Privacy Policy

Last updated: December 31, 2019

Shopper’s Voice is dedicated to ensuring that your information is managed responsibly with respect for your personal privacy. This Privacy Policy applies to the information we collect on our United States and Canadian Shopper’s Voice websites and through our electronic Consumer Product Survey. The Privacy Policy for the Television, Online Video & Internet Usage Research Study is available here.

Shopper’s Voice collects consumer opinions, shopping habits and other related information in order to:

  • Provide members with relevant information and offers
  • Help partner companies introduce new products and market existing ones
  • Send members other information about Shopper’s Voice

Please read the rest of our Privacy Policy for details on what information Shopper’s Voice collects, how we use and share it, and how to manage your membership.

For information on California Residents Consumer Privacy Rights provided by the California Consumer Privacy Act (CCPA), please see the Addendum for California Residents Consumer Privacy Rights.

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What information we collect

Contact information: Shopper’s Voice collects your contact information, such as name, complete postal address, and email address, in order for you to participate in Shopper’s Voice programs and sweepstakes events. For example, your name and postal address are required to receive product samples, valuable trial coupons, product information and other offers via postal mail. Your email address and complete postal address are required to receive email offers.

Survey Information: Shopper’s Voice conducts the Consumer Product Survey, which includes questions regarding your household’s product usage, brand preferences, shopping habits, hobbies & interests (such as reading and sports), health conditions, wellness products, as well as demographic information (such as number of people in household, age range, gender, and household income range). We ask three required questions (age range, gender, and income range) and the rest of the questions are optional. Your responses enable us and our partner companies to provide you with the most relevant offers for your household. Many of our partners create offers especially for people with certain interests and demographic characteristics.

Email Information: Through our email, Shopper’s Voice may collect information about whether our email was opened and the contents or content contained in the email were clicked on. We may place web beacons or pixel tags within our email messages to enable us to collect this information and determine whether to resend offers to you or send you other relevant offers via email. This information may also be used in combination with the information of other members in an aggregate and anonymous format to develop summary reports for Shopper’s Voice and our partner companies so we can enhance and improve our products and services.

Social Media Features: Our websites may include social media sharing features, giving you the option to post information about your activities on this website to your profile page to share with others on your social media network, and we may set a cookie to enable the feature to function properly. You may choose to log in to our website using social media sign-in services. These services will authenticate your identity and provide you with the option to share certain information with us such as your name and email address to pre-populate the signup form to participate in our surveys. The information collected via the social media sign-in feature will be subject to the terms of this Privacy Policy. All other social media features are governed by that social media company’s privacy policy.

Third Party Information: Shopper’s Voice and our partner companies may use additional information from other companies to help improve our products and services and to provide you with more relevant information and offers.

Online Activity: Shopper’s Voice may collect certain information about your online activity as explained below in more detail under Cookies and Online Activities.

Shopper’s Voice may also collect other information with your consent, or as permitted or required by law.

How we use and share information

By providing us with your contact information and/or survey responses, you consent to our collection, use and disclosure of such information for the purposes identified or described at the time of collection as described in the survey or as otherwise described in this Privacy Policy. Shopper’s Voice will not use your information except as described in this Policy in effect at the time of collection.

Product Offers: Our partner companies use your contact information and survey responses to provide our members with free product samples, valuable trial coupons, product information, research opportunities, discounts and other offers via email, postal mail, online advertising and, on occasion, by telephone. If at any time you no longer want to receive these offers, you can cancel your membership by following the instructions indicated below under Managing your Membership.

Email Offers: By providing your email, you may receive product offers based on your survey responses via email. These emails are sent by Shopper’s Voice, not our partner companies, and are clearly marked with our logo. If at any time you no longer want to receive email offers, you can unsubscribe by clicking the Unsubscribe link in the email received, or by following the instructions indicated below under Managing your Membership.

