PRIVACY POLICY

Epsilon Privacy Policy

Last updated: February 18, 2020

Epsilon Data Management, LLC (“we,” “our,” “Epsilon”) provides a variety of data marketing and consumer analytics products, technologies, and services (the “Services”) designed to provide data intelligence and consumer insights for our clients (“Clients”). Our solutions, as described on this website (or any other website on which this Privacy Policy is posted) (“Website” or “Websites”), are used for both online and offline marketing purposes. When we say “you” we are referring to consumers, including the person reading this Privacy Policy.

We take very seriously the privacy interests of the individuals whose information we collect through our Services. We provide this Privacy Policy (“Privacy Policy”) to explain how we use and manage information collected through our Services, and what rights consumers have to control how their information is used and shared.

Our corporate Websites are designed for our Clients, prospective clients and others who want to learn about our Services. We address the information we collect and use from those Websites in Section 5 of this Privacy Policy.

Our treatment of applicant, prospective applicant, and other prospective employment related information is described in Section 6 of this Privacy Policy.

When we handle information on behalf of Clients related to their own customers (and prospective customers), we do so as a service provider. We address these practices separately in Section 7 of this Privacy Policy.

For the privacy policy applicable to the Epsilon PeopleCloud Digital Media Solutions, Epsilon PeopleCloud Prospect, and Epsilon PeopleCloud Discovery products, please visit https://www.conversantmedia.com/legal/privacy.

In addition, this Privacy Policy does not apply if you are accessing our Websites from the European Union. In that case, you should refer to EMEA Epsilon Privacy Policy.

1. Information That We Collect and the Ways We Use It

In order to provide our Services, we obtain information about you through the means discussed below. In addition to the purposes set out below, we may use all or a combination of this information to detect or prevent fraud, and to defend our legal rights and comply with the law. Epsilon also receives information through its corporate Websites. We describe that information in Section 5. We may combine the information that we collect through the Services with information that we collect automatically or receive from other sources. We share and disclose the information we collect as described in Section 3.

Categories of information collected

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

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

Geolocation information

  • Data marketing services
  • Online targeting
  • Additional marketing services
  • Operate our Services
  • Apparel & Accessory Companies
  • Automotive Companies
  • Business to Business Companies
  • Parenting Product Companies
  • Consumer Packaged Goods Companies
  • Inquiries About Products or Services
  • Consumer Survey Companies
  • Surveys from Consumers/Self-Reported Data
  • Data Compiling Companies
  • Health and Wellness Product and Service Companies
  • Electronic Companies
  • Financial Service Companies
  • Food & Beverage Companies
  • Gift Product Companies
  • Lifestyle & Interest Product Companies
  • Not for Profit Organizations
  • Public or Government Entities
  • Publishing Product Companies
  • Telecommunications Companies
  • Travel, Leisure & Entertainment Companies

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

  • Data marketing services
  • Online targeting
  • Additional marketing services
  • Operate our Services
  • Apparel & Accessory Companies
  • Automotive Companies
  • Business to Business Companies
  • Parenting Product Companies
  • Consumer Packaged Goods Companies
  • Inquiries About Products or Services
  • Consumer Survey Companies
  • Surveys from Consumers/Self-Reported Data
  • Data Compiling Companies
  • Health and Wellness Product and Service Companies
  • Electronic Companies
  • Financial Service Companies
  • Food & Beverage Companies
  • Gift Product Companies
  • Lifestyle & Interest Product Companies
  • Not for Profit Organizations
  • Publishing Product Companies
  • Telecommunications Companies
  • Travel, Leisure & Entertainment Companies

Inferences, e.g., inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

  • Data marketing services
  • Online targeting
  • Additional marketing services
  • Operate our Services
  • Apparel & Accessory Companies
  • Automotive Companies
  • Business to Business Companies
  • Parenting Product Companies
  • Consumer Packaged Goods Companies
  • Inquiries About Products or Services
  • Consumer Survey Companies
  • Surveys from Consumers/Self-Reported Data
  • Data Compiling Companies
  • Health and Wellness Product and Service Companies
  • Electronic Companies
  • Financial Service Companies
  • Food & Beverage Companies
  • Gift Product Companies
  • Lifestyle & Interest Product Companies
  • Not for Profit Organizations
  • Publishing Product Companies
  • Telecommunications Companies
  • Travel, Leisure & Entertainment Companies

