For purposes of this Policy, the following definitions shall apply:
“Customer Portfolios client” means the business entity for which Customer Portfolios is managing the marketing database. Customer Portfolios receives marketing data from each Customer Portfolios client and manages this data in a marketing database system that is used only by that specific Customer Portfolios client. The data that Customer Portfolios receives is from each Customer Portfolios client, not the end-consumer. The end-consumer provides their data to each respective Customer Portfolios client. End-consumers do not provide information directly to Customer Portfolios. Each Customer Portfolios client uses their respective marketing database, which Customer Portfolios hosts and maintains for the Customer Portfolios client, for the Customer Portfolios client’s marketing purposes to the Customer Portfolios client’s end-consumers.
“End-consumer” means the customer of a Customer Portfolios client.
“Personal information” means any information or set of information that is received by Customer Portfolios from a Customer Portfolios client that identifies an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Customer Portfolios client or to which Customer Portfolios client discloses personal information for use on Customer Portfolios client’s behalf.
We are not responsible for the privacy of any information you reveal or post in any public forum (e.g., message board or chat room), or for the privacy practices of websites that are operated or owned by third parties.
Types of Data Collected
We gather three basic types of information: Personal Data, Monitoring Data and IP Addresses.
Collection of Personal Data
Personal data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, postal address, or phone number (“Personal Data”). Customer Portfolios requests Personal Data from you when you register on the Site. The registration process may request that you provide your name, business email address, business address, business phone number, and company affiliation, and agree to the User Agreement presented at the time of registration. In addition to information collected during registration, Customer Portfolios may collect Personal Data voluntarily provided by you, including in emails to the Site, online forms, order and registration forms, surveys, and promotion participation.
You do not have to provide us with any Personal Data to visit the Site. However, if you choose to withhold requested information, you may not be able to visit all sections or use all features of the Site.
Collection of Monitoring Data and Use of Certain Online Tools
Customer Portfolios uses these technologies to understand how the Site is used and to customize and enhance the Internet experience for individual users. When you revisit the Site, Customer Portfolios may recognize you by a Tool and customize your experience accordingly. For example, once you have completed the registration process, a cookie and/or Tool will be used to avoid having you register again. We believe cookies and Tool technologies add value to the user experience, and the information resulting from these technologies is not sold or otherwise made available by Customer Portfolios to third parties for such third parties’ marketing purposes. We similarly expect our service providers to do the same.
Collection of IP Addresses
When you visit and interact with the Site, we and third parties with whom we have contracted to provide services to us may collect IP Addresses. Your Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Sites, along with the time(s) of your visit(s) and the page(s) that you visited. Where required by applicable law, this log information may be treated as Personal Data.
Use of Data Collected
Use of Personal Data Collected
Fulfillment of Requests. Customer Portfolios may use Personal Data about you to fulfill the purpose for which such Personal Data was provided (e.g., to send newsletters to you or deliver products and services).
From time to time, we may use Personal Data about you to inform you of products, programs, services, and promotions that we believe may be of interest to you. If you would prefer that we do not send electronic marketing messages to you, please see the “Your Choices” section below.
We may operate sweepstakes, contests and similar promotions (collectively, “Promotions”).
We typically ask you for certain Personal Data when you enter and, if applicable, win a Promotion. You should carefully review the rules, if any, of each Promotion in which you participate, as they may contain additional important information about our use of Personal Data about you.
Internal Business Purposes
We may also use Personal Data about you for our internal business purposes, such as data analysis, editorial and feedback purposes, providing customer support, customizing and improving the content and layout of the Site or its other websites, completing business transactions, marketing & promotion, statistical analysis of user’s behavior, product development, administering individual accounts, and meeting government regulatory requirements such as sales tax collection, audits and so forth.
Use of Monitoring Data Collected
Monitoring Data may be used for internal or external purposes such as researching and identifying market segments and needs. Because Monitoring Data does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to share Monitoring Data with affiliated entities and other third parties, for any purpose.
In some instances, we may combine Monitoring Data with Personal Data (such as combining your name with your geographic location). If we do combine Monitoring Data with Personal Data, the combined information will be treated by us as Personal Data as long as it is so combined.
