We are ˮֱ, a global behavioral marketing company based in the United States with operations in Europe and Asia. Through our digital, direct, sampling, fulfillment, and customer care services, we help our clients manage a full consumer experience. And in doing so, we are helping clients shorten the distance between behavior and action. In addition to processing personal information legitimately, ethically, and lawfully, we believe marketing is, and will always be, about establishing trust with individuals and working hard to maintain it. Providing you with a simple, honest description of how we use (or “process”) your information is critical to establishing this trust. We also believe that giving you control over how we use your information is critical to keeping your trust. You have certain rights regarding the information we process about you and can exercise your privacy rights at any time by visiting our or by calling our privacy team toll-free (as further described below.)
We work hard to conform our practices to the laws and regulations which govern our processing of personal information. We rely on special contracts (often referred to as Data Transfer Agreements, Standard Contractual Clauses or Model Clauses) to transfer and process your information in the United States, Europe and the Philippines to ensure adequate privacy and security of your personal information. While we cannot guarantee 100% security, we implement technical and organizational measures designed to protect the privacy and security of your information, and we regularly review and improve our privacy and security practices. Visit the We implement technical and organizational measures to protect information section of our privacy statement to learn more. Finally, you may not use our websites if you are under the age of 18.
We may process different kinds of information about you:
Personal information about you at home. Information about you as an individual, such as your name, gender, telephone number, e-mail address, social media identifiers, and postal address. Note that if you live in the U.S., we may also process additional information about you, such as demographic attributes (age, home ownership, marital status, gender), behavioral indicators (brand alliances, communication channel preferences or purchasing habits) or interest indicators (life stage, lifestyle or activities).
Personal information about you at work. Information about you as a business professional, such as your name, gender, job title or function, company name, telephone number, e-mail, social media identifiers, and postal address.
Behavioral information about your use of our websites. Information concerning your visits to and use of our websites, such as the web pages, articles and website features you interact with and other technological data associated with your visit (how you came to our website, your internet domain, IP address, unique device identifiers, internet browser, operating system or mobile device platform).
Social media information you make publicly available. Information about your social media identifiers (e.g. – Facebook ID, Twitter ID or YouTube ID) and any content, posts, or information you make publicly available on social media platforms (which may describe your behavior, beliefs, sentiments, opinions, and interests).
We may use information about you in support of the following objectives and purposes:
Provide our products and services to other businesses. We may receive personal information from our clients about you as a prospective, current or former customer or employee responsible for facilitating the delivery of our products and services to your company. We do not own or control such information. Visit “Your Privacy Rights and How to Exercise Them” in our Privacy Statement to learn more.
Compile and license information to our clients. We may assemble and share personal information we receive from data aggregators and brokers for our, and our clients’, legitimate business, advertising and marketing interests. Our use, and our clients’ use, of such data is subject to strict guidelines. Visit “We use information about you to offer clients data” in our Privacy Statement to learn more.
Make inferences about you or your company. We may assemble and use personal information profiles to make inferences about you or your company, inform decisions about our products and services, and communicate with you. We may use cookies or similar tools to store small pieces of information on your computer’s hard drive in accordance with your choices. We do not recognize “do not track” signals submitted through browsers. Visit the , the , or “We use information about you for profiling, advertising and direct marketing purposes” in our Privacy Statement to learn more.
Advertise and market our products and services. We may process personal information we receive from you and other sources to present you with advertisements or send you marketing communications about our products and services.
Compile social media content to inform strategic business, advertising, and marketing decisions. We may process personal information made publicly available from social media companies and platforms, create profiles that describe or predict behavioral trends, and use such profiles to inform strategic business, advertising, and marketing decisions. Visit “We use information about you to compile the Behavioral Index” in our Privacy Statement to learn more.
Respond to your inquiries and requests. We will use personal information to facilitate your inquiries, requests, preferences and privacy rights. This includes personal information we ask you to provide as needed to validate your identity. Visit “Verifying your identity in connection with your requests” in our Privacy Statement to learn more.
Comply with the law and protect legal rights. We may process personal information to comply with the law, protect our rights and safety, or protect the rights and safety of others.
