DMS - PRIVACY NOTICE

Introduction

Direct Marketing Solutions (“DMS,” “we,” or “us”) provides to clients a wide variety of distribution, analytic, and marketing services, which help our clients and the platforms and partners they work with to provide more relevant marketing and communications, and to understand their consumers better. Our clients may reach their customers and others, for instances, through direct mail, email, display, mobile, and multi-media channels. Many of these services are described in greater detail on our website, https://teamdms.com/ (our “Website”).

We provide this Privacy Notice (this “Notice”) to consumers and other who want to learn about the data we handle and how we use it. When we provide services to our clients, we generally act as a “data processor,” and the customer is considered to be the “data controller,” as further described in the When DMS is a Controller and When DMS is a Processor sections below. We may provide additional data privacy notices specific to certain practices or regions. Those terms are to be read in conjunction with this Notice. This Notice may change from time to time (see Changes to Our Privacy Notice). Our Website, together with the products and services we provide, are collectively referred to herein as our “Services”.

Most of the information that we handle is not collected on our Website, but rather through relationships we have with other companies such as data suppliers, business partners (such as ad networks and other online partners), data service providers, agencies, and our clients. This Notice addresses information we collect in this way, as well as information we collect through our Website.

Children Under the Age of 18

Our Services are not for children. No one under 18 is permitted to provide any information on our Website. We do not knowingly collect information from children. If you are under 18, do not use our Website or provide any information to us. This includes giving us your name, address, phone number, email, or username. If we find out we have collected information from a child under 18, we will delete it. If you think we might have information from or about a child under 18, please contact us at optout@teamdms.com.

Information We Collect

We receive data from, and handle data on behalf of, a variety of consumer-facing companies, applications and services, business-facing companies, and data compilers and suppliers. We collect two basic types of information:

Information that identifies (whether directly or indirectly) a particular individual, such as your name, postal address, email address, and telephone number (“Personal Information”); and
Information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual (“Anonymous Information”). When Anonymous Information is directly or indirectly associated with Personal Information, the resulting information is also treated as Personal Information.

We may use Personal Information and Anonymous Information to create a third type of information: information about groups or categories of individuals, which does not identify and cannot reasonably be used to identify an individual (“Aggregate Information”).

In particular, we collect:

Contact information such as your name, email address, telephone number, postal address, mobile advertising identification number (“MAID”), and social media information.
Demographic information, including your age, ethnicity, race, nationality, marital status, gender, political affiliation, religion, philosophical beliefs, household composition, language, socioeconomic status, and household income.
Commercial or transaction information, including homeownership status, buying activity and interests, and retail purchase data (at category levels, not “SKU”-level).
Financial information, including your credit scores, credit history, investment records, and financial transactions with our clients.
Geolocation information, including precise or approximate location information provided by a mobile or other device with our Website and our clients’ websites, or associated with your Internet Protocol (“IP”) address or other online or device identifier.
Activity, usage, viewing, technical, and device data when you visit our Website, our clients’ websites, or open emails we send. This includes the content you view, how often you use a website, your browser or device type, your search queries, your device’s unique identifier, and an IP address. We may obtain this information from a third party, such as site or platform providers and analytics tools.
Copies of your Communications with us and our clients, such as form submissions and call logs.
Employment information, such as your occupation, job title, employer, business-related postal address, telephone number, fax number, professional license information, and income level.
Education information, such as your degrees obtained, schools attended, and certifications.

How We Collect Your Information

1. Directly From You. We collect information, including Personal Information, you provide to us when you:

Visit, register with, access, use, or otherwise engage with (collectively, “interact”) with our Website or any other website or mobile application owned or controlled by us that link to this Notice.
Apply for employment with us or go through onboarding process to become part of our team.
Email, text, call, or otherwise communicate with us.
Request or purchase products, services, or information from us.

