Path2Response Privacy Policy

Consumer Privacy Information

Last Updated: January 4, 2023

Path2Response LLC and our subsidiaries and affiliates (collectively, “Path2Response,” “us,” “we,” or “our”) is committed to protecting consumer privacy. This Path2Response Privacy Policy (“Privacy Policy”) describes how we collect, use, and share personal information in connection with: (1) our data marketing products and services (collectively, the “Data Services”); and (2) our website located at www.path2response.com and any other digital properties we own and operate that link to this Privacy Policy (collectively, the “Website”), our social media pages, our email, phone, and other communications, and our business operations. This Privacy Policy also provides information about how to exercise your rights and the choices you have with respect to your personal information.

Collection of Personal Information in Connection with the Data Services

In order to provide the Data Services, Path2Response collects and stores consumer personal information in its databases related to household purchases, demographics, and interests. The table below provides more detail regarding the categories of personal information we collect in connection with the Data Services, and have collected in the 12 months before the “Last Updated” date of this Privacy Policy:

Category of Personal Information

Description (specific data may include the following)

Identifiers

Name and Address

Hashed Email Addresses

Commercial or Transactions Information

Product category or services purchased 

Purchasing or donation histories or tendencies 

Records of personal property

Demographic Information

Age, Gender, Marital Status

Inferences about buying preferences or characteristics

Wealth Rating, Median Income, Inferred Credit Ranges

Internet or Network Activity Information

Browsing History

Online Activity Data (such as time on site, # pages visited, referring URL)

Device Data (such as IP address, computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, unique online identifiers, and general location information such as city, state, or geographic area)

We collect the categories of personal information described above from various sources. It is Path2Response’s business to help companies reach consumers who are interested in their products or services. To do that, we maintain a cooperative database where members (mostly catalog, retail, and Not for Profit organizations) contribute information about their customers. These companies commit to abiding by all applicable laws, regulations, and industry guidelines. Specifically, the following types of companies may be sources of the personal information described above:

  • Apparel & Accessory Companies
  • Automotive Companies
  • Business to Business Companies
  • Parenting Product Companies
  • Consumer Packaged Goods Companies
  • Inquiries About Products or Services
  • Consumer Survey Companies
  • Data Compiling Companies
  • Health and Wellness Product and Service Companies
  • Electronics Companies
  • Financial Services Companies
  • Food & Beverage Companies
  • Gift Product Companies
  • Lifestyle & Interest Product Companies
  • Not for Profit Organizations
  • Publishing Product Companies
  • Telecommunications Companies
  • Travel, Leisure & Entertainment Companies

In this Privacy Policy, we refer to this list collectively as “Data Services Clients.”

We also collect personal information from other third parties, such as public data sources (including census data, telephone directories, and real property recorder or assessor information), data licensors, or other information providers. For example, we may collect personal information from companies that provide us with information about your online activity on other sites and online services or search activity.

In addition, we and our third-party service providers may automatically collect the hashed email addresses and Internet or Network Activity Information described above on our customer’s websites and across other sites and online services. To do this, we use cookies and similar technologies. For more information about cookies, please see the section below titled “Cookies and Similar Technologies.”

Use of Personal Information in Connection with the Data Services

We may collect and use consumer personal information for the following purposes and as otherwise described in this Privacy Policy:

  • To Provide the Data Services. We use consumer personal information to provide the Data Services to our clients. We provide three main categories of services: (i) Analytic Services, (ii) Linkage Services, and (iii) Marketing and Advertising Services. These activities may include maintaining the personal information categories described above in our cooperative database and filtering this information into categories to help our clients narrow your preferences and interests. For example, if you purchase women’s clothing, your household will likely be in the category of women’s apparel and merchandise, and you may receive catalogs for women’s clothing in the mail. We may also use personal information and share it with our clients so that they can correct or update the personal information they have separately collected about you. 
  • For Research and Development. We use your personal information for research and development purposes, including to study and improve the Data Services and our business, understand and analyze the usage trends and preferences of our clients, and develop new features, functionality, products, and services. As part of these activities, we may create aggregated, de-identified, or other anonymized data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.
  • For Compliance and Protection. We may use your personal information to: (i) comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; (ii) maintain the safety, security, and integrity of our Data Services, business, databases, and other technology assets; (iii) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (iv) audit our internal processes for compliance with legal and contractual requirements and internal policies; (v) enforce the terms and conditions that govern the Data Services; and (vi) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
Disclosures of Personal Information in Connection with the Data Services

Sharing, Sales, and Disclosures for Targeted Advertising Purposes

As noted, Path2Response maintains a cooperative database where Data Services Clients contribute data about their customers in exchange for data about other consumers that may be interested in their products. We enhance that data with other data for analytics and marketing purposes as well as advertising services, then share it with third parties for purposes of marketing, advertising, and analytics services. Under some privacy laws, this type of sharing may be called “sharing,” “selling,” or disclosing for purposes of “targeted advertising.”

