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PRIVACY POLICY
TABLE OF CONTENTS
* Anteriad Data Services and Website Privacy Policy: Date of Posting: December
19, 2023
* 1. Information That We Collect and Use in Our Services
* 2. How We Use the Information
* As Part of Our Services:
* 3. How We Share Information with Third Parties, including Service Providers
* 4. Your Marketing and Opt-Out Choices
* 5. Cookies and Similar Technologies
* Cookies and How We Use Them
* Disabling Cookies
* 6. Data Collected Through Our Corporate Website
* Information Collected
* How Anteriad Uses the Information We Collect Through Our Website
* How Anteriad Shares the Information We Collect Through Our Websites
* 7. Links
* 8. Security and Data Integrity
* 9. Changes to this Privacy Policy
* 10. Storage of Information in the United States
* 11. CAN SPAM, calOPPA, CASL Acts and Your Choices and Access Rights
* 12. The GDPR and Your Choices and Access Rights With Respect to Personal Data
* 13. Data Privacy Framework/Transfer of Your Information
* Scope
* Purposes of Data Processing
* Notice
* Choice
* Onward Transfer
* Security
* Data Integrity
* Access
* Recourse, Enforcement and Liability
* 14. Data Retention
* 15. Children’s Privacy
* 16. Your California Privacy Rights
* 17. Contact Us
* ADDENDUM FOR CALIFORNIA RESIDENTS
* CALIFORNIA PRIVACY RIGHTS
* NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] – CALIFORNIA CONSUMER PRIVACY ACT
(CCPA)/ CALIFORNIA PRIVACY RIGHTS ACT (CPRA)
* 1. OUR COLLECTION OF PERSONAL INFORMATION
* 2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION
* We also may share any of the personal information we collect as follows:
* 3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION
* Our Purposes for collecting, using and sharing Personal Information
* 4. YOUR CALIFORNIA RIGHTS AND CHOICES
* A. Right to “opt-out” of the sale of your personal information
* B. Right to request access to your personal information
* C. Right to request deletion of your personal information
* D. How to exercise your access, and (if applicable) deletion rights
* E. Right to non-discrimination
* F. Information about persons under the age of 16
* G. Authorized agents
* H. NOTICE TO EMPLOYEES/APPLICANTS
ANTERIAD DATA SERVICES AND WEBSITE PRIVACY POLICY: DATE OF POSTING: DECEMBER
19, 2023
Anteriad Data Services and Website Privacy Policy
Anteriad, LLC (“We,” “Our,” “Anteriad”) provides a variety of data marketing and
consumer analytics products (the “Services”) designed to help for-profit and
not-profit organizations, and companies that work with them, to market their
goods and services in a relevant and efficient way. Our solutions, many of
which are described on this website, are used through direct mail, email,
online, connected-TV and other marketing channels.
Anteriad operates under several different brands, including but not limited
to OmniChannelBase, OmniEngine, BtoB Trends, HR Trends, TechTrends, BtoBTech
Insights, Enterprise Insights. For purposes of this Privacy Policy (“Privacy
Policy”), all such brands are collectively called “Services.”
We take seriously the privacy interests and consumer choices of the individuals
whose information we handle and maintain in our database. This Privacy Policy
describes how we collect, use and manage information, and what rights consumers
have to control how their information is used in marketing.
To review the “Addendum” we have created specifically to address disclosures
required under the California Consumer Privacy Act, please see our “CCPA PRIVACY
NOTICE.”
We also operate corporate websites, designed for our own customers and
prospective customers, and others who want to learn about our services. We
address the information we collect and use for those business purposes (such as
information we use to communicate with our corporate customers and potential
customers) in Section 6 of this Privacy Policy.
1. INFORMATION THAT WE COLLECT AND USE IN OUR SERVICES
In order to provide our Services, we receive data, including personal
information, from a variety of sources, including from websites and apps that
collect the information, public sources, and other data compilers. We refer to
the information that we collect and process throughout this Privacy Policy as
“Information” or “the Information.”