Disclosure of Personal Data Collected
Third Party Service Providers
We work with third parties who provide services including but not limited to data analysis, order fulfillment, and other services of an administrative nature. We reserve the right to share Personal Data about you with such third parties for the purpose of enabling these third parties to provide such services in a manner consistent with our Privacy Shield obligations. We are liable, under the Principles, for a third party agent that processes Personal Data in a manner inconsistent with the Principles, unless not responsible for the event giving rise to the damage.
Strategic Partners and Co-Branded Sites
From time to time, we may enter into a special relationship with another company that is not owned by or affiliated with Customer Portfolios to provide or promote joint products, services, applications, or features (together, “Jointly Offered Items”). These special relationships may include co-branded sites (“co-branded pages”). Any information, including Personal Data, that you provide in connection with one of these Jointly Offered Items, and/or on one of these co-branded pages, will be shared with our third-party partners. By selecting an application or providing your information on these co-branded pages, or by signing up to receive information about or download a Jointly Offered Item, you also consent to our providing Personal Data about you to those third parties. However, please note that as third parties generally use Personal Data about you in accordance with their own privacy practices, you should check these third parties’ websites for information regarding their privacy practices. PLEASE NOTE THAT THIS PRIVACY STATEMENT DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES. If you do not want Personal Data about you shared with such third parties, please do not provide Personal Data in connection with the Jointly Offered Items and/or pages that are co-branded with third parties.
We reserve the right to share the Personal Data you provide in connection with Promotions with third-party sponsors of such Promotions (irrespective of whether such Promotions are hosted by us), or otherwise in accordance with the rules applicable to such Promotion. You should carefully review the rules, if any, of each Promotion in which you participate, as they may contain additional important information about a sponsor’s or other third parties’ use of Personal Data about you.
We reserve the right to transfer any and all information that we collect to an affiliated entity or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including without limitation in connection with any bankruptcy or similar proceedings).
Law enforcement; emergencies; compliance
Your Choices Regarding Personal Data Collection and Use
You may “opt-in” to having your Personal Data used by Customer Portfolios to send promotional correspondence to you now by checking the appropriate box on the Registration Form, or at any time in the future by changing your User Profile, or by contacting Customer Portfolios via postal mail, e-mail, or telephone using the contact information below. If you decide later that you no longer would like to receive promotional correspondence from us, you may indicate that preference by contacting us via postal mail, e-mail or telephone using the contact information below.
To the extent the laws of your country entitle you to review, modify, correct, change, update, block (so that Customer Portfolios continues to hold your Personal Data but temporarily refrains from processing it), remove or anonymize Personal Data about you that Customer Portfolios has collected, you may exercise this right by making a request via postal mail, e-mail or telephone using the contact information below. However, such requests may require you to register again with Customer Portfolios in the event you later wish to access the Site. Where the laws of your country require it, you may ask Customer Portfolios to certify that it has notified the entities to whom your Personal Data has been transferred of any such changes to or removal of your Personal Data. We may need to verify your identity before implementing your request. We will endeavor to comply with your request as soon as reasonably practicable. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed. We are not responsible for removing or suppressing information from the databases of third parties with whom we have already shared Personal Data about you.
Customer Portfolios has established reasonable precautions to protect collected Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction, which include contractual, administrative, physical, and technical steps. Technical measures may include use of firewall protection and encryption technology where Customer Portfolios deems such measures are appropriate. Please note that while Customer Portfolios has endeavored to create a secure and reliable data transfer mechanism, we cannot ensure or warrant the security of any information you transmit to us, through or in connection with these mechanisms, or that which is stored by us. If you have reason to believe that your interaction with us is no longer secure, please notify us of the problem immediately by contacting us via the “Contact Information” section below. Please note that if you choose to notify us via postal mail, this will delay our response time.
Where Customer Portfolios receives personal information from a Customer Portfolios client regarding an individual, the Customer Portfolios client informs the individual about the purposes for which it collects and uses personal information about them and the choices and means, if any, the Customer Portfolios client offers individuals for limiting the use and disclosure of their personal information. Customer Portfolios will manage the data from the Customer Portfolios client per the Customer Portfolios client requirements.