2. Through Automatic Technologies and Analytics Tools. We collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, Web beacons, and third-party analytics tools when you visit our Website, whether or not you are logged in or registered. Please see Automatic Technologies We Use for further information, and Your Controls and Choices for how to disable cookies and otherwise make choices with respect to such data collection.
3. From Third Parties. We may obtain information from third-party sources such as our service providers and clients. We also license information from other companies. We may use this information to enhance the information that we already maintain and to improve the accuracy of our records, in addition to other purposes described in this Policy.
4. From Publicly Available Sources. We may gather information, including personal information, about your from publicly available information on the web or through other research we conduct.

Automatic Technologies We Use

The technologies we may use to automatically collect your information when you interact with our Website include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Click Tracking. Click tracking is an analytical feature that measures and reports where users click or tap on our Website. Every time you click on our Website, we record the event and log your user session for future analysis. We use this information only to improve our Website. Click tracking only collects the IP address assigned to you on the date when you visit our Website, rather than your name or other identifying information.
Analytics. We collect analytics information from our web server and Google Analytics (see Third-Party Tools We Use). This includes information such as how many users visit our Website, what pages they visit when they do so, what other sites were visited prior to coming to our Websites, and IP addresses. We use the information we get from analytics tools only to improve our Services, and do not combine the information collected with Personal Information.

Third-Party Tools We Use

We use the following third-party tools and services in connection with our Website:

Google Analytics. Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our Website. The cookie cannot be used by anyone but Google. We do not control Google’s tracking technologies or how Google may use them. Google’s ability to use and share information collected by Google Analytics about your visits to our Website is restricted by Google Analytics’ Terms of Use and Google’s Privacy Policy. If you have any questions about how Google Analytics uses your information, please contact Google directly. For more information on how to opt-out of Google Analytics, see Your Choices and Controls.
UXWizz. UXWizz is an analytics tool that uses sessionStorage and localStorage to manage user sessions and preferences. It collects information such as unique session IDs, hashed IP addresses, geolocation data, browser versions, screen resolutions, visit durations, pages visited, and user interactions like clicks and mouse movements. This data is stored on your own server and used to improve user experience through session playback and traffic analysis. For more information on how UXWizz uses and stores data, please refer to the UXWizz Privacy Policy.
Matomo. Matomo is an analytics tool that collects data such as anonymized IP addresses, browser types, device information, and user interactions like page views and clicks. This data is stored on your own server and used to improve user experience. For more information on how Matomo uses and stores data, please refer to the Matomo Privacy Policy.

How We Use Your Information

Consistent with applicable law and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you to:

Provide, maintain, and improve our Services.
Provide and deliver our Services, process transactions, and send related information, including communications and invoices.
Respond to comments, questions, and requests, and to provide customer support.
Send technical notices, updates, security alerts, and support and administrative messages.
Send you offers and promotions for third-party products and services, and to provide news and information.
Provide you with targeted advertising based on your activity on third-party websites and applications.
Operate, understand, optimize, develop, or improve our Services and operations, including by using survey research and analytics tools.
Help our clients deliver, target, and optimize direct mail and email campaigns, display, mobile, social media, and cross-channel marketing.
Measure the effectiveness of our clients’ ad campaigns (online and offline), such as 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.
Create sets of consumer attributes—categories of personal interests that are grouped together based on common interests or preferences (“Data Segments”). These Data Segments may be associated with a person, household, or when used online, a unique online identifier, such as being a member of a certain profession. Our clients use Data Segments to tailor more relevant ads and offers to prospective customers, or to learn more about their own customers and improve their own databases.
Provide other data services, such as verification, record look-up, anti-fraud services, business-to-business records and services, and other analytics and database tools.
Verify, cleanse, update, and maintain information provided through our Services or through the other methods described in this Notice.
Notify you of safety issues.
Consider persons for possible employment with DMS and communicate about employment opportunities or submitted employment applications.
Respond to request from individuals to access, correct, or delete their information, or requests to exercise other rights related to their information under applicable law.
Create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners or clients may use to provide and improve their respective services.
Comply with our contractual and legal obligations, resolve disputes, with users, and enforce our agreements.
Detect, investigate, and prevent activities that may violate our policies, pose safety issues, or be fraudulent or illegal.
Protect the rights and property of DMS, our clients, and others.
Carry out any other purposes as described at the time the information was collected.