The Information often includes various contact information, such as name,
address, email address and telephone number. It also includes demographic
information about individuals. It may also include information (on the
individual, household, or wider (e.g., zip code) level), such as:
* Professional information, including occupation and job title or job history,
* Particular interests, such as (for instance) home improvement, music, online
shopping, health and beauty sport, or travel, or political leanings,
* Demographic information, such as gender, age or age range, level of education
or likely income range.
* Geolocation information, such as location coordinates tied to a device or
wifi identifier.
* Online identifiers (such as cookie or mobile ad IDs), and IP addresses
This type of information may be inferred – for instance, if a household is in a
particularly wealthy area, we might infer a particular income range.
Anteriad also receives information through this website (and any other website
we operate), and through corporate interactions and events. We describe this
information in Section 6.
2. HOW WE USE THE INFORMATION
Anteriad uses the Information for a range of purposes, including the following:
AS PART OF OUR SERVICES:
* Data Marketing Services. Our Services include providing marketing
information to our customers, generally regarding which customers or
prospective customers are most likely to be interested (or disinterested) in
certain offers. When we provide these Services, consumers may be identified
(and their information shared) in various ways, such as by household, email
address, or device identifier. Similarly, we help our customers identify and
understand their customers better, by providing insights about them.
* Online Targeting. We sometimes create defined audience segments (“Audience
Segments”) based on common demographics and/or shared (actual or inferred)
interests or preferences (e.g., households with tech professionals, or with
an interest in winter travel). When we do this, we may 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 4.
* Email Targeting. We use the infrastructure and technology of either our
Customers or our own service providers to help our Customers send and target
(and measure and analyze) their email campaigns.
* Additional Services. Other Services we may sometimes provide to our
customers (or that they may provide to their own customers), which may
overlap with or supplement the above, may involve (a) help with targeting and
optimizing direct mail, email campaigns, display, social and mobile
marketing; (b) measuring how effective marketing campaigns have been, 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; (c) analyzing and optimizing our customers’ (or their service
providers’) proprietary databases; (d) providing “validation” or data
“hygiene” services, which is how companies update and/or correct their
databases by verifying or removing or correcting old, incorrect or outdated
information or (e) providing fraud prevention and identity verification
purposes.
* To Operate Our Services. We also use the Information for our own internal
purposes – such as to improve, test, update and verify our own database;
develop new products; operate, analyze, improve and secure our Services and
our databases and servers.
3. HOW WE SHARE INFORMATION WITH THIRD PARTIES, INCLUDING SERVICE PROVIDERS
Anteriad may share the Information with customers, marketing services and
platforms, as well as service providers that help us to provide the Services
we’ve described above (or other services we may add in the future). This
includes sharing in the following ways:
* With Our Customers: Our customers include (but are not limited to) brands
and agencies and various marketing data platforms that help them to market
and advertise to their own customers (and prospective customers); our
customers also include other data compilers, who work with their own
customers. We license the Information in various ways to our customers (and
something to partners and resellers, who license the Information to their
customer), when we provide our Services. We license the Information in
various ways to our customers (and sometimes to partners and resellers, who
license the Information to their customer), when we provide our Services. We
may sometimes share the Information with those Customers’ service providers
too (for instance, a provider that prints or sends mailings or email for a
Customer) or license to the Customer for their own fraud prevention and
identity verification purposes. In such circumstances, our Customers may
include, but are not limited to, global entities engaged in payment
transaction processing, other related payment services, and multinational
Fintech and AdTech companies.
* With Email Platforms: We share our Customers’ data (but sometimes our own)
with email platforms, for the purpose of targeting, measuring, sending and
analyzing email campaigns.
* With Our Partners: We may also share the Information, including personally
identifiable information (such as contact information) and Audience Segments,
with business and data partners to help to tailor marketing and advertising
campaigns and other communications. Likewise, we may share the information
with those partners for analytical purposes, including to help those parties
measure campaign performance, inform future campaigns, or to handle, analyze,
or segregate this Information – generally on our or our customers’ behalf,
but sometimes to help those parties’ own customers.
* With Our Service Providers: We share the Information with a variety of
service providers in order to operate, protect and advertise our Services and
maintain our website(s). For instance, we may share the Information with
hosting providers, tech and customer support providers, marketing and
advertising solution vendors, other data providers (such as to enhance or
verify our Information), security providers, billing and payment vendors (as
to our business to business information), and other companies that help us
operate, improve or develop the Services.