Partner Companies: By supplying your contact information and survey responses, you agree that we may share your information with our partner companies so they may provide you samples, information and offers that may be most relevant to you. We have contractual agreements with our partner companies to ensure that the information they receive from us is handled securely. However, our email messages may contain links to other sites not affiliated with Shopper’s Voice and may have privacy practices that differ from those of Shopper’s Voice. We encourage you to review the privacy policies of any third party site you may link to from our email messages.

Third Party Service Providers: We may transfer your personal information to our third party service providers to assist us with: providing you with our or our partner companies product offers; deploying email, postal, and online campaigns; data processing, data warehousing, data verification and supplementation; market research, fulfillment, and technical support. By providing your information, you agree to this transfer, storing and processing. Personal information held by Shopper’s Voice, its affiliates, agents and/or service providers may be located in and transferred to the United States, Canada, and India.

Our third party service providers are contractually required to protect members personal information and honor the commitments made in this Privacy Policy, subject to the laws of the jurisdiction in which the information is held. This may include lawful requirements to disclose personal information to government authorities in certain circumstances.

Legal Requests: We may also disclose any information about you as permitted or required by law, including to law enforcement, other government officials or other third parties as we, in our sole discretion, believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, or other activity that is illegal or may expose us to legal liability.

Merger or Consolidation: We may also disclose such information to third parties, as we believe necessary or appropriate, in connection with a proposed or actual merger, consolidation, financing, securitization, insuring, sale, assignment or other disposal of all or part of Shopper’s Voice or our business or assets, for the purposes of evaluating and/or performing the proposed or actual transaction, provided that such a third party agrees to honor the commitments made in this Privacy Policy.

Summary Reports & Analysis: Your survey responses, email activity, or online activity may be combined with information from other members to create aggregate and anonymous research reports that will not personally identify you. These reports help us enhance and improve our offers, products, and services, and those of our partner companies. We may use or provide these reports to third parties for analysis or other purposes.

Cookies and Online Activity

Shopper’s Voice, our third party service providers who assist with managing our website, and other third parties use cookies, web beacons and similar technologies on our websites for a variety of purposes. We collect, and allow other third parties to collect, information when you visit our website, including information on how you use our website, device information such as your computer’s IP address, the browser and operating system software you use, and other information to help us determine products and services that may be of interest to you.

Cookies Used by Shopper’s Voice on Our Website

Cookies are small text files your web browser receives from websites you visit that store data to make your browsing experience easier and faster. By using our websites, you agree that we can place cookies on your device.

Performance Cookies: These cookies collect information about how visitors use our websites for web analytics purposes, for instance, which pages visitors go to most often and error messages received. We use Google Analytics for web analytics. All information collected by these cookies is anonymous; they do not collect information that identifies a visitor. These cookies are only used to improve how our websites work and your experience on our websites.

Functionality Cookies: These cookies allow our websites to remember choices you make (such as remembering your user name and password, language preference or the region you are in) and provide enhanced, more personalized features. These cookies may also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have requested, such as keeping you logged in to your account as you browse the Internet. These cookies do not track your browsing activity on other websites.

Other Cookies: We may also use cookies to understand activity on our websites or websites you reach through our email. We use these cookies to help deliver relevant advertising to you while you visit other websites. See the section Online Targeted Advertising below for more information.

Modifying Your Browser Settings

You can modify your browser settings at any time, including setting your browser to notify you when you receive a cookie, giving you the choice to decide whether or not to accept it. If you reject cookies, you may still use our websites, but the functionality of some areas may be limited. We do not honor any “do not track" signals coming from browser settings, cookie signals, or other mechanisms that provide you the ability to exercise choice regarding the collection of information about your online activities over time and across third-party websites or online services.

Below are links to information on managing your cookie preferences with common browsers:

To learn more about Google Analytics, including how to opt-out, please visit:
https://tools.google.com/dlpage/gaoptout

For more information about cookies, please visit: http://www.aboutads.info/consumers#cookies.

