Middle-earth Enterprises Privacy Policy

Your privacy is important to us at Middle-earth Enterprises, LLC (“MEE” or “we”, or “us,” or “our”). This Privacy Policy (the “Privacy Policy”) applies to any websites or mobile applications owned or operated by us, including, without limitation, the website currently located at www.middle-earth.com (collectively, the “Websites”), any newsletters subscribed to via the Websites or other means (“Newsletter”), digital subscriptions to the Websites (if applicable), and any other service or product of MEE, including without limitation news, offers, promotions, advertising, mobile applications, or other digital properties, as expressly indicated by MEE such as through a link or other display of this Privacy Policy (collectively with the Websites, the “Service(s)”).

This Privacy Policy explains what information, including Personal Information (defined below), we collect from or about you on our Services, how we use or share such information, how to exercise any rights you may have with respect to your Personal Information, and the safeguards we have in place to reduce the risk of unauthorized access and use. For the purposes of this Privacy Policy, “Personal Information” means any information, alone or in combination, from which a natural person can be identified. It does not include data where identifiers have been removed (e.g., anonymous or aggregate data).

Please read this Privacy Policy carefully, which is part of and subject to our other terms of use, before using our Website or Services or signing up for the Newsletter. If you do not agree with our Terms of Use and/or the Privacy Policy, please do not sign up for the Newsletter or use our Website. By accessing or using our Website or by providing your email address, you agree to our use of your Personal Information and other information consistent with the Terms of Use and this Privacy Policy and agree to receive the Newsletter.

1. Contact Information

MEE may collect a variety of information about you, including your name, age, gender identification, address, email address or other personal information. To sign up to receive the Newsletter on MEE’s website, initially you will only be asked to provide your email address. When you sign-up for our Newsletter from our website, you will actually be signing up in Mailchimp. Mailchimp will keep and protect your email address according to their security and privacy policy. When MEE sends out its Newsletter, it will be doing so through Mailchimp. MEE will keep your email address or any other Personally Identifiable Information, and will share such information with third parties who will manage the Newsletter and be responsible for updating the email lists and working with MailChimp to ensure you receive the Newsletter. From time to time, MEE might run a contest with the winners receiving Middle-earth sponsored or licensed merchandise. In such a case, your personal information may be required to enter the contest of promotion and more personal information may be needed in order to claim your prize if you win. MEE may keep this information on its servers, or on a separate portable storage device kept in a secure location and only so long as it is necessary to comply with the terms and conditions of the contest or future contests.

2. Scope of this Privacy Policy

This Privacy Policy applies to information we collect:
This privacy policy applies to information we collect on our Websites and that you provide to us or allow us to obtain from other websites or third parties. This policy does not apply to information collected by others with Middle-earth themed websites that MEE does not own nor control.

3. Collection of Information

a. Collection of Personal Information.

MEE, or where relevant, a designated service provider, collects information that you choose to provide or we receive from other sources (such as from the scan of your Comic Con badge or other tradeshow badge, etc.). This may include Personal Information or Sensitive Personal Information (as defined below) that you provide when you sign up for the Newsletter or by submitting the information to enter a sweepstakes, contest, or to receive other promotions, news, offers or information about MEE, Middle-earth or similar subjects.

b. Collection of Sensitive Personal Information

“Sensitive Personal Information” shall be understood to mean any information that reveals: (a) consumer’s Social Security or other state identification number; (b) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) consumer’s geolocation; (d) consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, or text messages, unless the business is the intended recipient of the communication; (f) consumer’s genetic data; and (g) other categories according to applicable state laws.

Normally, MEE does not request Sensitive Personal Information, but such information may be provided by a vendor of a tradeshow that you attend and if you provide that information to the entity operating the tradeshow.

c. Sources of Personal Information and Sensitive Personal Information

Information You Provide. At present, MEE only asks you to provide your email address. If you desire to enter a contest or give-away and you win, you will be asked to provide additional information such as your name and mailing address so that the prize can be sent to you. If you submit Personal Information or Sensitive Personal Information to us about others, then you represent and warrant that you are authorized to do so and that you have received authorization from the person about whom you are providing the information and that person has consented to have all information used, disclosed, and transferred in accordance with this Privacy Policy. At present, MEE does not ask you to provide any Sensitive Personal Information.