* Corporate transfers: If Anteriad, its stock or its significant assets are
acquired by or merged into another entity, our information will be
transferred to that entity, and may be shared during due diligence in
anticipation of any such transaction.
* As required by law or to protect any person or entity: Anteriad may disclose
Information if we believe that such disclosure is necessary to (a) comply in
good faith with relevant laws or to respond to subpoenas or warrants served
on us; or (b) to protect or otherwise defend the rights, property or safety
of Anteriad, our customers, or any other person or entity.
4. YOUR MARKETING AND OPT-OUT CHOICES
There are multiple ways that you can opt-out of having the Information used to
market to you:
* First, you may contact us directly to have your personal information removed
from our database via our website privacy portal located at Form. When you
do this, please provide your current address, your email address, and any
prior home or email addresses you would like “opted out” of our marketing
databases. Or if you prefer, you can contact us directly by Email or mail,
at:
> Attn: Privacy
>
> Anteriad, LLC
>
> 2 International Drive, Suite 300,
>
> Rye Brook, NY 10573, USA
>
> Email: privacy@Anteriad.com
We will then in most cases remove your personal information from our active
marketing databases within 30 business days, from the time we received the
opt-out request. We may in certain cases (but not in most cases) require that
you verify any of the information that you submit, such as through a verified
email response or another verified response.
* If you would like to opt-out of direct mail advertising in general, we
recommend that you visit the DMA Choice website, at dmachoice.thedma.org. The
DMA Choice service is run by the Direct Marketing Association and allows you
to follow few easy steps to ensure that your marketing preferences are
honored.
* If you wish to opt out of online targeted ads (sometimes referred to as
“interest-based” or “personalized” advertising), you can also visit 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 Anteriad’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.
* If you wish to opt out of Hashed Email you can visit the opt-out
portal https://optout.networkadvertising.org/optout/email.
* To adjust your advertising preferences in iOS (version 12.4 and earlier),
visit Settings > Privacy > Advertising > Limit Ad Tracking or Settings >
Privacy > Advertising > Reset advertising ID. For version 14.5 and later,
please visit Apple Support here. To adjust your advertising preferences in
Android, visit Settings > Google > Ads > Opt out of interest-based ads or
Settings > Google Services & Preferences > Ads > Opt out of Ads
Personalization. Additionally, visit https://youradchoices.com/appchoices to
download the AppChoices Tool to control interest-based advertising on apps on
your mobile device and https://thenai.org/opt-out/mobile-opt-out for more
information and instructions on opting out on mobile device.
* If we market to you by email, in our corporate capacity – such as if you are
a customer or prospective customer of ours and we send information about our
Services — you may “unsubscribe” from our marketing emails through a link
placed in your emails.
5. COOKIES AND SIMILAR TECHNOLOGIES
COOKIES AND HOW WE USE THEM
Anteriad its business partners use certain industry-standard technologies,
including cookies and similarly functioning technologies, which we describe
below. (We and/or our service providers 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 or service providers 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 generate a generic notice of the visit and 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. When you turn off cookies, pixel
tags simply detect a given website visit.
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.
Sometimes, we work with companies that link our Audience Segments to cookies (as
also described in Section 2), in order to help companies better target (or
suppress) advertisements to consumers. This is one of type of the various
categories of advertising that are often referred to as “personalized” or
“interest-based” advertising” or “Interest-Based Advertising.” You can opt out
of this type of advertising through the industry opt-out methods described in
Section 3, which are cookie-based.
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.
6. DATA COLLECTED THROUGH OUR CORPORATE WEBSITE
INFORMATION COLLECTED
Anteriad collects information from users of our website(s) (including any page
on which this Privacy Policy is posted), including:
* The domain name and IP address of a user’s web browser, along with a time
stamp and other information about a user’s browser or device.
* Information about what content and pages users access, utilize or visit on
our website, or how they interact with our content – for instance, if they
spent a certain amount of time reviewing a particular blog post or
description of particular services.
