This privacy notice covers those activities provided to our Clients by Customer Portfolios located at 88 Black Falcon Ave, #320 Boston, MA 02210 (“Customer Portfolios”, “we”, “us” or “our”). This policy applies to all personal information received by Customer Portfolios from our Clients in the United States, from the European Economic Area, and from Switzerland.
Customer Portfolios is processing your personal data as a “data processor,” on behalf of each Client which is a “data controller.” This means that it is the Clients who decide what data they share with Customer Portfolios, how it can be used, and determine the lawful basis for that sharing. Customer Portfolios does not use Client data for its own purposes; nor does it source any contact details itself, these are all captured and provided by the Clients.
Privacy Shield for Consumer Data
Customer Portfolios complies with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield 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, the United Kingdom, 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 click here.
What information we collect
Our Clients determine what type of information they collect, including (but not limited to)
- Full Name
- Email Address
- Mailing Address
- Phone Number
- Demographic Information
- Purchase History
- Web History
- Communication Preferences
We do not collect sensitive information such as credit card information or social security information.
How we collect it
We are the Data Processor, not the Data Controller. We have secure integrations with our clients’ customer-facing systems, such as ecommerce, point of sale, and email platforms.
Web History is collected through web pixels and anonymized cookies, which allow us to better personalize your online experience. To learn more about cookies, visit Allaboutcookies.org
What we do with it
Data is collected by the Clients to give consumers a personalized experience. We analyze the data at a holistic level to determine patterns that help our Clients market smarter and make the consumer experience more relevant and enjoyable.
As the Data Processor, Customer Portfolios operates on behalf of our Clients, providing services that enable organizations to apply database marketing strategies that increase marketing efficiency. Customer Portfolios processes marketing information on behalf of its Clients, acting on the instructions of its Clients. Customer Portfolios does not control or share such data without direction from the Client.
Transfer of Data
Your information may be transferred to — and maintained on — computers located outside of your governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside United States and choose to provide information to our Clients, please note that we transfer the data to United States and process it there.
Customer Portfolios, on the express instruction of a Client, may share Customer Data with other Marketing Vendors to create a better customer experience. Please visit the respective Client and Vendor Privacy Policies for details relating to the specific Vendor. 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.
We use physical, electronic and administrative safeguards designed to protect your personal information against loss, misuse or alteration. All information is stored securely and may only be accessed by employees with a legitimate business need to access the information.
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.
How to Access Your Information and Opt Out
You may still receive catalogs from Clients for six months after the date in which you opted out. This is because companies prepare their mailings months in advance and decide on contact lists early on in the process. You should notice a gradual reduction of unsolicited mailings, but please allow six months for the request to become fully effective.
Customer Portfolios LLC
88 Black Falcon Avenue
Boston MA 02210
We participate in the ANA “Privacy Shield” Program
Customer Portfolios is a participant in the dispute resolution procedures of the Association of National Advertisers 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 ANA 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.
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.) Association of National Advertisers (“ANA”) Privacy Shield Dispute Resolution Program. The ANA will then serve as a liaison to us to resolve your concerns in a timely manner. You can reach the ANA Privacy Shield program at:
Attn: Privacy Shield
225 Reinekers Lane, Suite 325, Alexandria, VA 22314
EU and Swiss individuals can also contact the dispute resolution provider (ANA) online at https://thedma.org/resources/consumer-resources/privacyshield-consumers/
We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).