Data Privacy

What Data We Collect and How We Use It

What we do is complex, and it has an impact on consumer privacy. We would like to take a moment to explain how we protect your privacy. We don’t release information to third parties concerning specific items that a consumer has purchased, what magazines they read, or what charities they support unless requested by the organization with whom the consumer has the relationship, or if required by law. We also don’t knowingly collect information historically considered to be highly sensitive in the United States such as credit card or bank account numbers, Social Security numbers or other government-issued identifiers or HIPAA data or other information specifying a consumer’s medical conditions. We don’t work with clients whose offer or business we consider pornographic, fraudulent or harmful to families.

Instead, we match our clients’ customer information to a specific consumer by comparing name, address, email address or other identifiers. We are able to then associate a consumer or a de-identified consumer profile with other data, including demographic data, social media informed data, geographic data, transaction data and transaction-based insights, and other interest-based data. We then analyze the data we have about consumers using statistical models designed to predict consumer interest in specific offers from particular businesses and non-profit causes or in categories of product, service or cause. Our models predict not only who might be interested in our clients’ offers but which consumers are likely to have little or no interest in them. This can help improve our clients’ marketing decisions, which helps reduce the amount of irrelevant advertising consumers see and saves our clients’ money.

We do not accept or generate information specifying individuals’ health conditions (such as protected health information, aka “HIPAA data”) and do not seek to predict that any person has a particular health condition. We do serve clients that sell health-related products, which can range from non-prescription items such as maternity apparel, vitamins and supplements to prescription drugs. In all cases, our predictions are designed to identify those with likely interest in a product or service, and not a specific medical condition. In other words, we predict whether a person may be interested in buying these types of products, but we do it without individual health information and do not predict that a person has a particular health condition on behalf of our clients or partners. In these cases, our predictive technology would seek to identify interest in the product, which might include consumers with a particular health condition and also consumers without the health condition. For example, for retailers selling maternity apparel, our predictive models seek to predict interest in that type of apparel, which will likely include those who are expectant parents (which we would not know), but also those who are not expectant parents (which we also would not know) but are likely to buy for other reasons, for example as a gift for others. In every case we strive to identify and follow industry best practices around consumer privacy and ethical use of data when making these predictions.

Please note, our marketing products and services are designed only for use in marketing to United States consumers above the age of 18. We do not knowingly collect information about consumers residing in other locations (such as Europe) or about children.

Once we complete our analysis, we provide our clients with the results in a format designed for the marketing methods through which they plan to contact consumers. For example, when clients use our products to send direct mail or to better understand likely interests of their customers, we typically provide our clients information related to names and postal addresses or other individually identifying information. When our clients ask for help to connect with potentially interested consumers through digital channels, such as online or mobile advertising, we would typically provide our products in de-identified form using industry standard privacy practices. In these cases, we, or our client, or partner will combine the results of our analyses with digital identifiers in the applicable digital channel (such as with cookie IDs for web advertising, device IDs for mobile advertising or email addresses for email advertising).

How We Protect Consumer Data

We work with a lot of consumer data, so you may be interested in how we protect it. We have implemented physical, technical and administrative measures to safeguard the security of all of the consumer information in our custody. We align our security with the NIST-800-53 privacy and security controls published by the National Institute of Standards and Technology and engage an external security audit firm to test our security against these standards annually.

Categories of Personal Information Collected and Shared in the Past 12 Months

Please see the table referenced at the bottom of this page for a list of the following with respect to the categories of personal information that we have collected in the past 12 months for use in our marketing products and services:

the categories and descriptions of personal information collected,
categories of sources from which the information was collected,
the business or commercial purposes for which the information was collected,
the categories of third parties to whom personal information was sold or disclosed for a business purpose.

Your Privacy Choices and Your California Privacy Rights

We believe in honoring individuals’ choices regarding use of their personal information. We are consumers too, and we care deeply about our own privacy and about how our company is perceived. We believe that almost everyone wants to receive offers that are relevant and valuable to them, but that individuals also may want the choice not to receive individualized advertising. We adhere to self-regulatory programs like the DAA and the DMA division of the ANA; in which they require that businesses recognize and honor consumer choice. Accordingly, we offer you three potential privacy choices: you may request to opt out of our marketing products and services, you may request that we delete personal information about you, and you may request access to personal information we use for our marketing products and services that we have about you. This section describes more about your privacy choices and how you may submit these requests.

For consumers in some states (such as California), these choices are legal rights under applicable law, and these rights are described in more detail below.

Pursuant to California Civil Code Section 1798.83, we do not disclose information of consumers from whom we directly collect data to third parties for the third parties’ direct marketing purposes if the consumer has opted out, and we provide a cost-free means for consumers to opt out of any such sharing through this page.

Opt-Out Requests

“Opt out” is a frequently used term, but what it means and how it is implemented may differ between states and across companies. In some states, such as California, it is legal right for residents of that state referred to as the “sale opt-out” or “do not share” or “do not sell” right. At its core, however, to opt out is to make a choice about how companies use and share your personal information. And we listen and seek to respect your opt-out choice.

The industry-standard opt-out for online behavioral advertising is an excellent way to make your choice in the context of online behavioral advertising. When you use one of these opt-out tools—and there are links to them below under Other Privacy Choices And Opt-Out Solutions—a cookie is placed on your browser that signifies your choice. Respectable companies that serve display ads check for the presence of that cookie before determining whether they are allowed to serve a targeted ad on the browser. If they are not allowed to use interest-based advertising, they will instead display a random or generic ad. Respectable companies that play some role in online advertising, other than serving ads, partner with respectable ad serving companies to honor consumer choice. We work with respectable ad serving companies.

