Marketing Services Privacy Policy

Introduction

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.

This Privacy Policy is effective as of January 1, 2020. 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.

Definitions

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 U.S.-EU 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 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.

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
  • Birthday
  • 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 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.

How to Opt Out

To opt out of communications from our Clients, please see each respective Clients’ Privacy Policy. Unsubscribe links can be found at the bottom of every Client email. Clients have within 10 days to make sure that the consumer is opted out.

To move forward with an erasure request with one of our Clients, please see your brands’ respective Privacy Policy and guides for erasure request submission. Once received from the respective Client, Customer Portfolios will nullify and encrypt all attributes containing personal information (PI) and personal identifiable information (PII) on file relating to you, the consumer. This encryption is irreversible once processed.

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.

Contact Info

We can be contacted using any of the methods below in connection with the matters addressed in this Privacy Policy.

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

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 acknowledgement 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

We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).