Information Collected Automatically. At present, we do not use tools, technologies or third-party applications like cookies and web server logs to collect information automatically on the Website. The Website consists of a landing page hosted by Mailchimp that only asks you for your email address and only if you wish to receive MEE’s newsletter or enter into a contest, give away or sweepstakes.

Information Collected from Other Parties. MEE may request that Mailchimp provide MEE with email addresses of those who have signed up in order to choose contest prize winners. In such a case, MEE will use the email address of the contest prize winners to solicit additional information in order to send the prize to the winner. Those email addresses will not be stored on MEE’s servers but will be kept on a local computer and then transferred to an external storage device kept in a secure location.

d. Usage Data and Websites Activity

MEE does not collect such data.

e. Interactive Features

At present, MEE does engage vendors to provide certain interactive features on our Website

4. How We Use the Information We Collect

We may use your Personal Information:

• To send you the Newsletter through Mailchimp;

• To send you offers, contest information, advertising, other information;
• Where we need to perform a contract we have entered into with you or to fulfill your request;
• Where we need to comply with a legal obligation;
• With your consent.

In addition to the purposes for collection and use described above, we may collect and use Personal Information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may use Personal Information in connection with, or during negotiations of, the sale, assignment, merger, or reorganization of all or a portion of our business, and for our affiliated entities to assist in providing and maintaining our Services and for other permitted business purposes.

For more information on how to opt out of our use of your Personal Information and Sensitive Personal Information to you with offers and promotions, please see Section 11 below (“Preference Management”). Please note that if you exercise choice in this manner, you will continue to receive communications concerning your account and products and services you requested, and in response to any requests for information by you. Please also note that this opt-out process may take some time to complete, consistent with applicable law.

5. Disclosure of Personal Information 

At present, the only Personal Information that you provide is your email address and is kept with Mailchimp for the emailing of the Middle-earth Newsletter. As set forth above, MEE may obtain a list of email addresses from Mailchimp in order to process contents or giveaways. Such PII will not be kept on MEE’s serves but on a portable hard drive kept in a secure location. The information will be erased once sufficient time has elapsed for legal compliance.

At present, MEE will only disclose your Personal Information to third parties (including Mailchimp) to assist you in receiving news about MEE, its activities, contests, offers, etc. and for other purposes described in this Privacy Policy, i.e., disclosing your Personal Information as required by applicable law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may disclose Personal Information to other parties in connection with, or during negotiations of, a sale, assignment, merger, or reorganization of all or a portion of our business, and to our affiliated entities to assist in providing and maintaining our Services and for other permitted business purposes.

6. Text Messages

At present, MEE does not collect your phone number.

7. Cookies and Online Tracking Technologies 

At present, MEE uses no cookies or other tracking technology.

8. Online Advertising

At present, MEE engages in no on-line advertising, nor do we provide or sell your information to any third-party providers that advertise.

9. Selling and Sharing Personal Information

At present, MEE does not sell or share your Personal Information with any third-party other than Mailchimp.

10. Retention of Personal Information

As set forth above, MEE will store your Personal Information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the Personal Information was collected, or as may be required or permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove Personal Information from our systems and records or take appropriate steps to properly anonymize and deidentify it, where legally applicable.

11. Preference Management

If you want your email address or other Personal Information deleted, you can contact us and we will ensure that it is removed from Mailchimp’s system and on any external MEE devices. To contact MEE, go to the landing page where you entered your email address and follow the “contact us” link.

12. Rights and Choices for Personal Information

We offer our users certain choices related to their personal information. If you are a California resident, you may have additional rights under state law, which are provided in the “California Privacy Rights” Section 13 below.

