PRIVACY POLICY

 

This Privacy Policy was last updated on November 14, 2019.

We take your privacy very seriously and are committed to being transparent with how we use your information. This website (www.complex.com), mobile application and any of our services and sites directing you to this Privacy Policy are controlled by Complex Media, Inc., 229 W. 43 Street, 10th Floor, New York, NY 10036 (hereinafter, “Complex,” “we,” or “us”).

This Privacy Policy also incorporates the terms contained in the Terms of Use.

Summary

Purpose of data collection, data processing and data use

Complex is engaged in operating online publications covering forthcoming trends and news in fashion, art, music, and culture. Complex collects and processes personal data for the following purposes:

  • Operation of the website, including statistical analysis of the use
  • Provision of content
  • Advertising
  • Execution of contracts

Groups of people concerned and the associated data and category of data

Customer and user data, data from partner companies that are needed to fulfill the purpose.

Children under 13

Our website is not directed toward children under 13 and we will not knowingly collect information for any child under the age of 13.

If you are the parent of a child under the age of 13 and have a concern regarding your child’s information on our website, please contact us at legal@complex.com.

Recipients or groups of recipients to whom data may be disclosed

Public authorities in connection with an overriding legal regulation, contractors in connection with a partnership in accordance with Article 28 of the General Data Protection Regulation (GDPR), external partners and internal departments of Complex to fulfill the purpose.

Time limits for the deletion of data

Under statutory provisions, a variety of obligations and periods apply with regard to the keeping of data. Once these retention periods have expired, the corresponding data must be erased as a matter of routine. Any data not affected by this is deleted if the purposes mentioned above cease to apply.

Transfer of data to third countries

By using social plugins, such as the Facebook like button, data may be transferred to a third country.

Legal basis for the collection and processing of personal data:

Legal basis for the processing of personal data on the basis of the user’s consent is Art. 6 (1) lit. a GDPR.

Legal basis for the processing of personal data which is necessary for the conclusion or performance of a contract entered in the interest of the user is Art. 6 (1) lit. b GDPR. This also applies to pre-contractual processes.
Legal basis for the processing of personal data which is required to fulfill a legal obligation concerning Complex is Art. 6 (1) lit. c GDPR.

Legal basis for the processing of personal data which is necessary in order to realize a legitimate interest held by either Complex or a third party, except where such considerations are overridden by the need to protect the user’s interests or fundamental rights, is Article 6 (1) lit. f GDPR.

Our Privacy Policy Explains

  • What information we collect and why we collect it
  • How we use that information
  • Your rights with regard to the processing of personal data by Complex

If you have any questions about this Privacy Policy or would like to know more about what information we collect and store, please contact us at: legal@complex.com.

Information We Collect

We collect information to provide better services to our users and improve our business. We collect information in two ways:

Information you give us or information provided through a social network.

For example, some of our services require you to sign up for an account, provide information for a contest or award, or link an account through a social network. The information we collect may include email, name, phone number, address, or credit card information. Such information is necessary to render the services requested and/or to provide contractual services. Legal basis for such data processing is Article 6 (1) lit. a, b or f GDPR. Unless statutory provisions provide otherwise, the data will be deleted if the purpose cease to apply, e.g., if the services are performed in full or if you unsubscribe from our services.

When you contact us, either by e-mail or by using our contact form, we collect the data you have submitted with your request (e.g., name, e-mail) and may keep a record of your communication to help solve any issues you might be facing. Legal basis for such data processing is Article 6 (1) lit. b and lit. f GDPR. Unless statutory provisions provide otherwise, the data will be deleted if the purpose cease to apply, e.g., if we have processed your request.

We work with social networks including, but not limited to Facebook, Twitter, Snapchat, Instagram, and YouTube. We have access to information you directly provide and information through those social networking services based on your privacy settings on those networks. Such information serves to enhance the usability of our services. Legal basis for such data processing is Article 6 (1) lit. f GDPR. Unless statutory provisions provide otherwise, the data will be deleted if the purpose cease to apply.

Information we gather from surveys.

If you take part in one of our surveys, we store your contact data and the information you provide as part of the survey. We use this data in anonymous form only. It is not possible to draw any conclusions about your person. We publish the results of the survey on our website or share them with partner companies, e.g. advertising partners or connected websites. For example, we may share information to show trends about the general use of our services.

