Privacy Policy

This Privacy Policy describes how Iverson Media and Communications LLC. d/b/a iMedia Audiences/iMediaSalesTeam/ReptideMedia (“Marketing Company”, “we”,“us”) may collect, use, share, retain and transfer information from a “Visitor”, a “SME Clients” and “Patrons” (“you” and “your” and as defined below), to provide online digital marketing services and a reporting platform (“Services”). The information we collect and process depends on how our Services are used, but includes and is not limited to information we collect through:

imediaaudiences.com, imediasalesteam.com, reptidemedia.com (the “Websites”);”Marketing Company” (the “Websites”);
By other online and offline interactions with “Marketing Company”, including but not limited to sales calls, attending events, customer service inquires and other business transactions;
The websites of our SME Clients (“SME Client Websites”);

Our Services and our “iMedia Business Center” as defined below.

This Privacy Policy does not apply to California residents. If you are a California resident, see the “For California Residents” section below.

DEFINITIONS

As used in this Privacy Policy, these terms have the following meanings:

“SME Clients” means a person or entity (and authorized end users of such person or entity) that enters an Order for Services, has access to iMedia Business Center, or signs up for an account to use some of our tools.

“iMedia Business Center” means our SME Clients portal through which we may provide campaign results and other digital marketing reports. A SME Clients’s access to and use of the iMedia Business Center is governed by its agreement with “Marketing Company”.

“Visitor” means any person who visits the Websites or engages with us in connection with our marketing, recruitment, events or other general business activities that we may conduct or that others conduct on our behalf, but who is not a SME Clients or acting in the capacity of a Patron to a SME Clients.

“Patron” means a customer or a prospect of a SME Clients who visits a SME Clients Website and engages with the SME Clients using our Services. For example, if you are a SME Clients that offers home services such as roofing services, customers or prospects that come to a SME Clients Website to learn about your services are defined as Patrons for purposes of this Privacy Policy. As described below, we collect and process Patron information only on behalf of and at the direction of a SME Clients.

“Order” means the agreement entered into by “Marketing Company” and a SME Clients for Services.

“Personal Information” (or “Personal Data” as used in the “Individuals in the European Area (EEA) or UK” section below) means any information that identifies, relates to, describes, references, or is reasonably capable of being associated with an identified or identifiable natural person.

“Services” means the online digital marketing Services and platform offered by “Marketing Company” as further described in our Terms (see link below).

“Service Provider” means the entity which “Processes” Personal Information on behalf of the “Business” as those terms are defined in the California Consumer Privacy Act of 2018, as amended. As described further herein, we are a Service Provider to SME Clients.

“Social Media Platforms” means third-party platforms such as, but not limited to, Facebook, X, Instagram and Youtube.

“Terms” mean the “Marketing Company” marketing terms and conditions found here.

VISITORS: PERSONAL INFORMATION WE COLLECT

This section applies to information that we may collect and process or that you may provide to us when you visit the Websites or when you engage with us in connection with our marketing, recruitment, events or other general business activities that we may conduct or others on our behalf.

As a Visitor, we may collect the following types of Personal Information about you and your business contacts as described below:

(A) Personal Information you provide to us,

(B) Personal Information we may automatically collect, and

Personal Information you provide to us.

When you interact with the Websites or directly with “Marketing Company”, we collect information that you provide to us. We may collect Personal Information from you when you use the Websites to contact us with questions about the Services or our company or respond to our marketing and promotional messages, such as subscribing to our email list or filling out an online form. If you attend a “Marketing Company” event, such as a trade show, or interact with one of our sales representatives, we may ask for Personal Information from you in connection with such interactions. You may provide additional information when you communicate with us or otherwise interact with us, and we may keep copies of any such communications for our records.

The Personal Information you provide may include:

Business or personal contact information (such as your name, telephone number, email address and mailing address);

professional information (such as your job title, or company);

marketing information (such as your contact preferences), or

any other information you choose to provide to us.

