Last updated August 4, 2018
Alliance Data Privacy Solutions, Inc. (hereinafter “ADPS”, “We”, “Us” or “Our” and includes our affiliated companies) is concerned about personal privacy and is committed to protecting the privacy of visitors to our websites and subdomains (our “Sites”). This Privacy Policy identifies the personally identifiable information that ADPS collects about you at our Sites and describes how ADPS uses and protects such information. It also describes the choices available to you regarding our use of your personally identifiable information (“Personal Information”) and how you can access and update this information.
The Information We Collect About You
We collect information directly from individuals online, as well as automatically through the use of our Sites.
Information Collected Directly
We may collect Personal Information about you directly from you. For example, Personal Information may be collected when you fill out a ‘Contact Us’ form, sign up for our mailing lists, post comments on our blogs, or otherwise provide us information through the Sites. Generally, the information we collect includes your:
- Name, employer name, and your title or position,
- Phone number
- Email address
- Mailing address and contact details, and
- Other information related to your request or inquiry.
Automatically-Collected Information
When you visit our Sites, we may automatically collect information that does not reveal your identity directly but may include information about the specific device you are using, such as the hardware model, operating system version, web-browser software (Firefox, Safari, Internet Explorer, etc.) and your Internet Protocol (“IP”) address/MAC address/device identifier, general location information, domain name, page views, a date/time stamp, and Internet service provider (“ISP”). In some countries, including the European Economic Area, this information may be considered Personal Information under applicable data protection laws.
For more information, see the “Cookies” section below.
Our Use of Personal Information
We use the Personal Information you provide to respond to your request or inquiry and in the ordinary course of conducting our business. Generally, we use the information (including Personal Information) that we collect online as follows:
- to provide you with services and support;
- to provide and operate our Sites;
- to respond to your requests or provide information requested by you;
- to manage your account;
- to communicate with you about your use of the Sites and to process your payments;
- to obtain and understand your feedback or user experience;
- to better understand our customers and the way they use and interact with our Sites;
- to improve service reliability or improve features and functionality;
- to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks;
- to provide you with marketing and promotional communications (where this is in accordance with the law, and subject to you opting-in);
- to determine the effectiveness of marketing and promotional campaigns;
- to post testimonials (with your prior consent);
- to interact with you on third party social networks (subject to that network’s terms of use);
- to comply with the law or legal proceedings (for example, we may disclose information in response to subpoenas, court orders, and/or other lawful requests by regulators and/or law enforcement, including responding to national security or law enforcement disclosure requirements); and
- where necessary, for the administration of our general business, accounting, recordkeeping and legal functions.
Disclosure of Personal Information
We will not rent or sell your Personal Information, nor will we share it with third parties, outside of ADPS, for their marketing purposes.
We may share Personal Information with the following categories of third parties:
- third party service providers that provide services to us or to whom we outsource certain services, such as data hosting or software or technology services;
- our professional advisers, such as lawyers and accountants;
- government and/or regulatory authorities;
- professional indemnity insurers; and
- regulators, tax authorities and/or corporate registries.
In addition, we may disclose Personal Information to other third parties under the following circumstances:
- as part of any merger, sale and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, including related to due diligence conducted prior to such event where permitted by law;
- for any purpose with your consent; and
- if we are required to do so by law (for example, to law enforcement, courts or others, in response to subpoenas, court orders, and/or other lawful requests).
We may also share information with third parties for research, marketing, analytics and other purposes, provided such information is anonymized or pseudonymized.
Cookies
Cookies are small files that a site transfers to your computer’s hard drive through your web browser (if you allow) that enables it to recognize your browser and capture and remember certain information. A cookie cannot read data off of your hard drive or read cookie files created by other sites. Cookies may do things like allow you to navigate faster through the site, remember your preferences and passwords, and generally improve the user experience. You can turn off the ability to receive cookies by adjusting your browser settings. Please note that turning off the ability to receive cookies may affect the functionality of our Sites and the information you can access through it.
We use cookies to compile aggregate data about traffic and interaction on our Sites so that we can offer better experiences and content in the future. We use third-party companies, such as Google Analytics, to assist us in understanding our site visitors.
We do not share with these third parties any information that would readily identify you (such as email address); however, these third parties may have access to information about your device (such as IP or MAC address). We do not have access to, or control over, the technologies that these third parties may use to collect information about your interests, and the information practices of these third parties are not covered by this Privacy Policy. Other than as discussed in this document, we have no control over these third parties.
Our Cookie Policy contains further information about our use of cookies.
Marketing
As noted, we may send periodic promotional emails to you, and where required by law, we will obtain your consent to do so. You may opt out of such communications at any time by following the opt-out instructions contained in the email or email us at [email protected]. If you opt out of receiving marketing emails from us, we may still send you emails about your account or any services you have requested or received from us.
International Transfers of Information
We are based in the United States and the information we collect is governed by United States law. Our databases are located within the United States. If you access our Services from outside the United States, by providing data to us, you consent to transfer, processing, and storage of that data in the United States. Data protection laws in the United States and other jurisdictions may be different from those of your country of residence. If your data is collected in the EU, we will transfer your Personal Information subject to suitable safeguards, such as standard contractual clauses.
Your Privacy Rights
The laws in certain jurisdictions (such as the EU and California) provide you with rights concerning your Personal Information. We honor the following rights:
- your right to access, rectify, or erase any Personal Information we have collected about you through the Sites;
- your right to data portability;
- your right to restrict or object to our processing of Personal Information we have collected about you;
- your right to ask us not to process your Personal Information (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you.
You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
If you would like to review the Personal Information we have collected about you via the Sites, you may do so by submitting a request by sending an email to [email protected].
We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity.
To request deletion of your Personal Information, you may do so by submitting a request by sending an email to [email protected].
Please note that we store information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, you have the right to lodge a complaint with a European supervisory authority.
California Privacy Rights
California Civil Code section 1798.83 requires us to disclose to our California customers, upon request, the identity of any third parties to whom we have disclosed Personal Information within the previous calendar year, along with the type of Personal Information disclosed, for the third parties’ direct marketing purposes. Please note that under California law, we are only required to respond to a customer request once during any calendar year.
In addition, California Business and Professions Code Section 22581 requires that we allow California residents under age 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted. Such requests should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
If you are a California resident and would like to make either type of request described above, please contact us at [email protected], or by mail to:
Privacy Request⋅ Alliance Data Privacy Solutions, Inc. ⋅ 2305 Historic Decatur Rd., Suite 100 ⋅ San Diego, CA 92106
Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we take steps to remove that information from our servers.
Third Party Websites and Links
Our Site contains links to other sites whose information practices may be different than ours. Visitors should consult the other sites’ privacy notices as we have no control over information that is submitted to, or collected by, these third parties.
Data Security
We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, no physical or electronic security system is impenetrable. We cannot guarantee the security of our servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us or our third-party service providers over the internet.
How to Contact Us
If you have any questions or concerns about the Privacy Policy for ADPS or its implementation, you may contact us at [email protected]. If at any time you decide that we should no longer hold any of your Personal Information, or you wish to change the use to which any such information can be put, please let us know by emailing us at [email protected].
Revisions to Our Privacy Policy
We reserve the right to revise this Policy or any part of it from time to time. Please review the Policy periodically for changes. If we make material changes, we will endeavor to provide notice ahead of such changes, such as by email or through a notice on www.alliancedataprivacy.com.