For any questions related to our web technologies, please contact us via email at contactus@mail.ShoppersVoice.com.

Online Targeted Advertising

Shopper’s Voice works with partner companies and service providers to enable the delivery of relevant ads to consumers while protecting consumer privacy and offering choices about participating in such activities. This is called Online Targeted Advertising and is based on your site behavior (anonymous behavior such as pages visited), survey responses, perceived interests, and demographic information. Targeted advertising does not result in more ads, rather the ads you see may be more relevant to you.

Shopper’s Voice and our partner companies use cookies to help deliver relevant advertising to you. These cookies do not collect or store any personally identifiable information, they only store anonymous data, such as your site behavior, browser information and your perceived interests. Certain non-personally identifiable information may be collected and shared with these partners, including whether an ad was viewed and selected by the viewer.

We work with our partner companies to anonymously deliver ads based on your survey responses and your perceived interests. To do so, Shopper’s Voice works with our partner companies and service providers to place anonymous cookies on your browser and display online ads on websites you visit about goods and services that you will likely find of interest.

Shopper’s Voice or our service providers may place a web beacon within an email message that is sent from Shopper’s Voice on behalf of our partner companies. Once this email is opened, a cookie is placed on your browser and this cookie enables Shopper’s Voice or our partner companies to later display an ad on websites you visit.

Shopper’s Voice also assists our partner companies with retargeting, a method of re-engaging members with web display ads or emails who previously opened an email or visited our website.

Opting Out of Online Targeted Advertising

You may opt out of online targeted advertising from Shopper’s Voice and our partners by clicking on the Advertising Option Icon in the ads you receive. The Icon will appear as  and may be accompanied by text such as “AdChoices. It will be located around the perimeter of the ad. Simply click on this Icon and proceed to the opt-out link or preference setting link. Once directed to the opt-out page or preference setting page, you may immediately opt-out of future online targeted advertising from Shopper’s Voice and our partners. We may also use technologies, such as our own cookies, to provide you with personalized but anonymous online display advertising tailored to your interests. To opt out of our cookies used for this online advertising, click here.

To facilitate an opt-out, an opt-out cookie will automatically be placed on your device to block further targeted advertising. If you delete this opt-out cookie, clear your cookies, switch browsers or devices, or purchase a new device, your opt-out preference will not be maintained. You will need to opt-out again through the Icon in the ad. It is only when the opt-out cookie is present and can be read on your browser that we know you decided not to participate in targeted advertising.

Compliance with the Digital Advertising Alliance

Shopper’s Voice uses the Ghostery Assurance Platform to comply with the cross-industry Self-Regulatory Program for Online Behavioral Advertising as managed by the Digital Advertising Alliance. Shopper’s Voice supports deployment of the Advertising Option Icon, in partnership with Ghostery, to help consumers understand how their data is being used and provide choices to consumers that want more control.

Learn More

For information about the Advertising Option Icon, cookies and targeted advertising in general, please visit www.aboutads.info (United States) or youradchoices.ca/ (Canada) and www.iab.net/privacymatters.

To manage your online profile and your opt-out status, you may utilize the Digital Advertising Alliance tool at http://www.aboutads.info/consumers/ (United States), http://youradchoices.ca/understanding-online-advertising (Canada) or the Network Advertising Initiative opt-out tool at http://www.networkadvertising.org/understanding-online-advertising.

Choices and Managing Your Membership

Shopper’s Voice provides you with the opportunity to decide which programs you would like to participate in, so you have a choice as to what offers you receive.

Email Offers: You can stop receiving email offers at any time by following the “Unsubscribe" instructions on any email we send you, at managing your membership online, or by writing to us via email at contactus@mail.ShoppersVoice.com or via postal mail at the address indicated below under Contact Us.