We share, and in the 12 months before the “Last Updated” date of this Privacy Policy, have shared in this manner the following categories of personal information with our Data Services Clients and with Advertising and Analytics Companies (including Advertising Networks, Advertising/Marketing Companies, Data Analytics Providers, Social Networks, Consumer Services Companies, Marketing Data Companies, and Consumer Data Resellers): 

  • Identifiers
  • Commercial or Transactions Information
  • Internet or Network Activity Information

For example, names and addresses are provided to the Data Services Clients for the purposes of bringing you offers of interest including catalogs, direct mail, and online advertising. We may also provide your name, address, and aggregated transaction information to Advertising and Analytics Companies who provide marketing, advertising, and analytics services.

Other Disclosures of Personal Information

In addition, we may disclose each of the categories of personal information described above with the following categories of third parties:

  • Service Providers. We may also provide the personal information we have collected and received to service providers who perform certain business-related functions on our behalf. Examples include formatting or updating addresses, analyzing data, and providing marketing analysis. The agents performing these functions on our behalf have access to the personal information as needed to perform their functions for us. We do not permit them to use the data for other purposes.
  • Related Companies. Where applicable, we may share personal information with our affiliates, subsidiaries, and other related companies.
  • Business Transaction Participants. If we sell all or part of our business or make a sale or transfer of assets or are otherwise involved in a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Path2Response or our affiliates (including, in connection with a bankruptcy or similar proceedings), we may transfer your personal information to a third party as part of that transaction (or potential transaction), including at the negotiation stage.
  • Authorities and Others. We may share your personal information with law enforcement, government authorities, and private parties, as we believe, in good faith, to be necessary or appropriate to comply with a law, to exercise a right or privilege, or for the other purposes described in the “Compliance and Protection” section above.
  • Professional Advisors. We may share personal information with our professional advisors, such as lawyers, bankers, consultants, auditors, and insurers, such as when disclosing personal information is necessary in the course of the professional services that they render to us.

Each of the categories of personal information described in the section titled Collection of Personal Information in Connection with the Data Services may have been disclosed to these third parties, as well as to the Data Services Clients and Advertising and Analytics Companies, for business purposes in the 12 months preceding the “Last Updated” date of this Privacy Policy. 

Website and Business Operations Privacy Information

Collection of Personal Information in Connection with Our Website and Business Operations

Path2Response also collects personal information in connection with our Website, social media pages, customer communications, and other business operations. The table below provides more detail regarding the categories personal information we collect in connection with the Website and our business operations, and have collected in the 12 months before the “Last Updated” date of this Privacy Policy:

Category of Personal Information

Description (specific data may include the following)

Identifiers

Name, email address, phone number, business mailing address, and social media handle.

Commercial or Transactions Information

Transaction history, such as records of products and services that you have purchased from us, payment amounts, payment methods, and other information about your orders.

Preferences, such as your preferences for receiving marketing and other communications from us.

Communications, such as the questions, inquiries, and requests that you send to us.

Survey responses, such as the responses that you provide to our surveys and questionnaires.

Internet or Network Activity Information

Browsing History

Online Activity Data (such as time on site, # pages visited, referring URL)

Device Data (such as IP address, computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, unique online identifiers, and general location information such as city, state, or geographic area)

Audio, Electronic, Visual, or Similar Information

Customer service call recordings, which may be recorded to help us facilitate your inquiries or for quality and training purposes.

We may collect the personal information categories described above directly from you when you provide it to us, such as when you contact us with questions regarding our business, the Website, or our Data Services, sign up to receive emails from us, or respond to one of our surveys. 

When you visit our Website, we will also collect information automatically regarding your use of the webpage, including the Internet or Network Activity Information described above. The Website uses cookies and similar technologies to collect some of this information. For more information, please see the section below titled “Cookies and Similar Technologies.”

We may also collect personal information from third parties, such as our clients, public sources (such as social media platforms), and our business partners (such as marketing partners).