Personal Information we may automatically collect

When you visit the Websites, we use cookies and similar technologies such as pixels and web beacons to collect certain information automatically from your browser or device.

The Personal Information we may automatically collect includes:

details about how you use the Websites, including how you engage and move around the pages, pages viewed, time and date of visit, duration of time on different pages;

the software you’re using, and other characteristics such as your web browser type and language;

IP address; identifiers associated with cookies or other technologies that may uniquely identify your browser including whether it is associated with your company;

Mobile device information, including the type of device you use, operating system version, and the device identifier

Geolocation data, but only if shared with us through device settings

pages you visited before or after navigating to or from the Websites, and your activity there including but not limited to any purchases or transactions made.

Our use of cookies and other tracking technologies such as pixels and plugins as described in the Cookies and Other Tracking Technologies section below and in our Cookie Policy.

Information we get from third parties.

We may collect information from third parties, such as public databases, Social Media Platforms, third-party data providers, and our joint marketing partners, about you and your activities on and off the Websites. Examples of this type of information include the ads you see and how you interact with them, the purchase and transactions you make, how you use third party products and services, online or in person, and demographic information such as your professional or educational status.

VISITORS: HOW WE USE INFORMATION

We use the information we collect or you provide to us through the Websites and in connection with our marketing, recruitment, events or other general business activities for a range of business purposes, including but not limited to:

Develop, operate, improve, deliver, maintain, and protect the Websites and our marketing, recruitment, events and other business activities.

Respond to your online inquiries and requests and provide you with information and access to the resources or Services that you have requested from us.

Provide a personalized experience to you, including by sending you marketing information, product recommendations, and communications (e.g., email, text messages calls) about us in accordance with your marketing preferences, including information about our products, Services, promotions or events.

Conduct market research, advertise to you, and provide personalized or sponsored content based on your activities and interests.

Carry out other legitimate business activities and other lawful activities, such as data analysis, fraud monitoring and prevention, identifying usage trends and expanding our business activities.

Identify you across multiple devices.

To communicate with you, including marketing related messages or communications about our Services or those of our Business Clients, in response to your inquiries or questions, and for customer service and support purposes.

Manage event registrations and attendance, including sending event related communications to you.

Register visitors to our offices for security reasons and manage non-disclosure agreements that Visitors may be required to sign.

Process transactions and set up online accounts.

Enhance the safety and security of the Websites and Services and protect against misuse or abuse of the Websites and Services.

Comply with legal requirements and respond to lawful requests by public authorities.

VISITORS: HOW WE SHARE INFORMATION

See the General section below for ways we share your information.

SME Clients: INFORMATION WE COLLECT

This section applies to the information we collect and process on behalf of, or is provided to us by a SME Clients in connection with the Services. This section refers to a SME Clients and not to a Visitor or a Patron. We may collect the following types of Personal Information about you and your business contacts as described below:

(A) Personal Information you provide to us,

(B) Personal Information we may automatically collect, and

Personal Information you provide to us.

When you interact with the Websites or Services, or engage with us through other marketing, recruitment, events of business activities, we may collect information that you provide to us. In order to provide Services, we require our SME Clients to provide us with information about themselves, their authorized end users, their Patrons, and their business. This information may include:

Applicable personal and business information and payment information (e.g., name, mailing address, email address, telephone number, date of birth, social security number (used only for verification purposes) bank account, debit or credit card number and associated contact information).

Information about you to evaluate your credit worthiness, including your credit history, credit scores and other information provided by consumer reporting agencies such as your loan account or payment history;

Information about your authorized end users including name, email address, password, physical address, job title and phone number.

Information about your Patrons, such as name, mailing address, telephone number, email address, and the products and services you provide to your Patrons.

Information you send through the Services or provide in the iMedia Business Center, such as the content of free-text entry box on a SME Clients Website and telephone calls to a SME Clients.

When you contact “Marketing Company”’s customer support or communicate with us in any other way, we’ll collect whatever information you volunteer or that we need you provide to resolve your question.

We may collect email and telephone communications that you exchange with us.

Personal Information we may automatically collect.

When you use the Services, we collect information about which Service features you’ve used and how you have used them. Additionally, when you interact with an email campaign that you receive from “Marketing Company”, we may collect information about your device and interaction with an email. If you are visiting our Websites, we collect the same information described above in the Visitors section. This information may include:

Usage Information. We may collect information about how you use the Services, such as the dates and times you access the Services, the features and functions of the Services you use, and how you access the Services. We also collect information about the performance of the Services.

Device Information. We may collect information from and about the devices you use to access the Services. For example, we may collect information about your hardware and software, such as the hardware model, operating system version, device memory, unique device identifiers, browser type, and language.

Location Information. When you use the Services, we may also collect information about your location, such as an IP address.

Any information we collect about Visitors when visiting our Websites as a SME Clients.

Personal Information we may receive from third parties.

If you link the Services to a third party’s Services or platform, such as Google or a Social Media Platform, we may receive information from the other Services or platforms to provide certain features of the Services to you. For example, if a Patron leaves a review on your Facebook page, you may use certain features within the Services to access, review and respond to such reviews, and you thereby allow us to collect that and other information from your Facebook page.

You may choose to use features of the Services that are provided by third parties or partners of “Marketing Company” such as a vendor that provides a promotional email campaign on your behalf to Patrons. These third parties may share information with “Marketing Company” such as verifying credit applications or when you provide information about your usage, transactions and campaign results with the Services provided by that third party.

To improve our Services, verify eligibility for credit and personalize your experience, we may obtain information about you from third parties, such as without limitation public databases, credit verification companies, Social Media Platforms, third-party data providers, and our joint marketing partners.

SME Clients: HOW WE USE INFORMATION

We use your Personal Information to provide the Services to you for the reasons provided below, including to:

Develop, operate, improve, deliver, maintain, and protect the Services, and develop new products and Services.

For business purposes, including sending you communications, including by email or text if you provide your mobile number for that purpose.

For marketing purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and other third parties, provided that you have not already opted-out of receiving such communications.

We may use email to respond to support inquiries or to share information about our Services, promotional offers, or events that may interest you.

Monitor and analyze trends and usage. For example, we may analyze the needs and activities of our SME Clients and their Patrons to help us better serve them, and we may conduct research and analysis related to our business and Services.

Collect opinions and comments regarding the Services and new Services.

Enhance the safety and security of the Services.

Verify your identity and prevent fraud or other unauthorized or illegal activity.

Enforce our agreements and other usage policies.

Comply with legal requirements and respond to lawful requests by public authorities.

Bill and collect fees and charges owed to us by you to deliver the Services.

SME Clients: HOW WE SHARE INFORMATION

See the General section below for more ways we share your information. With respect to Patron data, we may share Patron data in accordance with your instructions in connection with the Services and with our third-party Services providers or business partners who help us deliver or improve the Services or who perform Services on our behalf.

PATRONS

This section refers to Patrons, and not to a Visitor or a SME Clients.

This section applies to the information we may collect and/or process about our SME Clients’ Patrons in our capacity as a “Service Provider”, “data processor”, “business associate” or such similar term as defined by applicable privacy laws or regulations.

We collect information about Patrons as instructed by the SME Clients. Generally, we require SME Clients to have the right to collect, use and share your information before providing it to us. Data collected about or from Patrons by the SME Clients is subject to the SME Clients’ privacy policy. “Marketing Company” is not responsible for the privacy or security practices of the SME Clients, which may differ from those set forth in this Privacy Policy. Any data you provide to a SME Clients is not covered by this Privacy Policy, but rather Patron data is subject to the respective SME Clients’ privacy policies and security measures.

If you are a Patron of a SME Clients and have any questions about “Marketing Company”’s processing of Patron’s Personal Information on behalf of the SME Clients, we direct you to contact the SME Clients who provided your information to us.