We share your information with our clients, partners, certain third parties, and as required by law. This includes:

When we provide Services to our clients, in which case they may use such information to market their products or services to you if you have not opted-out of these disclosures. For more information on how to opt-out of our sale of your personal information, please see Your Controls and Choices.
When we work with service providers performing services on our behalf; however, these companies are prohibited from using your Personal Information for purposes other than those requested by us or required by law. This includes sharing your:
- Contact information with our email marketing services provider to manage communications.
- Geolocation information with our email marketing services provider, and analytics companies to personalize user experiences, optimize marketing efforts, and analyze trends to improve our Services.
- Activity, usage, viewing, technical, and device data with our analytics companies and email marketing services provider to understand how you interact with our emails, Website, and clients’ websites, and with our web hosting provider to ensure the proper functioning of our Website and our clients’ websites.
- Applicant and Employee data with third party service providers who facilitate the application process employment onboarding, and payroll services.
When we share your Personal Information with third parties in connection with the sale of a business, to enforce our Terms of Use, to ensure the safety and security of our users, customers, employees, or other third parties, to protect our rights and property and the rights and property of our users, customers, employees, or other third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law.
If our company or substantially all of our assets are acquired, or in the event of a merger or bankruptcy, information about you and/or information you provide to us may be among the transferred assets.

Please note that, except as otherwise stated above, once we share your Personal Information with another company in the above circumstances, the information received by the other company is controlled by that company and becomes subject to its privacy practices.

Your Controls and Choices

In accordance with applicable law, your controls and choices may include:

Accessing, correcting, updating, or deleting your Personal Information.
Choosing or changing your choices for emails, alerts, or other notifications.
Setting your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Website may then be inaccessible or not function properly.
Setting your browser to transmit “Do Not Track” signals. However, since uniform standards for “Do Not Track” signals have not been adopted, our Website does not process or respond to such signals.
Choosing whether to receive from us offers and promotions for our or third-party goods and services we think may be of interest to you.
Opting out of Google Analytics by following Google’s instructions at https://tools.google.com/dlpage/gaoptout.
Controlling targeted advertising from many ad networks and partners, data exchanges, and marketing analytics and digital advertising and marketing service providers (by visiting the Digital Advertising Alliance or the Network Advertising Initiative.

You may exercise these controls and choices in various ways, including as outlined above, by emailing us at optout@teamdms.com or by following instructions provided in communications sent to you. We may not accommodate a request if we believe the request would violate any law or legal requirement or cause the information to be incorrect. Privacy choices you make on a third-party site or platform will not apply to our use of the information we have collected. If you have questions about the specific Personal Information about you that we process or retain, and your rights regarding that Personal Information, please contact us at optout@teamdms.com.

Data Security, Integrity, and Retention

The security, integrity, and confidentiality of your information are very important to us. We have implemented technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We retain your Personal Information for the length of time needed to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

Your State Privacy Rights

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

Confirm whether we process their Personal Information.
Access and delete certain Personal Information.
Correct inaccuracies in their Personal Information, taking into account the information’s nature and processing purpose (excluding Iowa and Utah).
Data portability.
Opt-out of Personal Information processing for:

targeted advertising (excluding Iowa);
sales; or
profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).

Either limit (opt-out of) or require consent to process sensitive Personal Information.

The exact scope of these rights may vary by state. To exercise any of these rights, or to appeal a decision regarding a consumer rights request, please email us at optout@teamdms.com.

For details about your state-specific rights and any additional required disclosures, please refer to our U.S. State Privacy Rights Notice.

Changes to this Notice

From time to time, we may change this Notice to accommodate new technologies, industry practices, legal/regulatory requirements, or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our Website, or by other means, consistent with applicable law.

Comments and Questions

If you have a comment or question about this Notice, please email us at optout@teamdms.com.

Contact Information

If you have any questions or concerns about this Privacy Policy, please visit us at “Contact Us Today” or write to us at Direct Marketing Solutions, Privacy Officer, 8534 NE Alderwood Road, Portland, Oregon 97220-1347, USA.

Public Privacy Notice