Use of Personal Information in Connection with our Website and Business Operations

We may collect and use personal information about you in connection with the Website and our business operations for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

  • Service Delivery and Business Operations. We use personal information to deliver the Website and our services and to operate our business, such as:
    • To provide you with the content, information, products, and services you have requested
    • To personalize your experience on our Website and our communications with you
    • To process your transactions and monitor your orders
    • To communicate with you about the Website and our business (including by sending announcements, updates, security alerts, and support and administrative messages)
    • To respond to your inquiries and requests for customer support
  • Marketing and Advertising. We and our service providers may collect and use personal information to provide you with Path2Response-related or other direct marketing communications. You may opt-out of direct marketing as described in the “Your Choices” section below.
  • Research and Development. We use personal information to measure and understand the way you use our Website and for other research and development purposes, including to study and improve our products, services, and business, understand and analyze the usage trends and preferences of our clients, and develop new features, functionality, products, and services. As part of these activities, we may create aggregated, de-identified, or other anonymized data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.
  • Compliance and Protection. We may use your personal information to: (i) comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; (ii) maintain the safety, security, and integrity of our products, services, business, databases, and other technology assets; (iii) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (iv) audit our internal processes for compliance with legal and contractual requirements and internal policies; (v) enforce the terms and conditions that govern the Website and our other products and services; and (vi) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

In addition, in some cases we may specifically ask you for your consent to collect, use, or share your personal information.

Disclosures of Personal Information in Connection with the Data Services

We may share personal information collected about you with certain third parties, including the parties listed below and as otherwise described in this Privacy Policy or at the time of collection:

  • Service Providers. Companies and individuals that perform services on our behalf or help us operate the Website or our business. Among other things, service providers may help us perform website hosting, maintenance services, database management, web analytics, billing, payment processing, fraud protection, customer service, or marketing.
  • Related Companies. Our affiliates, subsidiaries, and other related companies.
  • Business Transaction Participants. If we sell all or part of our business or make a sale or transfer of assets or are otherwise involved in a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Path2Response or our affiliates (including, in connection with a bankruptcy or similar proceedings), we may transfer your personal information to a third party as part of that transaction (or potential transaction), including at the negotiation stage.
  • Authorities and Others. We may share your personal information with law enforcement, government authorities, and private parties, as we believe, in good faith, to be necessary or appropriate to comply with a law, to exercise a right or privilege, or for the other purposes described in the “Compliance and Protection” section above.
  • Professional Advisors. We may share personal information with our professional advisors, such as lawyers, bankers, consultants, auditors, and insurers, such as when disclosing personal information is necessary in the course of the professional services that they render to us.

Each of the categories of personal information described in the section titled Collection of Personal Information in Connection with our Website and Business Operations may have been disclosed to these third parties for business purposes in the 12 months preceding the “Last Updated” date of this Privacy Policy. 

Cookies and Similar Technologies

As part of our Data Services and on our website, we, our service providers, and our clients may use cookies and similar technologies to facilitate the automatic data collection described in this Privacy Policy, such as:

  • Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online analytics and advertising services.
  • Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.

For example, as part of our Data Services, our clients may place tracking technologies operated by Path2Response or our service providers on their websites to automatically collect information about consumers visiting their sites and provide that information to our data cooperative.

On the Website, we may use third-party analytics services to monitor and analyze the use of our Website. For example, we use Google Analytics to help us analyze how the Website is being accessed and used. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on, available here.

Retention

We will retain each of the categories of personal information listed above 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 your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Security

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information.

Other Sites and Services

The Website may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

International Transfers of Personal Information

We are based in the United States of America, and we have service providers in the United States and potentially other countries. Your personal information may be collected, used, stored, and transferred in these countries or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service.

Children

The Website and the Data Services are not intended for use by anyone under the age of the 16, and we do not knowingly collect personal information about children under 16 years of age.

Your Choices

Access/Know, Correct, or Delete Personal Information

You may submit a request to access your information by using the form here or, you may call (888) 914-9661, PIN 625 484. 

If, after receiving your report, you feel that information about you is incorrect, you may submit a request to correct this information by emailing privacy@path2response or calling (888) 914-9661, PIN 625 484. Alternatively, you may make a request to delete your information.

You may submit a request to delete your information from our database here or, you may call (888) 914-9661, PIN 625 484. 

Please note that before we can process your requests, we may need to verify that you are who you say you are and to confirm that your request is authentic. We will review the information provided and may request additional information to ensure we are interacting with the correct individual. This is a security measure to, for example, help ensure we do not disclose information to a person who is not entitled to receive it. The identity verification process may vary depending on how you submit your request. 