The legal basis for such data processing is Art. 6 (1) lit. f) DSGVO. The data will be deleted as soon as the purpose of the storage has ceased to exist, e.g., when the survey has been completely evaluated.

Information we get from your use of our services.

We may collect usage information when you visit different parts of our site or use our applications. We may also automatically collect certain technical information such as device-specific information (such as your hardware model, operating system version, device type, unique device identifiers, and mobile information if you use a mobile device to access the site). Such information is necessary to provide our services and is used in anonymized or pseudonymized form only. Legal basis for such data processing is Article 6 (1) lit. f GDPR. Unless statutory provisions provide otherwise, the data will be deleted if the purpose cease to apply.

Information We Share

We do not share personal information with companies, outside organizations and individuals unless one of the following circumstances apply:

With your consent

We will share personal information with companies, outside organizations, or individuals if we have your consent to do so. We may also seek your additional consent for purposes of which you are subsequently notified.

For external processing

We provide personal information to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. These companies are authorized to use your personal information only as necessary to provide these services to us. If personal data is transferred to or processed in countries outside the European Union, we make sure that our contractors guarantee an adequate level of data protection.

For legal reasons

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We will share personal information with companies, outside organizations, or individuals if we have a good faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process, or enforceable governmental request, detect, prevent, or otherwise address fraud, security, or technical issues or protect against harm to the rights, property, or safety of our users or the public as required or permitted by law.

In case of a sale or asset transfer

If we become involved in a merger, acquisition, or other transaction involving the sale of some or all of our assets, user information, including personal information collected from you through your use of our services, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you and ask for your consent, where applicable.

In anonymous form for business purposes

We may share anonymous, non-personally identifiable information publicly and with our partners such as businesses with which we have a relationship, advertisers or connected sites. For example, we may share information to show trends about the general use of our services.

Information Security

We work hard to protect our users from unauthorized access to or unauthorized alteration, disclosure, or destruction of information we hold; however, no website is entirely secure. You should protect the account information in your possession as well. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at legal@complex.com.

  1. Cookies

Technologies such as cookies, beacons, tags, and scripts are used by us and our advertising and marketing partners, affiliates, and service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual, as well as aggregated, basis. We use cookies to remember users’ settings (e.g., geographic location) and for authentication. You can decide whether to accept cookies.

When visiting our website, we will ask you for your consent to use certain cookies. You may at any time revoke your consent to such use by using the opt-out button or the opt-out functions described below or by sending an e-mail to legal@complex.com.

In addition, users can control the use of cookies at the individual browser level by changing your browser settings (mostly found under “Options” or “Settings” in the browser menu). You have the choice of accepting all cookies, being informed about each cookie or refusing all. To manage Flash cookies, please click here.

If you choose not to accept cookies on our website, it is possible that the functionality of our website may be limited and some services may not be usable.

We and our service providers, marketing partners, and affiliates may use advertising cookies to deliver ads that we believe are more relevant to you and your interests. For example, we may use targeting or advertising cookies to customize the advertising and content you receive on our site, to limit the number of times you see the same ad on our site and to help measure the effectiveness of our advertising campaigns. These cookies remember what you have looked at on the site and other sites, and may be combined with other information acquired from third parties.

You may visit the links below to opt-out of cookies from over 50+ major third party behavioral advertising providers:

  1. Store

To place an order, you must create an account using your e-mail address and a personal password.

When placing an order via our store, we collect personal data required to process your order (name, billing address, shipping address, phone number, payment method, email adress). These data may be transferred to payment and shipping service providers.

Legal basis for such data processing is Article 6 (1) lit. b GDPR. Due to legal regulations, we are obliged to store order, address and payment data for 10 years. 

Our store is hosted by Bonsai, a service provided by Bonsai, Inc., 111 George Street, Suite 202, Toronto, CA, M5A 2N4). Bonsai provides us with an e-commerce platform that allows us to sell products to you. Personal data submitted during the order process will be stored on Bonsai’s servers solely for purposes of fulfilling your order. For further information, please see Shop Bonsai’s Privacy Policy

For more details, visit our Cookie Policy page.