We will not discriminate against you for choosing to exercise any of these privacy choices. You have the right to:
• Confirm that we process your Personal Information or request a copy of the Personal Information and Sensitive Personal Information we hold about you;
• Request that inaccurate information about you be corrected or deleted, taking into account the nature of the Personal Information and our purposes for processing it;
• Object to having your Personal Information and Sensitive Personal Information processed under certain circumstances;
• Request that we delete Personal Information and Sensitive Personal Information we hold about you;
• Request that we restrict processing your Personal Information and Sensitive Personal Information;
• Request to opt out of receiving the Newsletter and have your Personal Information deleted; and
• Withdraw consent provided for processing Personal Information and Sensitive Personal Information.

To exercise these rights or for any other questions related to this Privacy Policy, you may contact us using the link on the bottom of the landing page where you signed up to receive the Newsletter. Users in California and other jurisdictions as may be applicable may have additional rights as described herein. You may use an authorized agent to submit requests as allowed under applicable laws so long as you follow the procedures set forth herein.

Please note that if you make a privacy rights request, we may retain the Personal Information submitted in connection with your request for record keeping purposes.

13. California Privacy Rights

a. “Shine The Light” Law— California residents with whom MEE has an established relationship have the right to request certain information with respect to any Personal Information and Sensitive Personal Information MEE may have shared with third parties for their direct marketing purposes; however, at present MEE only allows Mailchimp to receive the email address in order to facilitate the distribution of the Newsletter.

For California residents under the age of 18 and registered users of the Website, California law (Business and Professionals Code § 22581) provides that you can request the removal of content or information you posted on the Website. Any such request should be sent to us using the “contact us” link located at the bottom of the landing page on which you provided your email address; however, please note that at present, MEE does not allow anyone to post content on its website. The only use that MEE has for your Personal Information is to distribute the MEE Newsletter and allow certain, eligible participates to win contests and give aways. Be advised, however, that applicable law may not permit us to completely or comprehensively remove your deleted content or for other reasons as set forth in this California law.

b. California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)— Under CCPA and CPRA, California residents may be able to exercise additional rights listed below in accordance with the laws of the State of California independently or through an authorized agent: Right to Correct, Right to Know, Right to Delete and Right to Opt Out.

Right to Correct. If you believe that Personal Information or Sensitive Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information – either the email address that you provided or information that you provided to an event (such as Comic Con) that MEE obtains by scanning your badge after receiving your permission.

Right to Know. You have the right to request that we disclose the following information for the 12-month period prior to the request date. Consumer requests of this nature may be made no more than twice in a 12-month period. You have the right to know what Personal Information we have collected about you, which includes:

The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information was collected;
• Our business or commercial purposes for collecting, sharing, or disclosing Personal Information;
• The categories of recipients to which we disclose Personal Information;
• The categories of Personal Information that we shared, and for each category identified, the categories of third parties to which we shared that particular category of Personal Information;
• The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information; and

• The specific pieces of Personal Information we have collected about you.

Where required by law, we will provide this information in a portable and, if technically feasible, readily usable format.

Right to Delete Personal Information. You have the right to request that we delete Personal Information and Sensitive Personal Information we collected from you or about you, subject to certain exceptions. Under the CCPA and CPRA, we may decline to delete your Personal Information under certain circumstances, for example, if we need the Personal Information to complete transactions or provide services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes (including maintaining business records), to comply with law, or to exercise or defend legal claims. Note also that we are not required to delete your Personal Information that we did not collect directly from you.

Right to Opt Out of Sales and Sharing of Personal Information. You have the right to opt out of the sale of your Personal Information and Sensitive Personal Information, and to request that we do not share your Personal Information and Sensitive Personal Information for cross-context behavioral advertising. At present, MEE does not sell nor provide your Personal Information to any third party other than Mailchimp to facilitate the distribution of the Newsletter.

Right to Limit Use and Disclosure of Sensitive Personal Information. At present, MEE does not collect, use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA and CPRA.

Rights Related to Automated Decision-Making. You have the right to opt out of automated decision-making, including profiling, that we use to evaluate certain personal aspects relating to your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. The law allows you this right even though at present, MEE does not use this technology.