Product Offers: You can let us know that you wish to stop receiving product offers from our partner companies by contacting us directly via email at contactus@mail.ShoppersVoice.com, via postal mail at the address indicated below under Contact Us or at managing your membership online. Please remember to include your name and complete address for verification purposes. Our partner companies are updated on a regular basis about members who no longer wish to receive offers.

Correcting/Updating Your Information: If you wish to access or correct your contact information, and you have provided Shopper’s Voice with your email address, you may update your name, email address, and password by logging in and updating your profile. For all other corrections and updates, please contact our Member Care Team by emailing contactus@mail.ShoppersVoice.com or writing to the address indicated below under Contact Us. For address corrections, please remember to include your name, old address and new address including city, state/province and postal code, to ensure accuracy.

Your right to access and correct your information is subject to applicable legal restrictions. We take reasonable steps to verify your identity before granting access or making corrections.

You may also withdraw your consent to our collection, use and disclosure of your contact information or survey responses at any time, subject to contractual and legal restrictions and reasonable notice. Please contact us via email at contactus@mail.ShoppersVoice.com or via postal mail at the address indicated below under Contact Us. Note that if you withdraw your consent to certain uses of your contact information or survey responses, we may no longer be able to provide some of our products or services.

If you are a California resident seeking to exercise your rights under the California Consumer Privacy Act (CCPA), please see the Addendum for California Residents Consumer Privacy Rights.

Security

We use reasonable business practices including physical, technical and administrative safeguards designed to protect your information against loss, misuse or alteration.

Shopper’s Voice is a licensed user of Entrust’s state-of-the-art encryption technology. We use Entrust’s services to securely transmit the data you provide to us on our registration form, survey pages, and login page. We also use this feature on our “Contact Us" page.

You can help safeguard your information by securely storing your login information and logging out of your browser at the end of each session.

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Terms & Conditions

Shopper’s Voice products and services are intended for residents of Canada and the United States that are over 18 years of age. To participate in the Tobacco Products category, a birth date is required to certify the respondent is at least 19 in Canada and 21 in the United States.

By registering with Shopper’s Voice, providing your contact information, providing answers on the Consumer Product Survey and/or using any of the services offered by Shopper’s Voice, you agree to abide by our Terms & Conditions and this Privacy Policy. View our Terms & Conditions or request a copy by writing us at the address indicated below under Contact Us.

Policy Modifications

Shopper’s Voice may change this Privacy Policy from time to time. If we identify new material purposes for the information already collected from you, we will seek your express consent prior to using the information for a new purpose. Any other changes to this Privacy Policy will be posted here and other places we deem appropriate so that you are aware of what changes have been made in how we collect, use and disclose your information. You should bookmark and periodically review this page to ensure that you are familiar with the most current version of this Policy. You can determine when this Policy was last revised by checking the “Last updated" legend at the top of this Policy. You may also request a copy of our Privacy Policy by writing us at the address indicated below under Contact Us.

Contact Us

For general questions regarding Shopper’s Voice or this Privacy Policy, please contact us:

By mail:

American Members:
Shopper’s Voice
Attention: Privacy Officer
P.O. Box 1478
Broomfield, CO 80038

 
For California Residents (please see Addendum for more information): 

You may submit requests using our online request form or by calling toll-free (888) 780-3869.
   

Canadian Members:
Shopper’s Voice
Attention: Privacy Officer
111 Gordon Baker Road, 3rd Floor
Toronto, Ontario M2H 3R1

By email: contactus@mail.ShoppersVoice.com

Shopper’s Voice is a trademark of ICOM Information & Communications L.P., owned by Epsilon Data Management, LLC.


ADDENDUM FOR CALIFORNIA RESIDENTS CONSUMER PRIVACY RIGHTS

Last Modified: December 31, 2019

NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] – CALIFORNIA CONSUMER PRIVACY PROTECTION ACT

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Policy applies if you are a natural person who is a resident of California (“California Consumer”) and uses our Services. This Addendum supplements the information in the Privacy Policy. However, this Addendum is intended solely for, and is applicable only as to, California Consumers: if you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it.

In the below tables and sections, we describe (as required by the CCPA):

1. Our Collection of Personal Information – the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from.

2. Our Business Purposes for Collecting and Using Personal Information – the types of recipients to whom we disclose or sell Personal Information.

3. How We Share Information with Third Parties – our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.

4. Your California Privacy Rights and Choices – what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.

The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information:

1. OUR COLLECTION OF PERSONAL INFORMATION

Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.

Categories of Information CollectedPurposes of Use
(see Section 2 below for additional information)
Sources of Personal Information

Commercial or transactions information e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

  • Data marketing services
  • Online targeting
  • Additional marketing services
  • Operate our Services
  • Surveys from Consumers/Self-Reported Data

Demographic and statistical information, including information regarding membership in protected classes or classifications e.g., information about a consumer’s race, color, age, medical condition (where self-reported), ancestry, national origin, religion, ethnicity, or marital status or gender

  • Data marketing services
  • Online targeting
  • Additional marketing services
  • Operate our Services
  • Surveys from Consumers/Self-Reported Data

Professional or employment-related information, e.g., occupation, business name or job title.

  • Data marketing services
  • Online targeting
  • Additional marketing services
  • Operate our Services
  • Surveys from Consumers/Self-Reported Data

Device information and other personal identifiers: e.g., name; alias; postal address; online identifiers; IP address; email address; or account name

  • Data marketing services
  • Online targeting
  • Additional marketing services
  • Operate our Services
  • Surveys from Consumers/Self-Reported Data

2. OUR BUSINESS PURPOSES FOR COLLECTING AND USING PERSONAL INFORMATION

The following chart provides additional information about our purposes for collecting and using your information – in effect, key aspects of our Services:

Purposes of Use

Data marketing services, for example:

  • providing marketing information to our Clients (which include companies, non-profit organizations, and political organizations), generally regarding their marketing, fundraising, customer service and engagement, and outreach activities.
  • helping our Clients identify and understand their customers better, by providing insights about them and managing loyalty programs.
  • assisting our Clients with use our Services to provide their customers and prospective customers with better service, improved offerings, and special promotions, for instance, advising on which consumers are most likely to be interested (or disinterested) in certain offers.

Online targeting, for example:

  • creating defined audience segments based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., households with prospective students). When we do this, we work with a data partner that “matches” our Information through de-identification techniques (such as through coded data “hashing”) with online cookies and other identifiers, in order to target and measure ad campaigns online across various display, mobile and other media channels. You may learn more about how to opt out of this and other online ad targeting in the section “Online Targeted Advertising” in the Shopper’s Voice Privacy Policy.

Additional marketing and database services, for example:

  • assisting in targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing.
  • measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases.
  • analyzing and optimizing our Clients’ (or their service providers’) proprietary databases or helping Clients to identify and mitigate potential fraud.
  • providing “verification” or data “hygiene” services, which is how companies update and/or “clean” their databases by either verifying or removing or correcting old, incorrect or outdated information.

Operate our Services, for example: 

  • improving, testing, updating and verifying our own database.
  • developing new products.
  • operating, analyzing, improving, and securing our Services.

3. HOW WE SHARE INFORMATION WITH THIRD PARTIES

We will share the information collected from and about you for the various business purposes described above, both with service providers and with third parties including our clients. The table below shows how and with whom we may share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months. Additional more general disclosure practices are also described below the table. In addition to the following, we may share the Information with any other party with your prior consent.

Categories of informationWhether We Sold This Information in the Last 12 MonthsThird Parties To Whom We May Disclose Personal Information

Commercial or transactions information, e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

Yes

  • Advertising/Marketing Companies
  • Advertising Networks
  • Internet Service Providers
  • Apparel & Accessory Companies
  • Automotive Companies
  • Business Service/Agencies
  • Business to Business Companies
  • Parenting Product Companies
  • Communication Services Companies
  • Consumer Packaged Goods Companies
  • Consumer Services Companies
  • Health and Wellness Product and Service Companies
  • Marketing Data Companies
  • Data Analytics Providers
  • Operating Systems and Platforms
  • Social Networks
  • Consumer Data Resellers
  • Educational Institutions & Companies
  • Electronics Companies
  • Energy and Utility Companies
  • Financial Services Companies
  • Food & Beverage Companies
  • Gift Product Companies
  • Lifestyle & Interest Product Companies
  • Manufacturing Companies
  • Not for Profit Organizations
  • Publishing Product Companies
  • Technology/Computer Software Companies
  • Telecommunications Companies
  • Travel, Leisure & Entertainment Companies
  • Affiliates not under the Epsilon brand
  • Public or Government Entities

Demographic and statistical information, including information regarding membership in protected classes or classifications, e.g., information about a consumer’s race, color, age, medical condition, ancestry, national origin, religion, ethnicity, or marital status or gender

Yes

  • Advertising/Marketing Companies
  • Advertising Networks
  • Internet Service Providers
  • Apparel & Accessory Companies
  • Automotive Companies
  • Business Service/Agencies
  • Business to Business Companies
  • Parenting Product Companies
  • Communication Services Companies
  • Consumer Packaged Goods Companies
  • Consumer Services Companies
  • Health and Wellness Product and Service Companies
  • Marketing Data Companies
  • Data Analytics Providers
  • Operating Systems and Platforms
  • Social Networks
  • Consumer Data Resellers
  • Educational Institutions & Companies
  • Electronics Companies
  • Energy and Utility Companies
  • Financial Services Companies
  • Food & Beverage Companies
  • Gift Product Companies
  • Lifestyle & Interest Product Companies
  • Manufacturing Companies
  • Not for Profit Organizations
  • Publishing Product Companies
  • Technology/Computer Software Companies
  • Telecommunications Companies
  • Travel, Leisure & Entertainment Companies
  • Affiliates not under the Epsilon brand
  • Public or Government Entities

Professional or employment-related information, e.g., occupation, business name or job title

Yes

  • Advertising/Marketing Companies
  • Advertising Networks
  • Internet Service Providers
  • Apparel & Accessory Companies
  • Automotive Companies
  • Business Service/Agencies
  • Business to Business Companies
  • Parenting Product Companies
  • Communication Services Companies
  • Consumer Packaged Goods Companies
  • Consumer Services Companies
  • Health and Wellness Product and Service Companies
  • Marketing Data Companies
  • Data Analytics Providers
  • Operating Systems and Platforms
  • Social Networks
  • Consumer Data Resellers
  • Educational Institutions & Companies
  • Electronics Companies
  • Energy and Utility Companies
  • Financial Services Companies
  • Food & Beverage Companies
  • Gift Product Companies
  • Lifestyle & Interest Product Companies
  • Manufacturing Companies
  • Not for Profit Organizations
  • Publishing Product Companies
  • Technology/Computer Software Companies
  • Telecommunications Companies
  • Travel, Leisure & Entertainment Companies
  • Affiliates not under the Epsilon brand
  • Public or Government Entities

Device information and other personal identifiers: e.g., name; alias; postal address; online identifiers; IP address; email address; account name

Yes

  • Advertising/Marketing Companies
  • Advertising Networks
  • Internet Service Providers
  • Apparel & Accessory Companies
  • Automotive Companies
  • Business Service/Agencies
  • Business to Business Companies
  • Parenting Product Companies
  • Communication Services Companies
  • Consumer Packaged Goods Companies
  • Consumer Services Companies
  • Health and Wellness Product and Service Companies
  • Marketing Data Companies
  • Data Analytics Providers
  • Operating Systems and Platforms
  • Social Networks
  • Consumer Data Resellers
  • Educational Institutions & Companies
  • Electronics Companies
  • Energy and Utility Companies
  • Financial Services Companies
  • Food & Beverage Companies
  • Gift Product Companies
  • Lifestyle & Interest Product Companies
  • Manufacturing Companies
  • Not for Profit Organizations
  • Publishing Product Companies
  • Technology/Computer Software Companies
  • Telecommunications Companies
  • Travel, Leisure & Entertainment Companies
  • Affiliates not under the Epsilon brand
  • Public or Government Entities

We also may share any of the personal information we collect as follows:

Sharing for Legal Purposes: In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our clients, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.