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
  • Apparel & Accessory Companies
  • Automotive Companies
  • Business to Business Companies
  • Parenting Product Companies
  • Consumer Packaged Goods Companies
  • Inquiries About Products or Services
  • Consumer Survey Companies
  • Surveys from Consumers/Self-Reported Data
  • Data Compiling Companies
  • Health and Wellness Product and Service Companies
  • Electronic Companies
  • Financial Service Companies
  • Food & Beverage Companies
  • Gift Product Companies
  • Lifestyle & Interest Product Companies
  • Not for Profit Organizations
  • Publishing Product Companies
  • Telecommunications Companies
  • Travel, Leisure & Entertainment Companies
  • Public or Government Entities

Internet or other electronic network activity information

E.g., browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer's interaction with a website, application, or advertisement.

  • Data marketing services
  • Online targeting
  • Additional marketing services
  • Operate our Services
  • Apparel & Accessory Companies
  • Automotive Companies
  • Business to Business Companies
  • Parenting Product Companies
  • Consumer Packaged Goods Companies
  • Inquiries About Products or Services
  • Consumer Survey Companies
  • Surveys from Consumers/Self-Reported Data
  • Data Compiling Companies
  • Health and Wellness Product and Service Companies
  • Electronic Companies
  • Financial Service Companies
  • Food & Beverage Companies
  • Gift Product Companies
  • Lifestyle & Interest Product Companies
  • Not for Profit Organizations
  • Publishing Product Companies
  • Telecommunications Companies
  • Travel, Leisure & Entertainment Companies

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 Section 8.

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 information

Whether We Sold This Information in the Last 12 Months

Third 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

Geolocation information

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., 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

Inferences, e.g., inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

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

Internet or other electronic network activity information, e.g., browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer's interaction with a website, application, or advertisement.

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 may 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. Cookies and Similar Technologies

a. Cookies and How We Use Them

Epsilon and its business partners use certain industry-standard technologies, including cookies and similarly functional technologies, which we describe below. (We use these technologies on our Website, for instance, and our partners may use these technologies in their own marketing services.)

We may work with third parties to provide or enhance our Services (e.g. for purposes of tailoring ads, or placing browser cookies), or to offer marketers ways to access or use our Information, often in de-identified form. These partners may set and access their own cookies, pixel tags and similar technologies on your device, which may have cookies with varying expiration periods. Those partners may, likewise, collect various types of information about your browser, device, or browsing activities through use of these cookies.

Cookies, in turn, are small data files that contain a string of characters, such as a unique browser identifier. Cookies are stored on your computer or other device and act as tags that identify your device. Our (or other companies’) servers send your device a cookie when you visit a website. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access web pages (such as the website of a marketer), pixel tags may permit our partners (or sometimes, us) to read the cookies that a respective company or server has deployed. Pixel tags are used in combination with cookies to track the activity on a site by a particular device.

We or our service providers, and other online marketing platforms that we or they work with, may use cookies to, among other things, “remember” you, determine visitor patterns and trends, collect information about your activities on our clients’ sites, or interact with the advertising you see. Cookies are used in this way to provide relevant content to you and replace non-relevant communications with ads that better match your interests.

b. Disabling Cookies

Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of our Website and other services may be difficult to use or become inoperable.

c. Types of Cookies used by Epsilon on our Sites

Performance cookies: These cookies collect information about how visitors use our Sites for web analytics purposes. For instance, we may use cookies to analyze which pages visitors go to most often and if they receive any error messages. These cookies are used to help improve our Sites and your experience on our Sites. By using our Sites, you agree that we can place these types of cookies on your browser.

Functionality cookies: These cookies allow our Sites to remember choices you make (such as remembering your username 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 personalizations. 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 collect information about your browsing activity on other websites. By using our Sites, or by signing up for an account with us, you agree that we can place these types of cookies on your browser.