Opt-Out of the Data Services

If you decide that you are no longer interested in receiving direct marketing from our customers, then you can opt-out of Path2Response sharing your information with other companies here or, you may call (888) 914-9661, PIN 625 484.

Opt-Out of Path2Response Marketing Emails

If you are subscribed to receive promotional emails from Path2Response, you may opt out of those marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails. 

Cookies

Most browsers let you remove or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Website and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit http://www.allaboutcookies.org.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. Our Website currently does not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Authorized Third-Party Agents

If you are an authorized agent making a request to access/know, correct, delete, or opt-out on behalf of an individual, we require additional documentation. 

For these types of requests, we require authorized agents to complete and submit an Authorized Agent Acknowledgment Form (“Form”) or equivalent, which may be downloaded here. This Form requests additional information that we need to process these requests, such as a copy of the consumer’s signed permission demonstrating that you have been authorized by the consumer to act on the consumer’s behalf. 

After completing, please attach and resubmit your request to agents@path2response.com.

We are not able to process requests from authorized agents if you do not provide us with sufficient detail to allow us to understand and respond to it. Path2Response does not use any Authorized Agent’s platform or technology to process requests submitted.

Consumer Rights Request Processing

For Calendar Year 2021 Path2Response processed the following Consumer Rights requests:

  • Request to Access Information: quantity processed 9; quantity denied 4; average time to process 11 days
  • Request to Delete Information: quantity processed 32; quantity denied 1; average time to process 3 days
  • Request to Opt Out of Sale: quantity processed 3020; quantity denied 103; average time to process 3 days

 

Additional Information For California Residents

Your California Privacy Rights

As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

  • Know/Access. You can request the following information about how we have collected and used your personal information:
    • The categories of personal information that we have collected.
    • The categories of sources from which we collected personal information.
    • The business or commercial purpose for collecting, selling, or sharing personal information.
    • The categories of third parties with whom we disclose personal information.
    • A copy of the personal information that we have collected about you.
  • Delete. You can ask us to delete the personal information that we have collected from you.
  • Correct. You can ask us to correct inaccurate personal information that we maintain about you.
  • Opt-out of sales/sharing. California privacy laws define a “sale” as disclosing a California resident’s personal information to a third party for monetary or other valuable consideration. Where such disclosure is for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, it qualifies as “sharing” under California privacy law. If we “sell” or “share” your personal information under California privacy laws, you can opt-out. 
  • Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment.

You may request to exercise your California rights to know/access, correct, or delete by following the instructions in the general “Your Choices” section above.

You can request to opt-out out of the sale or sharing of your personal information by clicking here: Do Not Sell or Share My Personal Information or by calling (888) 914-9661, PIN 625 484. At this time, Path2Response does not sell or share personal information collected via cookies and similar technologies on the Website. Therefore, due to technological limitations, broadcasting the Global Privacy Control (GPC) signal will not impact your opt-out preferences at this time. 

If you direct us not to sell or share your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes. We do not knowingly sell or share the personal information of California residents under 16 years of age.

To the extent we collect sensitive personal information (as that term is defined under California law), we do not collect or use it for the purpose of inferring characteristics about California residents or for other purposes other than business purposes authorized under California law.

Additional Information for Nevada Residents

Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us here or you may call (888) 914-9661, PIN 625 484.

Additional Information for Virginia Residents

Under Virginia privacy laws, you may request the rights listed below. Please note, these rights are not absolute, and, in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

  • Access/Port. You can request that we confirm whether we process your personal information and to access that personal information. You may also request to obtain a copy of personal information that you have previously provided to us in a portable and, to the extent technically feasible, readily usable format.
  • Correct. You can ask us to correct inaccurate personal information that we maintain about you.
  • Delete. You can ask us to delete personal information provided by or obtained about you.
  • Opt-out of sales and targeted advertising. If we sell your personal information for monetary consideration or engage in targeted advertising according to Virginia law, you can opt-out. 

You may request to exercise your rights to access/port, correct, or delete as described above in the general “Your Choices” section of the Privacy Policy. You can request to opt-out of sales and targeted advertising by clicking here or you may call (888) 914-9661, PIN 625 484. 

If we decline to take action on your request, you may appeal such refusal by sending us an email to privacyinfo@path2response.com within a reasonable time period after we sent you our decision. 

Changes to this Privacy Policy

Path2Response reserves the right to revise, in whole or in part, any portion of this Privacy Policy, without notice, at any time. Please review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the date of the latest version at the top of this Privacy Policy.

Contacting Us

For questions or concerns about our privacy policy or practices, please email us at privacyinfo@path2response.com.

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