III. Links to external social networks and social media widgets

Our website includes links to social networks and social media features. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policies of the companies providing them. Please note that Complex is not liable for the privacy policies of these companies. We recommend you to read the privacy policies of those companies after you get to one of their websites.

Facebook

Our website uses social plugins provided by the social network Facebook. The responsibility for the processing of data via such plugins lies with Facebook Inc. The plugins are identifiable by a Facebook logo (white letter f on blue background or a thumb up icon) or the notice “Facebook Social Plugin.” For a full list of all social Plugins, please see https://developers.facebook.com/docs/plugins?locale=en_US.

For the information on the purpose and scope of data collection and procession by Facebook, as well as your rights in this respect and settings options for protecting your privacy, please visit Facebook’s privacy policy: https://www.facebook.com/policy.php.

Google+ and Twitter

Our website also has links to our Google+ and Twitter pages and uses social plugins provided by the social network of Google+ and Twitter. Sole responsibility for Google+ and its websites lies with Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; for Twitter with Twitter Inc., 1355 Market St., Suite 900, San Francisco, CA 94103.

For further information regarding the purpose and scope of data collection, and regarding the further processing and use of your data by Google+ and Twitter, see the privacy rules of Google+ and Twitter. These are available online at http://www.google.com/intl/en/policies/privacy for Google+ and at https://twitter.com/privacy?lang=en for Twitter. There you will find, amongst other things, information regarding settings for the protection of your privacy and regarding your further rights regarding the collecting, processing and use of your data by Google+ and Twitter.

Instagram

Our website has links to our Instagram page and uses social plugins provided by the social network of instagram.com. The sole responsibility for Instagram and its website lies with Instagram LLC, 1601 Willow Road, Menlo Park, CA 94025, USA (“Instagram”).

For further information regarding the purpose and scope of data collection, and regarding the further processing and use of your data by Instagram, see Instagram’s own privacy rules. These are available online at https://help.instagram.com/155833707900388. There you will find, amongst other things, information regarding settings for the protection of your privacy and regarding your further rights regarding the collecting, processing and use of your data by Instagram.

Snapchat

Our website has links to our Snapchat page and uses social plugins provided by the social network of Snapchat. The sole responsibility for Snapchat and its website lies with Snapchat, Inc., Attn: copyright Agent, 63 Market Street, Venice, CA 90291, USA (“Snapchat”).

For further information regarding the purpose and scope of data collection, and regarding the further processing and use of your data by Snapchat, see Snapchat’s own privacy rules. These are available online at https://www.snap.com/en-US/privacy/privacy-policy/. There you will find, amongst other things, information regarding settings for the protection of your privacy and regarding your further rights regarding the collecting, processing and use of your data by Snapchat.

YouTube

Our website has links to our YouTube page and uses social plugins provided by the social network of YouTube. The sole responsibility for YouTube and its website lies with YouTube LLC with its main office at 901 Cherry Avenue, San Bruno, CA 94066, USA. YouTube is represented by Google Inc. with its main office at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

For further information regarding the purpose and scope of data collection, and regarding the further processing and use of your data by YouTube, see YouTube’s own privacy rules. These are available online at https://www.google.com/intl/en/policies/privacy/. There you will find, amongst other things, information regarding settings for the protection of your privacy and regarding your further rights regarding the collecting, processing and use of your data by YouTube.

VIII. Local Storage – HTML5

We may use Local Storage, such as HTML5 to store user preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your web browsing activity may also use HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. Legal basis for such data processing is Article 6 (1) lit. f GDPR. Unless statutory provisions provide otherwise, the data will be deleted if the purpose cease to apply.

  1. Log information

When you use our services or view content provided by us, we may automatically collect and store certain information in server logs. This information may include:

  • Details of how you used our service, such as your navigation paths and search queries.
  • Mobile related information if you access our website using your mobile device.
  • Internet protocol address.
  • Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
  • Cookies that may uniquely identify your browser, mobile device, or your account.
  • Browser type, operating system, and other technical information.

We may combine this automatically collected log information with other information we collect about you. We do this to improve marketing, analytics, and the products and services we offer you. Such information is used in anonymized or pseudonymized form only. Legal basis for such data processing is Article 6 (1) lit. f GDPR. Unless statutory provisions provide otherwise, the data will be deleted if the purpose cease to apply.