Interest-Based Advertising cookies: For information on cookies that are used for interest-based advertising, please see below under Interest-Based Advertising.

d. Other Tracking Technologies

We, and our service providers, may use other technologies, such as beacons, tags and scripts, on our Sites for analytics and administrative purposes. These technologies may be used in analyzing trends, administering the Site, recording users’ movements around the Site and gathering demographic information about our visitor base as a whole. We may receive reports based on the use of these technologies by these companies on an aggregated basis.

We may partner with third parties who provide certain features on our Sites, or to display advertising, based upon your web browsing activity using local storage objects (LSOs) such as Flash to collect and store information. Various browsers may offer their own management tools for removing Flash LSOs. To manage Flash LSOs, please click here.

For any questions related to our web technologies, you may contact us via email at privacy@epsilon.com.

5. Data Collected Through Our Websites

We will sometimes give you the opportunity to provide information directly to us through our corporate Websites – such as if you are a business interested in a relationship with us or an individual completing one of our surveys. Additionally, as you interact with our Websites, we may use (or engage with business partners and vendors that use) automatic data collection technologies such as cookies (described above) to collect certain information about your equipment, browsing actions, and patterns.

As you browse the internet or go across mobile apps, you may see advertisements on the web pages or the apps you visit. Some of these ads may be more relevant to you based on a variety of factors, such as the previous websites or apps you have visited, your perceived interests and your demographic information. This practice is called Interest-Based Advertising or Cross-App Advertising. To learn more about this practice, please visit the Network Advertising Initiative’s website.

We may work with our advertising partners to enable the delivery of relevant messages to the right consumers while protecting consumer privacy and offering choices about participating in such activities. Our third-party partners may use technologies, such as cookies, to gather information about your activities on this Site and other sites in order to provide you with relevant advertising. Relevant advertising does not result in more ads, but rather the relevancy of the ads you see.

To learn about how to opt out of receiving relevant advertisements on the web or mobile apps, visit the Relevant Advertising Opt-Out section below.

Our data collection practices concerning our Websites are included in the following chart:

Categories of information collected

Purposes of collection and use

Sources of Personal Information

Business contact information, e.g., email address, name/address, job title

  • Operate our Websites and Services
  • Send you marketing communications
  • Building and managing business-to-business relationships
  • Consumers
  • Trade associations
  • Conferences
  • Business data resellers

Device information and identifiers, e.g., online cookies identifiers, IP addresses, email address, name/address, job title

  • Operate our Websites and Services
  • Personalize your experience
  • Secure our Services
  • Fraud prevention and legal purposes
  • Consumers
  • Analytics providers
  • Cookies and tracking technologies
  • Data resellers

Internet or other electronic network activity information

E.g., browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer's interaction with a website, application, or advertisement.

  • Operate our Websites and Services
  • Personalize your experience
  • Secure our Services
  • Fraud prevention and legal purposes
  • Consumers
  • Analytics providers
  • Cookies and tracking technologies

Other information consumers choose to directly to provide to us, including for billing purposes

  • Operate the Websites and Services
  • Send marketing communications
  • Building and managing business-to-business relationships
  • Billing and accounting purposes
  • Communicate with you
  • Secure our Services
  • Fraud prevention and legal purposes
  • Consumers
  • Website visitors

As with the information we use within our products and services, we also may share any of the personal information we collect on or through our Website(s) 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 may 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. 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.

6. Prospective Employment Information

We may obtain personal information from you regarding any job postings you may apply to, which may include name, email address, mailing address, social media sign-in information, postal address, phone number, picture, jobs you show interest in, the date you first looked at a job, education level, employment history, and any other personal information contained in your résumé/CV that you submit through our Websites or otherwise provide to us. For instance, we collect prospective employment information when we receive information through the Career website, an Epsilon recruiter, or data from third party recruiters.

If Epsilon considers your application or extends an offer of employment, Epsilon may collect certain additional data either directly from you or from third parties such as background checks, where allowed by local law, with your consent. Epsilon relies on your consent when collecting this data.

When you visit our Websites (including our Career website), your browser automatically sends us an Internet Protocol address and certain other data, including the type of browser you use. Our cookies on this site are used solely to facilitate your online experience and are not used to make employment-related decisions.