Customer Portfolios will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. Customer Portfolios will take reasonable steps to ensure that Personal Data is relevant to its intended use, and is accurate, complete, and current (as provided by you), but Customer Portfolios must depend on you to update or correct your Personal Data whenever necessary.
We will retain Personal Data about you for the period reasonably necessary to fulfill the purposes outlined in this Policy and consistent with retention periods required by law and/or regulation.
Export of Personal Data
You acknowledge and consent to the fact that Personal Data provided by you or collected by us may be stored and processed by us in the United States, which may provide a different level of data security than in your country of residence. You also acknowledge and consent to the fact that we may, at our discretion, store and process such data in other countries, and we will endeavor to protect the Personal Data under our control wherever it is processed or stored.
Customer Portfolios uses a variety of new technologies and social media options to communicate and interact with consumers. These websites and mobile applications include popular social networking and media sites, such as, Twitter, Facebook and LinkedIn. If you post updates to or receive updates from www.twitter.com, www.facebook.com, www.linkedin.com, and other social networking websites, from your wireless phone, your wireless-service provider may charge you for each text message you send and receive. You must consult your wireless service provider regarding its pricing plans, as rates may vary. Use of third party social networking websites, such as, Twitter and Facebook, are governed by the privacy practices of those websites. Customer Portfolios does not capture or store your login information or any other personally identifiable information for Twitter, Facebook, LinkedIn and other social networks, however, session information or cookies may be stored on your wireless phone, by their websites.
Customer Portfolios complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Customer Portfolios has certified that it adheres to the Privacy Shield Principles of notice, choice, and accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability. Click here to learn more about the Privacy Shield program, and to view Customer Portfolios’ certification.
Customer Portfolios receives marketing data from each Customer Portfolios client and manages this data in a marketing database system that is used only by that specific Customer Portfolios client. The data that Customer Portfolios receives is from each Customer Portfolios client, not the end-consumer. The end-consumer provides their data to each respective Customer Portfolios client. End-consumers do not provide information directly to Customer Portfolios. Each Customer Portfolios client uses their respective marketing database, which Customer Portfolios hosts and maintains for the Customer Portfolios client, for the Customer Portfolios client’s marketing purposes to the Customer Portfolios client’s end-consumers.
Limitations on Application of Principles
Adherence by Customer Portfolios to these Privacy Shield may be limited (a) by Customer Portfolios’ dependency on the Customer Portfolios client, (b) to the extent required or permitted by law or legal process, such as to respond to or investigate a legal or ethical obligation or request or pursuant to court orders, subpoenas, interrogatories or similar directive carrying the force of law; and (c) to the extent expressly permitted by an applicable law, rule or regulation.
Any questions or concerns regarding the use or disclosure of personal information should be directed to the applicable Customer Portfolios client. Customer Portfolios client 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, and Customer Portfolios will support Customer Portfolios client as directed by Customer Portfolios client. For complaints that cannot be resolved between Customer Portfolios client and the complainant, the Customer Portfolios client dispute resolution procedures should be followed. Additionally, Customer Portfolios is a participant in the dispute resolution procedures of the Direct Marketing Association pursuant to the Privacy Shield Principles. Individuals have the right to invoke Binding Arbitration as a means to resolve any Privacy Shield Complaints. Individuals must contact the company directly, followed by the DMA Privacy Shield Dispute Resolution program before they can invoke Binding Arbitration. Binding Arbitration will be used solely to resolve individual complaints with no monetary reward available.
Customer Portfolios LLC
88 Black Falcon Avenue
Boston MA 02210
If you choose to contact Customer Portfolios via e-mail about this policy, please mark the subject heading of your e-mail “Privacy Inquiry.”
We Participate in the DMA “Privacy Shield” Program
If you believe that we are not in compliance with the Privacy Shield principles, first contact us by any of the contact methods above. If you do not receive a prompt acknowledgment of your inquiry, or if your inquiry is not satisfactorily addressed, you can then contact the (U.S.) Direct Marketing Association (“DMA”) Privacy Shield Dispute Resolution Program. The DMA will then serve as a liaison to us to resolve your concerns in a timely manner. You can also contact the DMA Privacy Shield program at: firstname.lastname@example.org.