A cookie has its limitations. Cookies are temporary, browser-specific, and device-specific. If you clear your cookies, if your anti-virus software clears your cookies, if your browser is set not to accept third-party cookies, if you use a second browser, if you use a different device to view the Web, then the opt-out cookie will not reliably stop you from seeing interest-based advertising. As improved tools are developed to be more comprehensive, we will evaluate them and expect the industry groups to which we belong will implement updated standards and tools.

The DMA division of the ANA maintains consumer opt-out solutions for direct mail and email offers, found at www.DMAChoice.org. We regularly update our records with information from these sources and seek to honor the consumers’ choices when creating our marketing products and services.

In addition to respecting the above industry opt-out solutions, you may opt out directly with us, as described below.

It is important to recognize what these marketing opt-out options will not do. They do not preclude a particular company or organization that you have dealt with in the past from sending you their marketing offers, including those that are combined or associated with a digital identifier you use. This works well for most people, because they have a voluntary, mutually-beneficial relationship with those companies that they have dealt with previously. Those who prefer not to receive offers from a particular company need to contact the company directly and ask that they not receive any future marketing materials from them.

In addition to marketing opt-out options, we also extend two additional privacy choices to consumers about how we use, share and retain their information. In some states, such as California, these may be referred to as the “deletion right” and the “access right” or “right to know.”

Deletion Requests

You have a right to request that we delete your personal information that we have collected. In some states, such as California, this is a legal right for residents of that state. If we deny a deletion request because we cannot sufficiently verify your identity (see below on how and why we verify the identity of those submitting privacy choices), then we will, if possible, treat the deletion request as an opt-out. We may retain limited pieces of personal information after a verified deletion request is received in several circumstances. We treat all deletion requests as opt-out requests as well. We will retain your contact information such as name, postal address or email address following a verified deletion request solely in order to ensure that we do not re-insert your information into our systems or otherwise for use in our marketing products and services if we receive your personal information from another source in the future. This allows us to fulfill our legal obligation to you. We may retain your personal information if required to deliver a service to you that you request from us. We may also retain your personal information if required or permitted by law or legal proceedings (for example if required by a legal subpoena we have received or to prevent or detect fraud).

Access Requests

You have a right to request that Accelerist disclose (1) the categories of personal information Accelerist’s data provider collects, discloses and sells within the twelve months preceding your verified request, (2) the categories of party from whom your personal information was collected during that time period, (3) the categories of party to whom the information was disclosed for a business purpose or shared/sold during that period and (4) the business purposes for which your personal information was collected or disclosed. You also have the right to request that Accelerist’s data provider disclose the specific pieces of your personal information Accelerist’s data provider has collected within the twelve months preceding your verified request. In some states, such as California, this is a legal right for residents of the state, which may be referred to as the “right to know,” “disclosure right” or “access right.”

How to Submit Your Privacy Choices

We offer a solution to storing your privacy choices. To submit your opt-out, deletion or access request, select the hyperlink below that corresponds to the request you are making and the person whose privacy choice is being made. Our privacy choices hyperlinks listed below, link to web forms that contain instructions detailing the information we will need to verify your identity, depending on the type of privacy choice you are making and whether you are the individual for whom the privacy choice is being made. In some cases family members or authorized third parties may submit privacy choices for an individual, and in some states, such as California, this is a legal right.

Alternatively, you can call, toll-free, 1-833-794-5263, to submit privacy choices by telephone.

Identity Verification Process.

In order to protect consumer privacy, we conduct an identity verification process to seek to properly verify the identity of parties who submit privacy choices to us. We want to simultaneously respect individuals’ privacy choices while seeking to avoid someone fraudulently submitting a privacy choice or unauthorized parties obtaining your personal information. The particular verification we require for a request depends on our assessment of the risk of what is being requested. The chart below describes the verification we use for particular requests based on who is submitting the request and what is being requested, and instructions in each of our privacy choices web forms listed above give specific details on what must be submitted and how to submit it.

A – Submit accurate contact information (name, postal address, email, telephone number, etc.) for the individual (if you are the individual submitting your own privacy choice, this is your information).

B – Submit Accelerist’s data provider’s permission form for authorized agents, signed by the individual and by you. Both signatures must be notarized. If you are a company or other legal entity, submit official documents from the state where the individual resides showing your registration in the state. You may download a copy of this form, by clicking here.

C – Submit Accelerist’s data provider’s identity verification form for individuals submitting their own privacy choice. Your signature must be notarized. You may download a copy of this form, by clicking here.

D – Submit Accelerist’s data provider’s permission form for family members, signed by the individual and by you. Both signatures must be notarized. You may download a copy of this form, by clicking here.

E – Submit your official signed power of attorney pursuant to California Probate Code Sections 4000 to 4465.

Authorized Agent

You may designate an authorized agent to make opt-out, deletion, and access requests on your behalf. Additional documentation is required for this type of submission, as described above.

Other Privacy Choices and Opt-Out Solutions

It is important to point out that the privacy choices described above apply specifically to Accelerist’s data provider and the personal information that Accelerist’s data provider collects about you. We do not control the privacy practices and marketing of other companies, therefore if you would like for your privacy choices to apply to other organizations or to their data that we may hold as their service provider, then you will need to reach out directly to the other organizations and submit your requests.

If you opt-out of marketing with us, you will likely continue to get interest-based advertising offers originated by others. To dramatically decrease interest-based advertising contacts you should not only opt-out with us but also through other services. Some of the major opt-out services are: