Privacy and
Security Standards

Path2Response ensures that any client data that comes into its possession or control, or the possession or control of any Path2Response personnel, is protected at all times in a manner that is consistent with industry data security practices applicable to such data. Protection from corruption and from unauthorized access and interference are in effect while such client data is within the possession and control of Path2Response and while it is in transit across a network between Path2Response’s servers and any other location.
Path2Response maintains all client information in strict confidence. Path2Response makes all client data available only to its employees and contractors who have a need to access the client information in order to perform activities related to the data cooperative solution. We do not disclose, transmit, or make available specific client data to third parties (including subcontractors), unless such disclosure, transmission, or making available has been explicitly authorized by client, in writing.

DEFINITIONS

The following are terms used by Path2Response and occur in this document when discussing our privacy and security standards:

Personally Identifiable Information

Personally Identifiable information (PII) is any data that could potentially identify a specific individual. Any information that can be used to distinguish one person from another and can be used for de-anonymizing anonymous data can be considered Personally Identifiable Information Examples of Personally Identifiable Information include:

Sensitive Personal Information

Sensitive Personal Information (SPI) is a subset of Personally Identifiable Information, which due to its nature has been classified by law or by Path2Response policy as deserving additional privacy and security protections. Examples of Sensitive Personal Information include: Government issued identification numbers (Social Security numbers, driver’s license numbers, and passport numbers); Financial account numbers (credit card numbers, bank account numbers, and other information if it would permit access to a financial account); and Credential information (account name, passwords, or encryption keys).

Client Data

Client Data is information provided to Path2Response by a client that contains personal identifying information of the client’s (including affiliated brands and titles) customers. This information typically includes, but is not limited to, customer ID, name, address, email address, and transaction data. Client Data is provided in order for Path2Response to perform certain services requested by client and other data cooperative members, which may include, without limitation, collecting, recording, storing, organizing, matching, aggregating, analyzing, transferring, disclosing, manipulating, combining, and/or deleting such data.

Security

At Path2Response, we consider the security of our clients’ data to be of the utmost importance and work diligently to protect it.
Path2Response has adopted, implemented, and maintains security procedures and practices to prevent the unauthorized and accidental access to, modification, use, disclosure, appropriation, and destruction of our clients’ data. We have procedures and practices in place that:
Path2Response’s security encompasses physical, administrative, and technical measures designed to protect sensitive client data, including consumer information. Path2Response’s hosting environments and security measures are continuously reviewed and assessed; routinely performing internal security audits encompassing hardware, system software, and procedures/policies. Our role-based security and configuration release mechanisms ensure proper governance of system configuration, so all our clients’ data is constantly protected. Additionally, our layered security ensures that client data is highly secure and protected as it passes through the solution. Path2Response ensures that all physical, network, application, network, and employee security are in place to continually protect client assets in our internal and external systems.

Physical Security

Path2Response is a remote-first company, with no central servers or permanent physical facilities. Our entire enterprise is cloud-based, utilizing state-of-the-art, secure and compliant infrastructure. We utilize a Managed Services Provider known as Syn Ack Fin to manage our operations. Syn Ack Fin is SOC2 certified and its most recent report is available for review.

Encrypted Transfer

Client data is always encrypted when transmitted across Path2Response networks to protect against eavesdropping of network traffic by unauthorized users. Even in cases where source and target endpoint devices are within the same protected subnet, client data transmission is still encrypted due to the potential for high negative impact of a client data breach. The types of transmission may include client-to-server, server to-server communication, as well as any data transfer between core systems and third party systems. Client data transferred via HTTP is always transferred via HTTPS; this includes REST API interfaces. File transfer of data from a client to Path2Response may also occur via HTTPS; however, it is recommended that all clients transfer files to Path2Response via SFTP.

Firewalls

Path2Response uses several layers of firewalls to ensure the security of their systems and the data contained within these systems. Client data is processed within dedicated hosted systems not accessible by the public Internet. These systems are protected with software firewalls with extremely limited port access; allowing only absolutely required ports to be opened. Surrounding these systems are hardware firewalls that limit access via SSL/IPSec tunneling between the hosted servers and only the Path2Response office.

Access Control

Access to client data is extremely limited; only Path2Response personnel with specific needs for access to client data are granted access to data, through a secure and restricted mechanism. Access to client data is only available using secure private key files, utilizing secure tunnels between the Path2Response office and the servers containing the client data.

Backups

Path2Response has established rigorous procedures for data recovery. These procedures are tested and validated constantly to ensure no loss of data in the event of a system failure. Data is backed up in encrypted form and stored in an off-site facility. Depending upon the criticality, durability, and transience of the data, backups occur upon receipt/creation or daily.

Privacy

Path2Response collects, processes, and aggregates data in compliance with all applicable industry standards, best practices and self-regulation. Specifically, we comply with standards put forth by the Direct Marketing Association. Clients are responsible for ensuring overall compliance with their own privacy statements.

Sanitization

All data within the Path2Response systems are sanitized for the specific step in the process. Generally, data is anonymized and personally unidentifiable; only attaching name and address at fulfillment.

Notification

If any client data is sent to Path2Response with Sensitive Personal Information (SPI), the file is rejected; the file is immediately destroyed, the client is notified, and Path2Response’s senior management is notified.

Business Continuity/Disaster Recovery

Path2Response maintains a business continuity and disaster recovery plan outlining the prerequisites to be managed and the steps to be taken in the case of an event that disrupts business operations. This plan includes protection of assets and data as outlined above as well as the steps to recover and ensure continued operational capacity.

Software Development Process

Path2Response utilizes a dynamic development process that allows the flexibility to adapt to business and customer needs quickly. The software development approach enabled at Path2Response is agile in nature, utilizing a variety of methodologies based on iterative development. These methodologies include engineering best practices intended to allow for rapid delivery of high-quality software, a business approach that aligns development priorities with customer needs and company goals and frequent inspection and adaption of priorities and request backlog.

Data Retention

Per our published Privacy Policy, we retain data for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

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