* Information, including personally identifiable and contact information that
you provide, which could include (for instance) survey information, sign-up
information (e.g., if you sign up for events or newsletters), requests for
information, mailing addresses and email addresses.
HOW ANTERIAD USES THE INFORMATION WE COLLECT THROUGH OUR WEBSITE
We use the Information we collect through our website(s) to do the following:
* Create and manage your unique user account.
* Provide Services to you.
* Respond to and communicate with you (including regarding news and updates
about our services).
* Send you offers and ads for our products and services, when you browse the
website(s) or other companies’ websites on the Internet (such as to
“retarget” you with information about our services).
* Send you offers and ads for products and services of partner brands, or other
offers we believe may be of interest to you, such as invitations to events
and webinars.
* Perform data analysis (including market research).
* We may combine the Information with other information we obtain from third
parties, publicly available sources, and any other product or service we
provide to further improve the relevance and effectiveness of products, and
advertisements offered, including (but not limited to), those provided on or
through our services.
* We may use IP addresses to help diagnose problems with our servers and to
administer our website(s). We also may use IP addresses to help identify
visitors to our website(s) for the duration of a session and to gather
demographic information about our visitors. We may use clickstream data to
determine how much time visitors spend on each web page of our website(s),
how visitors navigate through the website(s), and how we may tailor our
website(s) to better meet the needs of our visitors. We also use this
Information for compliance with our legal obligations, policies and
procedures, including the enforcement of our Terms and Conditions.
* If we collect Information from “offline” sources – such as if you provide us
your business card at a trade show – we will maintain that information and
use it for marketing and business purposes, as well.
HOW ANTERIAD SHARES THE INFORMATION WE COLLECT THROUGH OUR WEBSITES
We may sometimes share or otherwise disclose the Information we collect about
you, as described in this Privacy Policy or otherwise disclosed to you when you
provide us with the information, including as follows:
* We may share the Information with service providers who help us deliver the
services you request or we provide. For instance, we share the Information
with tech and customer support providers, marketing and advertising
providers, other data providers (such as to enhance or verify our
Information), security and data hygiene vendors, payment vendors (as to our
business to business information), and other companies that may help us
deliver or develop Services.
* We may share the Information to communicate with you and market to you,
including through email, direct mail or display media.
* We will disclose your PII (or other Information) if we believe in good faith
that we are required to do so by law, regulation or other government
authority or to protect the rights, safety or property of ourselves or any
person or entity. We may also cooperate with law enforcement agencies in any
official investigation and we may disclose any Information to the requesting
agency in doing so.
* If we or all or substantially all of our assets, are purchased by another
company (such as in a merger, consolidation, restructuring, the sale of stock
and/or assets, or other corporate change or financing transaction), the
Information in our possession will likely be transferred to the successor
entity. We also may share the Information during the course of any due
diligence process leading up to any such transaction.
Our website(s) use cookies and similar technologies, both for its internal and
operational purposes and to market to you (such as to retarget ads to you when
you visit other sites across the Internet).
7. LINKS
This website may provide links to other websites that Anteriad thinks users will
find interesting or useful. Anteriad is not responsible for the privacy
practices of these other sites or companies.
8. SECURITY AND DATA INTEGRITY
Anteriad 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.
9. 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, unless we indicate a later
effective date. Please check back to learn of any changes to this Privacy Policy
10. STORAGE OF INFORMATION IN THE UNITED STATES
If you are accessing our website from outside of the United States, your
connection likely will be through and to servers located in the United States
and all Information you provide will likely be processed and securely maintained
in our web servers and internal systems located within the United States. (We
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).
11. CAN SPAM, CALOPPA, CASL ACTS AND YOUR CHOICES AND ACCESS RIGHTS
The CAN-SPAM Act of 2003
Anteriad upholds and adheres to The CAN-SPAM Act of 2003 which establishes
regulations for commercial email, including what information must be included in
an email message, the types of messages that are prohibited, and how to
unsubscribe from commercial emails.
The CAN-SPAM Act was passed in response to concerns about the increasing amount
of spamming and other deceptive marketing practices. The law establishes
requirements for commercial messages, gives recipients the right to have Email
Marketers stop emailing them.