General: Disclosing & Retaining Your Personal Information to Other Parties

With respect to Patrons, we will disclose your Personal Information as instructed by the SME Clients. With respect to a SME Clients and Visitor, we may disclose your Personal Information to other parties, including:

Our affiliates

partners, vendors, Service Providers

Technology companies, analytics companies and other third parties with whom we have business relationships

Government regulators

Our legal advisors and parties involved in a legal process

To an entity involved in the sale of our business

Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or Services we provide to you.

DATA RETENTION

We retain Information provided by or collected from SME Clients, Visitors and Patrons for as long as is reasonably necessary to provide the Services, for the purposes outlined in this Privacy Policy based on the context in which you provided it, or for the duration required by law, whichever is the longer.

Data Transfers: We may share the information we collect globally, both internally across our offices, and externally with our vendors, Service Providers and third parties who may be located in different jurisdictions. Data transfers may be necessary to operate and provide the Services. We have appropriate safeguards in place whenever we transfer your information.

Anonymized, Aggregated or De-Identified Information. As instructed by the SME Clients, we may anonymize or aggregate information derived from Patrons. With respect to SME Clients and Visitor data, we may anonymize, aggregate or otherwise strip any Personal Information or other information we collect of all personally identifying characteristics so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Do We Use “Cookies”?

Yes. Cookies, SDKs, tracking pixels and similar technologies are small files that the Websites stores on your device that recognizes the user’s browser or device and captures and remembers certain information.

In general, we and our third-party providers, advertisers and marketing partners, use these technologies on the Websites to optimize the functionality of the Websites, to help us understand how the Websites are used and to provide users with interest-based content and/or advertising, including textual and/or audio-visual ads or content based upon their browsing activities and interests.

With respect to cookies on a SME Clients Website, we use technology as instructed by the SME Clients and pursuant to our Terms. A SME Clients may request that “Marketing Company” initiate campaigns which may require certain cookies on the SME Clients Website to track browser or device information and build a profile of interests. The type of cookie placed on the SME Clients Website depends on the type of Services the SME Clients purchases from “Marketing Company”. For example, if a SME Clients purchases ads on Social Media Platforms, cookies will be placed on the SME Clients Website to collect ad performance metrics. Additionally, we do not allow SME Clients who are Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) covered entities to use certain technologies (i.e., FB Meta Pixel in the Capture Code). SME Clients who are HIPPA covered entities are required to provide us prompt notice of your covered entity status and agree to the configuration limitations of our products and services. We are not responsible and disclaim all liability for data collected by third party technologies that you authorize us to provide on a SME Clients Website.

For more information about the cookies and other technologies that we, our affiliates and third-party providers and advertisers use on our Products, please read our Cookie Policy.

In addition, you may opt out of certain interest-based advertising by using the following resources:

You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.

You may opt-out of receiving some permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.

You may opt-out of having your activity on our Products made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

THIRD PARTY LINKS

Our Websites may contain links to other websites, applications or Services that are not owned or controlled by us, including links to Social Media Platforms, or may redirect you off our Websites to other locations for information or other Services. This Privacy Policy only applies to information collected by us. We are not responsible for the privacy and security practices of other website applications or Social Media Platforms or the information they may collect (which may include IP address or device identifiers). You should refer to such third parties’ privacy policies on their sites to determine their respective privacy practices. Links to any other websites, applications, Social Media Platform or content do not constitute or imply an endorsement or recommendation by us of the linked websites, application, Social Media Platform, and/or content. No data collected by us or by third parties is 100% secure.

SECURITY

We use commercially reasonable procedures and various technical, administrative and physical safeguards to help protect the confidentiality of Personal Information. However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party Services Providers can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Personal Information or private communications will always remain private or secure. We do not guarantee that your Personal Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features.

With respect to security requirements of SME Clients, we may in our agreements with the SME Clients provide for additional or different security measures.

If you believe that your Personal Information has been accessed or acquired by an unauthorized person, please promptly Contact Us so that necessary measures can quickly be taken.

