use Demand Media’s software and services. This Privacy Statement covers how Demand Media treats personal information that is either collected or received. This includes, but is not limited to email addresses, phone numbers, names, addresses, age, gender, and interests.

Demand Media’s Pluck product provides a white-label solution used by Demand Media’s customers (“Customers”) to implement social networking communities. Each of Demand Media’s Customers determine how to provide the Pluck functionality to end-users. In this arrangement Demand Media’s Customers have final control on what information is collected and the end-user’s ability to opt-out/opt-in of the information gathering process. When registering with one of Demand Media’s Customers’ websites, some or all of the information gathered from end-users may be stored by Demand Media. All information collected by Demand Media Customers is governed by such Customer’s privacy policy. Any information provided to Demand Media by the Customer, or collected by Demand Media as a result of Customer’s configuration of the Pluck Services, will be governed by this Privacy Policy.

Because protecting your privacy is important to Demand Media, we adhere to the Safe Harbor Agreement concerning the transfer of personal data from the European Union (“EU”) to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (“Principles”) with respect to all data that we receive, whether directly from the end user or from one of our Customers. If there is any conflict between the policies in this statement and the Principles, the Principles will govern. This statement outlines our general policy and practices for implementing the Principles, including the types of information we receive, how we use it, and the choices affected individuals have regarding our use of, and their ability to correct, that information.

This privacy statement applies to all personal information we receive (except as noted below). For purposes of this privacy statement, “personal information” means information that:

is transferred from the EU to the United States; is recorded in any form; is about, or pertains to, a specific individual; and can be linked to that individual.
It does not include information that pertains to a specific individual, but from which that individual could not reasonably be identified.

Principles Protecting Individuals’ Privacy

Notice and Choice

Because the Customer determines what personal information is collected, end users should review the Customer privacy policy to determine the types of personal information collected from them, the purposes for which such information is collected and used, and the types of non-agent third parties to whom the personal information is disclosed. The Customer should also be consulted regarding the choices and means, if any, offered to individuals for limiting the use or disclosure of their information. Customers’ privacy policies will govern their collection and disclosure of any such information. Demand Media stores all personal information solely for use by Customers and end users related to their use of Pluck services.

Disclosures and Transfers

Demand Media will not disclose an individual’s personal information to third parties, except when one or more of the following conditions is true:

  1. Our Customer that provided the information to us asks for us to transfer it back to them for whatever purpose the Customer chooses;
  2. We have the individual’s permission to make the disclosure, whether such permission is made directly to Demand Media or to our Customer;
  3. The disclosure is required by law or professional standards;
  4. The disclosure is reasonably related to the sale or disposition of all or part of our business;
  5. The information in question is publicly available;
  6. The disclosure is reasonably necessary for the establishment or defense of legal claims; or
  7. The disclosure is to another Demand Media entity or to persons or entities providing services on our or the individual’s behalf (each a “transferee”), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:
  • is subject to law providing an adequate level of privacy protection;
  • has agreed in writing to provide an adequate level of privacy protection; or
  • subscribes to the Principles.

Permitted transfers of information, either to third parties or within Demand Media, include the transfer of data from one jurisdiction to another, including transfers to and from the United States of America. Because privacy laws vary from one jurisdiction to another, personal information may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the information originated. Notwithstanding, Demand Media may share aggregate data with 3rd parties per our agreement with the Demand Media Customer. This information will not identify the related end-user.

Data Security

Demand Media takes your security seriously and takes reasonable steps to protect your information. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use and confidentiality of information, either for its own purposes or on behalf of our clients, Demand Media has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we process. However, we cannot guarantee the security of information on or transmitted via the Internet or stored by our Customers.

Data Integrity

We process personal information only in ways compatible with the purpose for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, we take reasonable steps to make sure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use.

Access and Correction

An end-users’ ability to manage the data stored by Demand Media is controlled by Demand Media’s Customers. However, if an individual becomes aware that information we maintain about that individual is inaccurate, or if an individual would like to update or review his or her information, the individual may contact us using the contact information below and we will take reasonable steps to work with our Customer to correct the problem. The individual will need to provide sufficient identifying information, and we may request additional identifying information as a security precaution. In addition, we may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Agreement. In some circumstances, we may charge a reasonable fee, where warranted, for access to personal information.

Enforcement and Dispute Resolution

Demand Media utilizes the self-assessment approach to assure its compliance with our privacy statement. Demand Media periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Principles. We encourage interested persons to raise any concerns with us using the contact information below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this policy.

If you would like to speak to someone at Demand Media about your information, or if you have a concern about information we have collected or stored, please contact We will do our best to respond to you in a timely and professional manner to answer your questions and resolve your concerns.

Privacy Statement Changes | Subject to Change

This privacy statement may be changed from time to time, consistent with the requirements of the Safe Harbor. We will post any revised policy on this Web site, or a similar Web site that replaces this Web site. Demand Media reserves the right to modify all or some of this privacy statement at any time without notice.