PATH2RESPONSE Cooperative Marketing
Data Use Guidelines
Path2Response maintains a cooperative database where members contribute data about their customers, in exchange for data about other consumers that may be interested in their products. 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 transactional data. Path2Response is considered a processor.
Members of the Path2Response cooperative contribute client data 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.
In addition to data contributed by Path2Response cooperative members, Path2Response also maintains and processes public information provided by third parties. We receive this information from business partners who provide it to us to enhance the data we maintain. We encourage all Path2Response cooperative members to notify consumers when personal information is collected, and that it will be shared. We do not knowingly collect or receive data from minors.
We may provide the data we have collected and received to third parties and we may work with other businesses to bring selected opportunities to our clients. We may also employ other companies and individuals to perform certain business related functions on our behalf. Examples includes formatting or updating addresses, analyzing data, and providing marketing analysis. The agents performing these functions on our behalf have access to the Data as needed to perform their functions for us, we do not permit them to use the data for other purposes.
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:
- comply with all applicable laws, rules, regulations or similar enactments, and industry standards related to the data we house;
- require storage of client data in a physically and technologically secure environment that protects it from unauthorized access, modification, use, disclosure, appropriation and destruction;
- restrict access to those persons who have a “need to know” for purposes of providing services; and take into account the nature of client data and commensurate risks associated with handling such data.
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.
Path2Response collects, processes, and aggregates data in compliance with all applicable industry standards, best practices and self-regulation. However, we respect and honor your right to privacy, so you can choose to opt-out of Path2Response’s master database. We honor requests made directly by consumers to remove their names from our database. We do not honor 3rd party requests from commercial organizations to remove consumers from our database.
If you wish to have your information removed from Path2Response cooperative marketing, please fill out the form with your full name, your current address and previous address if you have been at your current address less than 6 months. You can also write us and submit your request to: Path2Response, Attn: Data Operations Department, 1805 Highway 42, Second Floor, Louisville, CO 80027. Please include your full name, your current address and previous address if you have been at your current address fewer than six months. Path2Response cooperative members will not receive your individual record of information for their marketing purposes.
Not all multi-channel marketers are members of the Path2Response cooperative, so we comply with the Direct Marketing Association’s Mail List Preference Service. Clients are responsible for ensuring overall compliance with their own privacy statements. You can opt-out of other mailing lists through this service. If you want your information removed from other mailing lists, please visit DMAChoice.thdma.org to learn more.