You may at all times object to the use of personal data for the above mentioned purposes by informal notification by written letter to Complex Media, Inc., 229 W. 43rd Street, 10th Floor, New York, NY 10036, or by e-mail to legal@complex.com.

  1. Your right to information and other rights of the persons affected

Right to information

You have the right to obtain confirmation as to whether or not your personal data is being processed by us. Where that is the case, you have the right to access to the personal data and the following information:

  1. the purposes of the processing;
  2. the categories of personal data concerned;
  3. the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  5. the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
  6. the right to lodge a complaint with a supervisory authority;
  7. where the personal data are not collected from the data subject, any available information as to their source;
  8. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Where personal data is transferred to a third country, you have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.

Right to rectification

You have the right to obtain the rectification of inaccurate or incomplete personal data.

Right to erasure

You have the right to obtain the erasure of personal data where one of the following grounds applies:

  1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. you withdraw the consent on which the processing is based according to of Article 6 (1) lit a or Article 9 (2) lit. a GDPR, if there is no other legal ground for the processing;
  3. you object to the processing pursuant to Article 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21 (2) GDPR;
  4. the personal data have been unlawfully processed;
  5. the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which Complex is subject;
  6. the personal data have been collected in relation to the offer of information society services referred to in Article 8 (1) GDPR.

If Complex has made personal data public and is obliged to erase the personal data, Complex, taking account of available technology and the cost of implementation, takes reasonable steps, including technical measures, to inform controllers which are processing the personal data you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

The right to erasure shall not apply to the extent that processing is necessary:

  1. for exercising the right of freedom of expression and information;
  2. for compliance with a legal obligation which requires processing by Union or Member State law to which Complex is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  3. for the establishment, exercise or defense of legal claims.

Right to restriction of processing

You have the right to obtain restriction of processing where one of the following applies:

  1. you have contested the accuracy of the personal data, for a period enabling Complex to verify the accuracy of the personal data;
  2. the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
  3. Complex no longer needs the personal data for the purposes of the processing, but is required by you for the establishment, exercise or defense of legal claims;
  4. you have objected to processing pursuant to Article 21 (1) GDPR pending the verification whether the legitimate grounds of Complex override yours
  5. Where processing has been restricted under the above, such personal data shall, with the exception of storage, is only processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If you have obtained restriction of processing you will be informed before the restriction of processing is lifted.

Notification regarding rectification or erasure of personal data or restriction of processing

Complex will communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with the above to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. On your request, Complex informs you about those recipients.

Right to data portability

You have the right to receive the personal data you have provided to Complex in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller, where:

  1. the processing is based on consent pursuant to Article 6 (1) lit. a of Article 9 (2) or on a contract pursuant to Article 6 (1) lit. b GDPR; and
  2. the processing is carried out by automated means.

In exercising your right to data portability, you have the right to have the personal data transmitted directly from one Complex to another controller, where technically feasible.

The right to data portability shall not apply to processing necessary for the performance of a task carried out in the public interest.

Right to object

  1. You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you that is based on point Article 6 (1) lit. a or lit. f GDPR, including profiling based on those provisions. Complex no longer processes the personal data unless Complex demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
  2. Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  3. If you object to processing for direct marketing purposes, the personal data is no longer being processed for such purposes.

Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

This shall not apply if the decision:

  1. is necessary for entering into, or performance of, a contract between the data subject and a data controller;
  2. is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
  3. is based on the data subject’s explicit consent.

In all such cases, please refer to us by written letter to Complex Media, Inc., 229 W. 43rd Street, 10th Floor, New York, NY 10036, or by e-mail to legal@complex.com.

Right to revocation

You may at all times revoke consent to the processing of personal data. You can use the function on this page at I. Cookies.

Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data by Complex relating to you infringes the provisions of the GDPR.

In all such cases, please refer to us by written letter to Complex Media, Inc., 229 W. 43rd Street, 10th Floor, New York, NY 10036, or by e-mail to legal@complex.com.

If you have any questions about your privacy or data protection, please feel free to contact us at any time using the details given above.

XII. Changes

We may update our Privacy Policy from time to time. Thus, we advise you to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately, after they are posted on this page.