CAN-SPAM contains seven requirements that Anteriad adheres to in order to avoid
unsolicited email spamming.
* Be honest and transparent in your header (including from, to, and routing
information)
* Do not be deceptive in your subject lines
* Disclose the email as an advertisement
* Provide your physical postal address in the body
* Give instructions for opting out
* Honor opt-out requests within ten business days
* Ensure processors or third parties comply with CAN-SPAM
CalOPPA
Anteriad upholds and adheres to CalOPPA and requires that any person or company
whose website collects personally identifiable information from Californian
consumers must feature a conspicuous Privacy Policy stating exactly what
information is collected and with whom it is shared. This includes tracking of
online visits for marketing purposes.
The law applies to email marketing because it requires:
* A Privacy Policy, and
* Transparency about what kinds of personal data your app or website collects
* To comply with the law’s requirements, it’s necessary to include a statement
within our Privacy Policy that we collect email addresses and whether we
share them with third parties or not.
Anteriad ensures that we provide subscribers with a means of opting out of email
marketing campaigns.
CASL
Anteriad upholds and adheres to CASL, or Canada’s anti-spam legislation,
protects consumers and businesses from misusing digital technology, including
spam and other electronic threats. It also aims to help companies stay
competitive in a global, digital marketplace.
CASL covers “Commercial Electronic Messages” (CEM), which is a bit broader than
simply applying to emails. For example, it also covers instant messages, text
messages, and social media messages that are related to commercial activities.
CASL, like the GDPR, touches on consent. Anteriad adheres to the requirements
for implied consent, such as (making a purchase, donation, gift, providing
volunteer time or resources, providing an email address, or publishing an email
address).
If Anteriad do not meet the conditions of implied consent, Anteriad obtains
express consent from subscribers. This requires either a written agreement or an
oral agreement from the subscriber stating that they consent to receive digital
communications from our or our client’s business.
If you wish to opt out of email marketing campaigns, please click here.
12. THE GDPR AND YOUR CHOICES AND ACCESS RIGHTS WITH RESPECT TO PERSONAL DATA
If you are a resident of one of many European countries, including the United
Kingdom, an important European privacy law (or an equivalent counterpart) the
General Data Privacy Regulation (the “GDPR”) provides you with certain rights,
and places certain obligations on companies, regarding how your “personal data”
(as the GDPR uses that term) is used. We describe those rights and obligations
below, and how and in what circumstances we honor them. (Please only rely on
this Section 11 if you are in fact a resident of such a country – it will not
apply otherwise.)
Legal Basis. The GDPR requires us to tell you about the legal ground we’re
relying on to process any “personal data” (as the GDPR uses that term) about
you. The legal grounds for us processing your personal data for the purposes set
out in Section 2 above will typically be because:
* You provided your (legally sufficient) consent;
* It is necessary for our contractual relationship, e.g., in order to provide
you services or features you’ve requested and we’ve promised;
* The processing is necessary for us to comply with our legal or regulatory
obligations – for instance, to communicate with you about or to help honor
your legal rights; and/or
* The processing is in our legitimate interest. For instance, we may process
and share business data (such as a person’s business email or address and job
title) in order to assist our customers to send relevant business-related
communications. (As an example, if you are a technology attorney, we might
help a privacy foundation or legal association send you an invitation to a
privacy law conference by providing or validating for them your most recent
contact information.)
Your rights. Your rights to access, correct, delete or withdraw consent. right
to request access to a copy of your personal data, or request that we correct or
“rectify,” restrict or delete Your personal data, You may exercise these rights
by contacting us at privacy@Anteriad.com or through our website privacy portal
located at Form. If you request that we delete your personal data, or withdraw
your consent, we will customarily retain a copy of your data sufficient to
suppress it from our active databases in the future: but if that is not what
you wish, you may indicate that to us (in which case your information may be
added to our database later, because we will not have “suppressed” it).
Moreover, when we delete your personal data, we may retain it (to the extent
legal permissible) for certain important (but narrow) internal purposes such as
legal, compliance, accounting or auditing purposes. Likewise, when you request
access to your information, we are required — for privacy and other important
compliance reasons — to verify your identity in a legally sufficient manner: if
we cannot do so, we will not be able to satisfy your access request.