We may use this information to evaluate your application, communicate with you in (for instance, to send you a welcome email), verify your information for employee recruitment purposes, analyze staffing needs and practices, respond to your requests for information, or otherwise efficiently manage our hiring process and employee administration. We may combine applicant data with research tools and data from other sources.

7. Information We Receive from Clients, and our “Agency” Services

Epsilon, as a service provider, provides its Clients with agency services as well as an email platform and loyalty service platform. For instance, Clients leverage Epsilon to schedule and manage their email campaigns and manage their loyalty and incentive programs. When our Clients provide us with information relating to their customer, prospective customers or other individuals, we handle it on behalf of our Clients as a service provider.

Our Clients determine how to engage with their customers and thus act as the business that determines the purposes and means of handling customer or “CRM” data. Under these circumstances, Consumers are ultimately subject to the privacy policy(ies) of the Clients controlling their data, and they should read those policy(ies) carefully. We are not responsible for the privacy practices of our Clients. Accordingly, this Privacy Policy and the rights acknowledged herein do not apply to data that Epsilon handles on behalf of its Clients.

As a service provider, Epsilon may only process its Clients’ data upon instruction from the respective Client. (Accordingly, Epsilon shares or discloses its Clients’ data to service providers, Clients, and Clients’ service providers per our Client’s instructions.) Epsilon may also share Client data (1) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information received by us, whether or not a response is required by applicable law; (2) to enforce our terms of use and other agreements or to protect our rights; and (3) to protect the safety of members of the public and users of the service.

While Epsilon strongly encourages its Clients to adopt responsible approaches to its marketing practices, Epsilon is not responsible for the information practices of such Clients.

8. Choices and Access

Client/prospect opt-out

We maintain contact lists to communicate with our clients and prospects. Individuals must affirmatively ask to join one or more of our email lists by registering on our Sites. All email messages sent to these lists include an opportunity to unsubscribe or opt out of future email messages. You may also request to be removed from future email messages by contacting us via email or by using the links below:

We also maintain a postal mailing list to communicate with our clients and prospects. You can request to be removed from our mailing list by sending your name and postal address to us via email or postal mail to one of the addresses listed below under Contact us.

For more information on Epsilon’s databases and for information on how to opt out, please visit our consumer preference center.

Access to Personal Information

At Epsilon, we believe it is important to provide consumers with clear information about the data available in our databases. If your personal information changes, or if you no longer desire our service, you may correct, delete or ask to have your information removed by contacting us.

U.S. residents may request access to learn what information Epsilon has about your household in our databases using our marketing data summary request form. You may request access by visiting this page: consumer preference center.

For non-U.S. residents, please contact us via email or postal mail at one of the addresses listed below under Contact us.

Relevant Advertising Opt-Out

You can opt out of relevant advertising through the following means:

  • U.S. Visitors:

You may opt out of our marketing databases. If we market to you by email, in our corporate capacity – such as if you are a Customer or prospective customer and we send information about our Services – you may “unsubscribe” from our marketing emails through a link placed in your emails.

You also may request that Epsilon not sell your information by filling out and submitting the online request form.

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

You can also opt out of online targeted ads (sometimes referred to as “interest-based” or “personalized” advertising), by visiting the opt-out portals operated the industry groups the National Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA), and you can learn more about how those opt-outs work on those linked web pages. Please note that these online opt-outs are cookie-based (unlike Epsilon’s direct opt-out). Thus, if you browse the web from multiple browsers or devices, you will need to opt out from each browser and/or device, and for the same reason, if you change browsers or clear your browser cookie cache, you will need to perform this opt-out function again. Opting-out in this way will not prevent you from seeing all types of online ads; it generally will prevent targeted ads customized to what advertisers think may be most likely to be relevant and of interest to you.

You may visit the Network Advertising Initiative (NAI) to learn more about its program and to opt out of the Interest-Based Advertising delivered by NAI members on web pages using cookies by visiting: http://www.networkadvertising.org/choices/.