Right to Non-Discrimination for the Exercise of Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA and CPRA, you also have the right not to receive discriminatory treatment by us.

You may use an authorized agent to submit requests; however, we must be able to satisfy ourselves that your authorized agent is really who they say they are. We do not discriminate against a user if they exercise any of the rights available under the CCPA or CPRA.

We will not fulfill a request pursuant to CCPA or CPRA unless you have provided sufficient information for us to reasonably verify you are the consumer about whom we collected Personal Information and/or Sensitive Personal Information. We will take appropriate steps to confirm the identity of a consumer making a request for purposes of verifying the authenticity of the request. You may be required to provide certain Personal Information to allow us to verify that you are the consumer about whom the request is being made. If you request that we provide you with specific pieces of Personal Information about you, we will apply heightened verification standards. An authorized agent may submit a request on behalf of a consumer if the consumer has provided the authorized agent with power of attorney in accordance with necessary state law; alternatively, the agent must (1) present verifiable written authorization from the consumer that the agent has the consumer’s permission to submit the request; and (2) independently verify the agent’s own identity with MEE.

Please note that while CCPA and CPRA rights do apply to Personal Information collected from job applicants and employees, this policy only covers those individuals in their capacity as users of our Website. Separate privacy disclosures will be made to these parties during their application and onboarding processes.

14. Nevada Privacy Rights

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may contact us by following the “contact us” link at the bottom of the landing page on which you provided your email address.

15. Information Security

MEE does not keep your Personal Information on its servers. It has contracted with Mailchimp to maintain and secure your personal information. MEE has conducted due diligence and has determined that Mailchimp has sufficient procedural and security safeguards in place to protect your Personal Information. If you do not want Mailchimp to have your Personal Information, you may contact us and we will remove you from the Newsletter list and delete your Personal Information.

16. Transfer of Information to the United States; International Users

The Websites are owned by MEE, but are operated by Mailchimp. If you are located outside the United States, please be aware that information we collect, including Personal Information and Sensitive Personal Information, may be transferred to, processed, and stored in the United States. By using the Website or Services, or providing us with any information, you consent to the transfer to and the processing, and storage of your information in the United States. Please be aware that the United States and jurisdictions other than the one in which you are located may not provide the same level of data protection as considered adequate in your country. Note also that your Personal Information and Sensitive Personal Information may be available to the US Government or its agencies under legal processes in the United States.

17. Children’s Privacy 

Our Website is not intended for children under 13 years of age. We do not knowingly collect Personal Information or Sensitive Personal Information from children under 13 on the Website. If you are under 13, please do not use or provide any information on the Website or through any of its features, register on the Website.

18. Links to Third Party Materials

The Website(s) or Services may include links to other websites or other online properties that are not under our control. MEE shall have no responsibility or liability for the content or privacy practices of any such linked websites or any link or linking program at any time. If you click on a link on our Website(s) and link to a third party’s website, then this Privacy Policy will not apply to your Personal Information and Sensitive Personal Information collected on that third-party’s website and you must read the privacy policy on that website to see how your information will be handled.

Social media widgets or tools may appear on our Website(s) or Services. Your interaction with and use of these widgets or tools will be governed by the terms of use and privacy policy of the applicable social media provider (e.g., Facebook).

19. Changes to Our Privacy Policy

We may update this Privacy Policy to reflect changes in our privacy practices. We will provide notice of any such changes (including when they will take effect) in accordance with applicable law. The changes will go into effect on the Effective Date shown in the revised Privacy Policy. If, in our opinion, a change is material, we will also endeavor to provide you with notice in advance of the material change. Such notice may include posting a notice on the Services or sending notification to the email address connected with your account. Your continued use of our Website or Services constitutes your consent to the revised Privacy Policy.

20. Contact Us

If you have any questions or concerns regarding this Privacy Policy, you can contact us by clicking on the “contact us” link at the bottom of the webpage on which your originally provided your email address.