Privacy Policy

This Privacy Policy explains how we collect your personal data on those websites of Customer Portfolios, LLC and its service providers that post or link directly to this Privacy Policy (collectively, the “Site”), how we protect such data, and the choices you have concerning our use of such data. Please read this Privacy Policy carefully. Customer Portfolios may from time to time update this Privacy Policy. Any changes to this Privacy Policy will become effective when we post or link to the revised Privacy Policy on the Site. Please review the “Revision History” legend at the bottom of this document to determine when this Privacy Policy was most recently revised.

This Privacy Policy applies only to personal data that is (a) collected by us through the Site or (b) included within customer lists that may be acquired by us from third parties. Other than with respect to item (b) of the preceding sentence, this Privacy Policy does not apply to our offline collection of personal data.

Definitions

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.

For the purposes of this Privacy Policy, “Customer Portfolios”, “CP”, “we”, “us”, and “our” means Customer Portfolios, LLC.

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.

As noted above, this Privacy Policy does not address our offline collection of information, with the exception of Personal Data included on customer lists that may be acquired by us from third parties. In that regard, we note that, from time to time, we may acquire from third parties certain lists containing the names and contact information of individuals who may be interested in our products and services. If we acquire such a list for promotional purposes, we seek to obtain appropriate representations from the other party that the listed individuals have opted into receiving promotional messages from any acquirer of such list.

Collection of Monitoring Data and Use of Certain Online Tools
In addition to Personal Data, Customer Portfolios and its service providers may collect and/or track information that by itself cannot be used to identify or contact you, e.g., demographic information, domain names, computer type, browser types, screen resolution, and other anonymous statistical data involving the use of the Site (“Monitoring Data”). We use Monitoring Data to help us understand who uses our Site and to improve and market it. Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user. Additionally, we may aggregate Personal Data in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information is considered Monitoring Data for purposes of this Privacy Policy.

To enhance the Internet experience on the Site, Customer Portfolios and our service providers may use ‘cookies’ on the Site. Cookies are data that a web server transfers to an individual’s computer for record-keeping and other purposes. We use cookies and other technologies to facilitate users’ ongoing access to and use of our Site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular website, to your computer. If cookies are disabled, however, all features of the Site may not operate as intended. Information about the procedure you are required to follow in order to disable cookies can be found on your Internet browser provider’s website. We expect our service providers to honor any decision by you to block or disable cookies in connection with the Site.

We and our service providers may also use various common Internet tools such as ‘pixel tags,’ ‘action tags,’ ‘web beacons,’ ‘.gif tags,’ ‘JavaScript’ or similar technologies (together, “Tools”) in connection with Site pages and email messages in certain formats to among other things, track the actions of Site users and email recipients, to determine the success of marketing campaigns and to compile statistics about Site usage and response rates. Tools allow us to count users who have visited certain pages of the Sites, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. When used in email messages in certain formats, Tools can tell the sender whether and when the email has been opened.

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).

Other Communications 
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.

Promotions
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.

Administrative Communications
In addition, Customer Portfolios reserves the right to use Personal Data to send to you important information regarding the Site, your account status and changes to the User Agreement, this Privacy Policy, or any other policies, agreements or transactions relevant to your use of the Site. Because this information may be important to your use of the Site, you may not opt-out of receiving such communications.

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.

Promotions 
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.

Assignment
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
Notwithstanding any other provision of this Privacy Policy to the contrary, we reserve the right to disclose Personal Data about you to others as we believe to be appropriate (a) under applicable law; (b) to comply with legal process; (c) to respond to governmental requests; (d) to enforce our Terms of Service; (e) to protect our operations or those of any affiliated entities; (f) to protect the rights, privacy, safety, or property of Customer Portfolios, the affiliated entities, you or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain. For example, we may, to the fullest extent the law allows, disclose Personal Data about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities.

Your Choices Regarding Personal Data Collection and Use
Choice
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.

Access
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.

Links

The Site may contain links to other Internet websites. These linked sites are not under Customer Portfolios control and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. We provide such links only as a convenience, and Customer Portfolios does not endorse, and is not responsible for, the privacy practices or the content of these websites. If you provide any Personal Data through any such third-party website, your transaction will occur on such third party’s website (not the Site) and the Personal Data you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, AFFILIATED ENTITIES THAT DO NOT POST OR LINK DIRECTLY TO THIS PRIVACY POLICY.

Security Measures
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 site for users, we cannot ensure or warrant the security of any information you transmit to us through or in connection with the Site or that 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 in accordance with Section “Contact Information for Customer Portfolios”) below (note that if you choose to notify us via postal mail, this will delay the time it takes for us to respond to the problem).

Notice
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.

Data Integrity
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.

Retention Period
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.

Mobile Information
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.

Enforcement
Customer Portfolios periodically will review its compliance with this Privacy Policy. Customer Portfolios will also review and respond to any formal written complaints that we received from you. Customer Portfolios will cooperate with the appropriate regulatory authorities, to resolve any complaints that cannot be resolved between us.

Privacy Shield Privacy Policy for Consumer Data
Customer Portfolios complies with the U.S.-EU Privacy Shield Framework and the U.S.-Swiss Safe Harbor Framework 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. To learn more about the Privacy Shield program, and to view Customer Portfolios’ certification, please visit Link coming soon!

Scope

This Privacy Shield Privacy Policy (the “Policy”) applies to all personal information received by Customer Portfolios from applicable Customer Portfolios clients in the United States, from the European Economic Area, and from Switzerland.

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.

Dispute Resolution
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.

Contact Information
We can be contacted using any of the methods below in connection with the matters addressed in this Privacy Policy: To Opt-out, modify your information or otherwise change your preferences, please contact using the information below:

Security Officer
Customer Portfolios LLC
88 Black Falcon Avenue
Suite 320
Boston MA 02210
Phone: +1-617-225-9501
E-mail: PrivacyInquiry@customerportfolios.com

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 reach the DMA Privacy Shield program at:

Privacy Shield Line
Direct Marketing Association
1615 L Street, NW – Suite 1100
Washington, DC 20336

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