We adhere to the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles. You can visit the DAA to learn more about its program and to "opt out" of the online behavioral advertising delivered by its participants on web pages using cookies by visiting: http://www.aboutads.info/.

  • European Union Visitors:

We support the European Digital Advertising Alliance’s (“EDAA”) Self-Regulatory Principles. You can visit the EDAA to learn more about its program and opt out of the online behavioral advertising delivered by its participants on web pages using cookies by visiting: http://www.youronlinechoices.eu.

  • Canadian Visitors:

We support the Digital Advertising Alliance of Canada’s (“DAAC”) Self-Regulatory Principles. You can visit the DAAC to learn more about its program and opt out of the online behavioral advertising delivered by its participants on web pages using cookies by visiting: http://youradchoices.ca/choices/.

Please note that these opt-outs operate by placing a cookie on your device that is unique to the browser you use to opt out. If you change browsers or computers, or delete the cookies on your computer, you will need to opt out again.

For any questions related to our digital services, you may contact us via email at privacy@epsilon.com.

  • Mobile App Opt Out:

You can learn more about how to opt out of the use of information for relevant advertising on your mobile application device, such as Apple iOS, by visiting this page: http://www.networkadvertising.org/mobile-choices

9. Privacy Rights for California Residents

If you are a California resident, California law requires us to provide you with certain additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). Please do not rely on the below information and disclosures in this section or otherwise directed to California residents if you are not a resident of California.

i. Your California Privacy Rights

CCPA Rights Disclosure. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

  • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
  • Provide access to and/or a copy of certain personal information we hold about you.
  • Delete certain personal information we have collected from you (if any). (Most of the personal information we have is not collected by us from consumers, but rather, is obtained in other ways.)
  • Provide you with information about the financial incentives that we offer to you, if any.

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

Please note that certain information may be exempt from such requests under California law. We also will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the type of request you are making, using a series of test questions.

You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests (which we may ask to review) or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us by filling out and submitting the online request form or by calling toll-free (866) 267-3861.

ii. Notice of Right to Opt Out of Sale of Personal Information

California residents may opt out of the “sale” of their personal information. As a California resident, you are permitted to designate an authorized agent to submit an opt out on your behalf. We may have sold the following categories of information about you: commercial or transactions information, demographic and statistical information, geolocation information, inferences, device information and identifiers.

If you would like to opt out of our use of your information for such purposes that are considered a “sale” under California law, you may do so as outlined on the following page: Do Not Sell My Personal Information. You can also submit a sale opt-out request by calling toll-free (866) 267-3861. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.

California law also gives residents the right to: (1) request that we provide you with information about the financial incentives that we offer to you and (2) not be discriminated against (as provided for in applicable law) for exercising certain of your rights. We offer no such incentives and engage in no such discrimination.

10. Privacy Rights and Choices for Consumers

Consumers whose personal information has been submitted to Epsilon by one of our Clients who wish to exercise any rights they may have under applicable laws should inquire directly with the relevant Customer. If consumers wish to make a request directly to Epsilon, they should provide the name of the Epsilon Client that the request refers to. We will refer the request to that Client and will support them as needed in responding to the request within a reasonable timeframe.

11. Do Not Track

Please note that, currently, Epsilon does not honor browsers’ Do Not Track (DNT) signals, due to the lack of clarity around the standards for the DNT signal.

12. Retention

Epsilon retains your information for as long as you have an open and active account profile with us or as needed to provide you the services you requested. We will retain and use your information to comply with our legal obligations, resolve disputes and enforce our agreements.

We will retain the minimum amount of personal information necessary to maintain a record of your opt-out if you choose to opt out of our communications.

13. Links to Third Party Sites

Our Sites contain links to unaffiliated third-party sites. We do not endorse or make any representations about any third-party sites (or any information, software or other products or materials found there) to which our sites might link. This privacy policy does not apply to the information collection and use practices of third-party sites. We encourage you to review the privacy policies of these unaffiliated third-party sites to understand their data collection and use practices.

14. Content Sharing Features

Our sites include social media sharing features, such as LinkedIn and Twitter buttons, and may set a cookie to enable the feature to function properly. These features may collect your IP address and which page you are visiting on our Sites. Social media features are governed by that social media company’s privacy policy.