Personalized Online Advertising Opt Outs has been amended to the
following: Personalized Online Advertising Opt-Outs. You may object to profiling
by online advertising platforms with whom we sometimes partner to help generate
(and measure or analyze) “personalized” online advertising. These platforms are
generally separate third party “controllers” of your data. You can set your
browser to refuse all or some browser cookies, or to alert you when cookies are
being sent. To learn how you can manage your Flash cookie settings, visit the
Flash player settings page on Adobe’s website. If you disable or refuse cookies,
please note that some parts of the Website may then be inaccessible or not
function properly. To opt-out of our collection and use of data for online
interest-based advertising on your browser (including a mobile browser if
third-party cookies are enabled in your browser) from companies participating in
the Digital Advertising Alliance Consumer Choice Page, please
visit www.aboutads.info/choices. To opt out of advertising solutions that tailor
ads shown within mobile apps based on your likely interests, please either set
the preference on your mobile device to limit ad tracking or download the
Digital Advertising Alliance’s AppChoices app and configure it to opt out of any
Digital Advertising Alliance participating company. For more information on this
and to opt out, please
visit www.policies.google.com/privacy, www.adssettings.google.com/ or www.optout.networkadvertising.org/.
If you are located in the European Union or European Economic Area, you can also
opt-out via the IAB Europe’s industry opt-out at www.youronlinechoices.eu.To
opt-out of the collection and use of data for interest-based advertising on your
mobile device, you can also modify the settings on your mobile device. Please
note that after choosing to opt-out via any of the methods above, if you use a
different device or a different browser, or if you delete browser cookies, you
may need to repeat the opt-out steps for that particular device or browser. In
addition, if you block cookies on your browser or if third-party cookies are
blocked by default, some of the opt-out tools above may not function.
You may unsubscribe from marketing and other communications that we may send (on
behalf of ourselves or others) by clicking the “opt-out” or “unsubscribe” link
in the footer of those emails.
Questions or Concerns. If you have a complaint or concern or question about how
we handle your personal data, please contact us as at the above contact
addresses, and we will seek to address any concerns you may have. If you are
not happy with how we have attempted to resolve your complaint, you may contact
the relevant data protection authority.
When We are a Processor. EU data protection law makes a distinction between
organisations that process personal data for their own purposes (known as “data
controllers”) and organisations that process personal data on behalf of other
organisations (known as “data processors”). Anteriad sometimes acts as a data
controller (for instance, when we make decisions about the data that comprises
our own datasets) and sometimes acts as a processor (for instance, when we
ingest information that belongs to a customer, such as a “CRM” file that we help
analyze). We generally are only able to help data subjects exercise their
rights as to data we are a data controller of. If you have a question or
request as to data we’re a processor of, you should generally address that to
the relevant data controller.
13. DATA PRIVACY FRAMEWORK/TRANSFER OF YOUR INFORMATION
Anteriad, LLC (Anteriad) complies with the EU-U.S. Data Privacy Framework
program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S.
Data Privacy Framework program (Swiss-U.S. DPF) as set forth by the U.S.
Department of Commerce. Anteriad has certified to the U.S. Department of
Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles
(EU-U.S. DPF Principles) with regard to the processing of personal data received
from the European Union in reliance on the EU-U.S. DPF and from the United
Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.
Anteriad has certified to the U.S. Department of Commerce that it adheres to the
Swiss-U.S. Data Privacy Framework program Principles (Swiss-U.S. DPF Principles)
with regard to the processing of personal data received from Switzerland in
reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in
this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF
Principles, the Principles shall govern. To learn more about the Data Privacy
Framework (DPF) program, and to view our certification, please
visit https://www.dataprivacyframework.gov/.
SCOPE
Anteriad collects, stores, transfers, and processes Personal Data in accordance
with applicable data protection law, including where it is necessary to provide
our Premium Services, to perform the Terms of Use, or to perform obligations
under contract. We may transfer your information to affiliates, partners and
other third parties as described herein. We will protect your Personal Data in
accordance with this Privacy Policy wherever it is processed.