Sharing in Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.

Sharing With Service Providers: We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.

Aggregate and Deidentified Information: We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

4. YOUR CALIFORNIA RIGHTS AND CHOICES

Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from them, to request deletion of that information, and to opt-out of the sale of their personal information, subject to certain restrictions. California residents also have the right to designate an agent to exercise these rights on their behalf. This section describes how to exercise those rights and our process for handling those requests, to the extent we act as a “business” (as opposed to a “service provider”) for purposes of handling personal information. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.) Sometimes, we act only as a “service provider” to our clients (for instance, if they provide information to us for analytics, processing or other data management services), in which case any consumer requests for access, deletion or opt out must be made through that client. We will forward any such requests to a named client, as feasible.

  1. Right to Opt-out of the Sale of Personal Information

    California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” – including in the definition making available a wide variety of information in exchange for “valuable consideration.” We may act as a “business” or a “service provider” under the CCPA. When we act as a business under the CCPA, a California resident may “opt out” of our “sale” of their personal information (as those terms are defined by the CCPA) by submitting their request using our online request form or by calling toll-free (888) 780-3869.

    Please note that this is not an opt out of interest-based advertising. To opt out of interest-based advertising, please visit the Network Advertising Initiative’s pages explaining and permitting that type of industry “opt out.”

  2. Right to Request Deletion of Personal Information

    A California resident may also request that we delete certain personal information we have collected from them (if any). (Note that this is different from their right to “opt out” of us selling their personal information, which is described above; where we do not collect personal information directly from consumers, “deletion” rights generally do not apply.) However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to a consumer’s relationship with us, or to comply with legal obligations, and (g) as necessary to comply with client contracts, including allowing advertisers to properly compensate publishers for driving traffic to their web properties. California residents can request deletion of their personal information by submitting their request using our online request form or by calling toll-free (888) 780-3869.

  3. Right to Request Access to Personal Information

    California residents also have the right to request that we disclose what categories of their personal information we collect, use, or sell. As a California resident, they may request access to the specific pieces of personal information that we have collected from them. California residents can access their personal information by submitting their request using our online request form or by calling toll-free (888) 780-3869.

    However, we may withhold some personal information where the risk to the consumer or our business is too great to disclose the information, or where we cannot verify the identity of the requester in relation to such personal information. Thus, for security purposes (and as required under California law), we will verify identity – in part by requesting certain information from the requester — when they request to exercise certain California privacy rights.

    Once we’ve received a completed request form, we will attempt to verify identity with a series of test questions. Then, we will either email the consumer access report to the email address provided on the form, delete the information, or opt out the requester out of sales. The information provided will be used solely to process requests and shared only with a service provider that assists Epsilon with identity verification.

    In addition, please read our privacy policy to learn more about:

    • The categories of personal information that we have collected about you.
    • The categories of personal information that we have sold.

    If we are unable to complete your requests, we will provide requesters with additional information about the reasons that we could not comply with the request.

  4. Right to nondiscrimination.

    We do not deny, charge different prices for, or provide a different level of quality of goods or services if a California resident chooses to exercise these rights.

  5. Information About Persons Under 16 Years of Age

    We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).

  6. Authorized Agents

    California residents may also designate an agent to make requests to exercise their rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that the designated agent has been authorized to make a request on behalf of the California resident. We will request a signed written authorization or a copy of a power of attorney.