ACCESSING, CORRECTING, OR DELETING YOUR PERSONAL INFORMATION

If you are a Visitor or a SME Clients, as required by applicable laws, and subject to any permitted exceptions and limitations, we will comply with any verified consumer request you submit with respect to your Personal Information. Please submit a verifiable consumer request to us through the web form link provided below in Contact Us.

Exception for Patrons: If you are a Patron of a SME Clients you must contact the SME Clients directly to access, correct, or delete your Personal Information. Go to the applicable SME Clients Website to find how to contact the business with your request.

CHILDREN PRIVACY

The Websites are not intended for use by children under 16. We do not knowingly collect Personal Information from anyone under 16 years of age. If we become aware that we have unknowingly collected Personal Information from a child under the age of 16, we will make commercially reasonable efforts to delete such information from our database.

LIMITATION OF LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, UNDER NO CIRCUMSTANCES, INCLUDING, BUT NOT LIMITED TO, NEGLIGENCE, WILL WE OR OUR SUBSIDIARIES, PARENT COMPANIES OR AFFILIATES BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL OR CONSEQUENTIAL DAMAGES THAT RESULT FROM OUR PROCESSING OR USE OF PERSONAL INFORMATION, EVEN IF WE ARE ADVISED BEFOREHAND OF THE POSSIBILITY OF SUCH DAMAGES. THE MAXIMUM AMOUNT OF DAMAGES FOR WHICH WE WILL BE LIABLE UNDER THIS AGREEMENT WILL BE THE GREATER OF THE FEES YOU PAID FOR ANY PRODUCT IN CONNECTION WITH WHICH YOU PROVIDED YOUR PERSONAL INFORMATION, OR $100. (BECAUSE SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN CATEGORIES OF DAMAGES, THE ABOVE LIMITATION MAY NOT APPLY TO YOU. IN SUCH JURISDICTIONS, OUR LIABILITY AND THE LIABILITY OF OUR SUBSIDIARIES, PARENT COMPANIES AND AFFILIATES, IS LIMITED TO THE FULLEST EXTENT PERMITTED BY SUCH LAW.)

INDEMNIFICATION

You agree to indemnify and hold harmless us, our affiliates, and each of our and their respective directors, officers, managers, employees, shareholders, agents, representatives and licensors, from and against any and all losses, expenses, damages and costs, including reasonable attorneys’ fees, that arise out of your provision of any inaccurate or unauthorized Personal Information to us, sending us Personal Information in violation of our Terms, or your violation of this Privacy Policy or any rights of another. We reserve the right to take over the exclusive defense of any claim for which we are entitled to indemnification under this section. In such event, you agree to provide us with such cooperation as is reasonably requested by us.

WAIVER OF CLASS ACTION CLAIMS

You and “Marketing Company” agree that each party may bring disputes against the other party only in an individual capacity, and not as a plaintiff or class member in any purported class or representative proceeding, including, without limitation, a federal or state class action lawsuit. However, nothing in this section limits your right or “Marketing Company” ’s right to bring a lawsuit against each other as an individual plaintiff. This provision applies to the maximum extent permitted by applicable law to all claims that arise under, in connection with, or relate to this Privacy Policy or the Personal Information you provide to us (whether your own or any other Personal Information you provide), Personal Information that is automatically collected by us and/or obtained by us from third parties; that arose under, in connection with, or relate to any previous privacy policy in effect or that otherwise arose before these terms went into effect; or that may arise in connection with or after or otherwise relate to your Personal Information (or any other Personal Information you provide to us) after termination of any business relationship we may have with you, including cancellation or deletion of your accounts if applicable.

ACCESSIBILITY

Please see out Accessibility Support page if you experience any difficulty in accessing any part of the Websites or this Policy. You may also Contact Us below.

CHANGES TO OUT PRIVACY POLICY

The terms of this Privacy Policy may change from time to time. We will notify you of any material changes to this Privacy Policy by posting a notice on the homepage of the Website for a reasonable period of time after such changes are made that this Privacy Policy has been updated and by changing the “Last Modified” date at the top of this Privacy Policy, and for SME Clients by sending you notice of the updates in the iMedia Business Center. We encourage you to check this page and the iMedia Business Center periodically for any changes. Your continued use of the Websites and our Services following the posting of changes to these terms will mean you accept those changes.

GOVERNING LAW

This Privacy Policy will be governed by and construed in accordance with the laws of the State of Massachusetts, without giving effect to any principles of conflicts of law, with disputes resolved through arbitration in Boston. “Marketing Company” makes no representation that this Privacy Policy and such practices comply with the laws of any other country. Visitors who use the Websites and reside outside the United States do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. If you reside outside of the United States, by using our Websites, you consent to the transfer and use of your information outside your country.

FOR CALIFORNIA RESIDENTS

This Privacy Policy does not apply to California residents. If you are a California resident, please see below.

INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (EEA) OR UK

In the event “Marketing Company” collects personally identifiable information from individuals in the EEA and UK through its Website, it is the controller (as defined under the GDPR) for processing and using that Personal Data, the following rights will apply:

Rights of Individuals Based in the EEA or UK

Subject to applicable law, you may be able to exercise any of the following rights in relation to your Personal Data:

Right to know what information we have about you: This is known as the “right of access” and gives you the right to find out what, if any, Personal Data we have about you, how we process it, and to request a copy of the Personal Data.

Right to correct your information: This is known as the “right of rectification” and gives you the right to ask that we correct or complete any Personal Data we have about you.

Right to delete your information: This is known as the “right to erasure” or “right to be forgotten” and gives you the right to ask us to delete your Personal Data.

Right to change how we use your information: This is known as the “right to restrict processing” and gives you the right to ask us to change how we use your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us using it in a certain way.

Right to move your information: This is known as the “right to data portability” and gives you the right to ask to receive your Personal Data from us in a structured, commonly used and machine-readable format or to have it transmitted to another controller.

Right to stop us from using your information: This is known as the “right to object” and gives you the right to ask us to stop using your Personal Data when applicable.

Rights relating to how we use your information to categorize you or make decisions about you: This is known as the “right in relation to automated decision-making and profiling”: You have the right to be free from decisions we may make that are based solely on automated processing of your Personal Data, including profiling, if they produce a significant legal effect on you, unless such decision-making or profiling is necessary for entering into or performing a contract between you and us, or is made with your explicit consent.

Right to withdraw consent: If we rely on your consent to use your Personal Data, you have the right to withdraw that consent at any time. This will not affect our use of your data before we received notice that you wished to withdraw your consent.

Right to file a complaint with the supervisory authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the supervisory authority that is authorized to hear those concerns in your jurisdiction, although we invite you to Contact Us with any concern as we would be happy to try and resolve it directly.

You may exercise your rights by contacting us as indicated under the “Contact Us” section below. To change your consent settings for our use of cookies and other technologies, please see our Cookie Policy.

The requests above will be considered and responded to in the time period stated by applicable law. Certain information may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests.

CONTACT US

Patrons: If you are a Patron of a SME Clients you must contact the SME Clients directly about your choices and rights. Please refer to the SME Clients’ website to find out how to contact them.

If you are a Visitor or SME Clients and have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Information described here, your choices and rights regarding such use, or you wish to exercise your rights, please contact us as provided below.

Email us through our Online Request Form

Write us at: “iMediaSalesTeam”, P.O. Box 142 Harvard, MA 01451 ATTN: Privacy Officer

General Data Protection Regulation (GDPR) – European Representative

If you are an individual based in the EEA and/or UK, in addition to or alternatively to contacting us, you can also contact EDPO regarding matters pertaining to the processing of your Personal Data under GDPR as follows.  Write us at: “iMediaSalesTeam”, P.O. Box 142 Harvard, MA 01451 ATTN: GDPR