We will share information about you with:
Recipients located abroad. We may share personal information with recipients located in another country when protected by special contracts designed to ensure adequate privacy and security protection, often referred to as Data Transfer Agreements, Standard Contractual Clauses or Model Clauses.
Other ˮֱ companies. We may share personal information with parent, sister or subsidiary ˮֱ companies, and with service providers we retain under a contract, to support the objectives and purposes defined above.
Clients. We may share personal information with clients to support our legitimate interest to compile and license information in support of their business, advertising and marketing objectives.
Legal authorities. We may share personal information with law enforcement agencies, regulators or other legal representatives to comply with the law, legal procedures, court orders and similar legally compelled disclosure orders.
Corporate merger. We may share personal information with another company to support a change to our corporate control, a merger, an acquisition or the sale of our company or assets.
We retain information about you differently based on different circumstances:
Client information. We retain personal information provided to us by our clients for the duration defined in our contract.
Information we license to clients. We retain personal information we license to clients for a period of one year, determined by the date we first obtain it, when it is updated by the source provider, or when it is otherwise used to communicate with you without your objection.
Social media information. We retain personal information obtained from social media companies until we create a report about behavioral trends and predictions. We retain these reports until we determine the trend or prediction described is no longer reflective of the behaviors, beliefs, sentiments, opinions, or interests relevant to strategic business, advertising, or marketing decisions.
Business and compliance records. We retain some personal information to compile and retain our business and compliance records for as long as needed to comply with the law.
You have the following privacy rights, and can exercise them at any time by visiting our preference page or calling us toll-free using the below contact information:
Receive information about how we process personal information. You have the right to be fully informed about our processing of information about you. We work hard to be transparent about our business objectives and the information about you that we process in support of such objectives. We also work to notify you when we acquire or collect information about you or when we use such information for the purpose of communicating with you. We also include choice mechanisms in our disclosure statements to allow you complete control over the processing of information about you.
Inquire, access, view or obtain a copy of personal information. You have the right to inquire if we process information about you, access or review such information, or even obtain an electronic copy of such information that you can use elsewhere.
Change personal information. You have the right to change your personal information at any time.
Object to the processing of personal information. You have the right to object to our processing of your personal information for the purposes of:
- Pursuing our legitimate business interests
- Supporting our advertising and direct marketing objectives
- Making automatic decisions concerning you
- Creating or using profiles to make inferences about you
- Licensing or selling information about you to other parties
- Sharing information about you outside your home country or region
- Presenting you with online advertisements based on your location or online behavior
Request the deletion of personal information. You have the right to request we delete information about you.
Not be discriminated against for exercising your rights. You have the right to not be discriminated against for exercising your privacy rights.
Prevent solicitations. You have the right to prevent marketing communications from being delivered to you via email, phone or direct mail.
Request assistance. You have the right to ask us questions about the processing of information about you and to request that we help you exercise your rights.
Issue a complaint regarding the processing of personal information. You have the right to issue a complaint about our processing of information about you through our Privacy Department. While we are committed to addressing your concerns, you also have the right to lodge a complaint with , or authorities about our use of information about you.
Restrict the processing of personal information. You have the right to temporarily suspend, or place a legal hold on, our processing of information about you. This right is typically reserved to prevent the deletion of information about you for 90 days and give you time to engage a regulator or other legal representative in preparation of a lawsuit or to pursue legal remedies.
We respect your privacy and the preferences you share with us, and are here to help.
You and can exercise your privacy rights at any time by visiting our or by calling our privacy team toll-free. Visit “Verifying your identity in connection with your requests” in our Privacy Statement to learn about why we cannot facilitate your privacy requests solely via email. We have staff dedicated to address your privacy inquiries, questions, concerns, requests and preferences. Our Data Protection Officer is responsible for leading our privacy team and is supported by our business teams across the U.S., Europe and Asia. If you have any questions or concerns about the ways we process your information or how to control information about you, please let us know. We look forward to hearing from you.
Global Privacy
[email protected]
+1-800-541-5594
Attention: Data Protection Officer
1 Executive Drive, Suite 303
Chelmsford, MA 01824