Kroll Direct Marketing and WSN LLC, dba Behaviorbase, as well
as affiliates, divisions, contractors and all data sources and suppliers, all
of which are referred to herein as "The Company” has a deep commitment to the
privacy of every individual about whom it holds information. Since we gather
individual consumer data, we want users to fully understand the terms and
conditions surrounding the capture and use of that information. This privacy
statement discloses what information we gather, how we use it, and how we
correct or change it.
The Company and its employees assert that protecting consumer privacy is our
greatest concern. We pledge to conduct our business according to the following
principles:
Consumer Rights
The Company understands the always-changing legalities and
courtesies regarding the use and dissemination of our customers’ information.
Compliance
The Company actively monitors all local laws in order to be
compliant with any regulatory requirement. Ethical Relationships
The Company pledges to conduct our relationships with both clients and other
information providers in an ethical and professional manner.
Awareness
The Company is committed to education for our clients, our
employees and the industry about the issues, guidelines and laws surrounding
individual consumer rights to privacy and The Company’s privacy policies.
Accuracy
The Company maintains strict quality control and due
diligence procedures to assure the integrity and accuracy of our information.
Security
The Company maintains strict security procedures to ensure
information will not be made available to any unauthorized person or business.
Consumer Benefits
The Company offers services and information products that
provide benefits to both consumers and businesses.
Information Gathering and Tracking
The Company captures consumer information from own websites
and through opt-in co-registration from our vendors. This information is
typically obtained through our own, or our vendors' sites in connection with a
user's registration. The information captured allows for more targeted offers
to consumers.
Use of Information
The Company uses any information obtained in order to
provide users with information on products and/or services that may be of
interest to them.
We may enhance or merge users’ personally identifiable information with data
collected from other sources to use in direct or online marketing, including
the data services described in "Sharing of Information" below. In the event we
enhance or merge personally identifiable information with data collected from
other sources, we will take all necessary steps to maintain the integrity and
quality of that information.
Sharing of Information
The Company uses the information described above to help
our clients better understand the demographics of their target audiences as
well as to support our marketing of data products and services. We may provide
personally identifiable data to marketing companies, advertising agencies, data
compilers, data companies, and, to the extent permitted by law, individual
reference and look-up service programs. Such information may be used by such
companies to provide consumers with information on products and services that
may be of interest.
If consumers in our database have indicated that they do not want to have their
data shared with third parties, The Company will limit the use of their data to
the suppression, validation and enhancement of existing information held by
third parties about its users. For example, marketers may use data about a
registrant provided by The Company, such as "opt-out" information, to suppress
or drop the registered user's name from a file of potential customers.
Additional information may be used to verify and/or validate the accuracy of
existing data on the registrant that was lawfully acquired by a marketer. In
addition, our data customers may use data supplied by The Company to enhance or
append personally identifiable data to their file for use in direct or online
marketing subject to the terms of their own privacy policies.
Exceptions may occur in the event of a merger, acquisition, sale of assets of
The Company or any of its divisions as a going-concern, or change of control,
in which case such data would be considered a business asset and would be
transferred subject to the terms of this privacy policy. Nonetheless, our users
will always have the opportunity to choose whether or not they want to receive
further information and offers from any division within The Company or our
marketing partners.
Opt-out/Unsubscribe Policy
By registering with our or our vendors' sites to receive
third party offers, users allow The Company and its affiliates to make their
personally identifiable information available to third parties in accordance
with the terms of this privacy policy. The Company provides users the option to
opt-out from receiving information sent on behalf of third party advertisers by
our internal affiliates or to opt-out from The Company and its divisions
sharing information with advertisers or third party marketers for promotional
purposes. Notwithstanding, all personally identifiable information provided by
a user may be used by The Company to support its marketing data services
business described above.
Users may unsubscribe to electronic mailings sent via our internal affiliates
at any time by following the instructions contained at the end of every
newsletter or emailing. Users may opt-out of receiving further information sent
on behalf of third party advertisers by The Company or from The Company sharing
information with advertisers or third party marketers for promotional purposes.
Currently, The Company does not offer users a means by which to completely
delete personal data in order to maintain a master suppression file.
Please note that information sent on behalf of third party advertisers is
prepared days in advance, so users may continue to receive email from The
Company for up to 7-days after they have un-subscribed.
Security Policy
The Company maintains security guidelines to protect the
loss, misuse, or alteration of information in its database. Access to
personally identifiable information is only provided to authorized employees of
The Company. Employees of The Company are made aware of our security guidelines
during our employee orientation process. Our security guidelines are reviewed
at least quarterly based on our fiscal calendar.
With any specific questions regarding our privacy policy, we can be reached via
email at privacy@lifestylebase.com. The Company takes online privacy extremely
seriously, and does not share the information users have submitted without
their permission.
Consumer Advocacy
We have a Privacy Advocate that is available to assist our
users with any privacy concerns they may have. Our privacy advocate will take
each individual’s concerns seriously and will ensure that any necessary steps
are taken to resolve any potential conflicts. Our privacy advocate supervises
the “unsubscribe” process and ensure that such consumers are removed from our
email lists within 7-days, and individually assist in various issues regarding
consumer privacy.
Internal Monitoring
Our Privacy Advocate also ensures that all aspects of our
privacy policy are upheld. All employees receive the appropriate training and
resources to ensure privacy compliance, and we regularly monitor our security
protocols, and handle any concerns regarding our employees’ compliance with our
privacy principles and policy.
Contact Information
Our Consumer Privacy Advocates may be reached via e-mail:
Privacy Department
BehaviorBase
privacy@behaviorbase.com