We may also allow you to email useful information from our Sites to a friend or colleague. If you choose to do so, we may ask you to provide your full name and email address, as well as your friend’s complete email address. We will send your friend a one-time email inviting him or her to visit the site, except where prohibited by law. Your friend or colleague may contact us at privacy@epsilon.com to opt out.

15. Participation in Online Forums

Our sites provide opportunities to participate in various online forums (for example, the Epsilon blog A Brand New View). If you contribute any content to an online forum, you retain your rights to any content you post. However, by posting content on or through an online forum, you grant us a worldwide, nonexclusive, royalty-free license (with the right to sublicense) to use, copy, reproduce, process, adapt, modify, publish, transmit, display and distribute your content in any and all media or distribution methods (now known or later developed) for any and all purposes.

Any content you post to an online forum may be publicly viewed and used by anyone on the internet. You are responsible for any content you post, and for any consequences thereof, including the use of your content by other users. To protect your privacy, we remind you and ask you to not submit personal information in a public forum.

By posting, you agree not to post any content that (i) is unlawful, harmful, threatening, abusive, harassing, tortious, defamatory, vulgar, obscene, libelous, invasive of another’s privacy, hateful, or racially, ethnically or otherwise objectionable; (ii) you do not have a right to make available under any law or under contractual or fiduciary relationships; (iii) infringes any patent, trademark, trade secret, copyright or other proprietary rights of any party; or (iv) contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment.

We may prescreen, refuse or remove any content that you post. We may also modify or adapt your content in order to transmit, display or distribute it.

We do not control the content posted by public users to our Sites and, as such, do not guarantee the accuracy, integrity or quality of such content. Under no circumstances will we be liable in any way for any user-contributed content, including, but not limited to, any errors or omissions in any content, or any loss or damage of any kind incurred as a result of the use of any user-contributed content.

To request removal of your personal information from our online forums, or to notify us of a posting that violates our rules for posting in Epsilon’s online forums described above, please contact us at privacy@epsilon.com. If we are unable to remove your personal information, we will let you know that we are unable to do so and why.

16. Sensitive Information

We ask that you not send or disclose any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) to us through our Sites or otherwise.

17. Use of The Sites by Children

Our Sites are not intended for children under the age of thirteen (13). We ask that children not provide personal information through our Sites. If we become aware that we have collected personal information from a child under the age of 13, we will delete that information from our records.

18. Security and Data Integrity

Epsilon takes steps to help ensure that the data we possess is housed and transmitted securely. This may include various types of physical and electronic security, including firewall protections, encryption, hashing or truncation of data, and access controls to personal information. While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we employ efforts that are designed to ensure that this does not occur.

19. Changes to this Privacy Policy

From time to time, we may update this Privacy Policy. Any changes to it will become effective when it is posted to our website. Please check back to learn of any changes to this Privacy Policy

20. Storage of Information in the United States

If you are accessing our Websites from a location outside of the United States, your connection will be through and to servers located in the United States and the Information you provide will likely be processed and securely maintained in our web servers and internal systems located within the United States. (We likewise generally store the Information used in our Services in the United States.) Thus, you should be aware that in accessing this website or otherwise communicating with us, the information we collect or receive from you may be subject to laws with lesser or different privacy standards than those in your own country (such as if you are in a country located in the European Union).

21. Contact Us

Epsilon has a designated privacy contact. To ask questions about Epsilon’s privacy policy or to request more information on Epsilon’s privacy practices, email us or send correspondence to:

  • North America
    privacy@epsilon.com
    Epsilon
    P.O. Box 1478
    Broomfield, CO 80038
    Attn: Privacy
  • EU and EEA region
    emeaprivacy@epsilon.com
    Epsilon International|
    Attention: Privacy
    Teddington House
    67 Broad Street, Teddington
    Middlesex TW11 8QZ, UK
  • Asian-Pacific region
    apac-privacy@epsilon.com
    Epsilon International-APAC
    Attention: Privacy
    Room 2601, 26/F
    Hopewell Centre
    183 Queen’s Road East
    Wanchai, Hong Kong