The type of Personal Data transferred to Anteriad from the EU, the UK and
Switzerland pursuant to Data Privacy Framework consists of Personal Data from
clients in the EU, the UK and Switzerland that Anteriad processes on behalf of
its clients, such as end-user name, address, email and transaction information.
Since the requirements for compliance with Data Privacy Framework vary depending
on whether we are acting as a Processor on behalf of our clients or as a
Controller, our policies and manner of compliance are described separately
below.
The practices we employ under the EU-U.S. Data Privacy Framework, as outlined
also apply to data transferred from Switzerland to the United States in
compliance with the Swiss-US Data Privacy Framework. Anteriad will adhere to the
Data Privacy Framework Principles with respect to data transferred pursuant to
the Data Privacy Framework Principles for as long as it retains such data.
PURPOSES OF DATA PROCESSING
Anteriad acts as a data processor with respect to Personal Data we receive from
our clients and process such information only under the instruction of our
clients and are controlled by our clients in the EU, the UK and/or Switzerland.
In this capacity, we do not own or control any of the information we process on
behalf of our clients. All such information is owned and controlled by our
clients. In this capacity, we receive information transferred from the EU, the
UK and Switzerland to the United States merely as a Processor on behalf of our
clients.
Before starting any processing on behalf of our clients, we enter into a
processing contract with the Controller that ensures the Controller is in
compliance with the EU, UK General Data Protection Regulations (“GDPR”) or
Member State Data Protection law that may apply. The processing contract will
also specify that the processing will be carried out with appropriate data
security measures. We have measures in place designed to protect Personal Data
from loss, misuse, unauthorized access, disclosure, alteration and destruction.
Any data processed by us will not be further disclosed to third parties except
where permitted or required by the processing contract, Data Privacy Framework,
GDPR, or the applicable Member State Data Protection law. Any information our
client (acting as the Controller) identifies as sensitive, will be treated
accordingly.
When Anteriad provides business and consumer information products, we act as a
Controller of the Personal Data contained in the information products. As a
Controller, we share Personal Data with third parties that fall into various
categories: clients, vendors and partners. Our clients include but not limited
to financial, retail, insurance, and automotive companies. Our vendors include
data suppliers and service providers. We also share Personal Data with partners
such as other data resellers for marketing purposes and to our Customers (which
may include, but are not limited to, global entities engaged in payment
transaction processing, other related payment services, and multinational
Fintech and AdTech companies) for their own fraud prevention and identity
verification purposes/services. When we act as a Controller of Personal Data,
the policies outlined apply to all Personal Data that has been transferred from
the EU, the UK or Switzerland to the United States.
Anteriad and its affiliates located in the EU, the UK or Switzerland, develop
and maintain Personal Data on data subjects, households, and businesses located
throughout EU Member States, the UK or Switzerland. This information is obtained
from public records, publicly available information, information acquired
through information providers, and information collected directly from data
subjects.
This information is provided to qualified businesses for marketing, customer
data integration, and connectivity purposes. This information may also be used
to provide information services, enhance the understanding a company has about
its customers, aid in accurate integration of a company’s customer information,
and be used as lists for direct marketing purposes and fraud prevention and
identity verification purposes.
NOTICE
We may be required to disclose Personal Data in response to lawful requests by
public authorities, including requests to meet national security or law
enforcement requirements. Prior to the transfer of Personal Data from the EU,
the UK or Switzerland to the United States, we require contractual confirmation
from the Controller from whom we acquired the information that the Personal Data
has been provided to us in accordance with GDPR, Data Privacy Framework, or the
applicable EU Member State Data Protection law, thereby ensuring the data
subjects have been provided with proper notice regarding how their Personal Data
will be used. In addition, when Personal Data is collected directly from data
subjects, we provide the data subject with notice regarding the manner and
circumstances in which the Personal Data will be used and transferred to third
parties.
CHOICE
We provide choices and means for individuals to limit the use of their Personal
Data. In addition to providing individuals with choices regarding our use of
their information, we will remove an individual’s name and related information
from our direct marketing information products if they request it. Consumers may
request an opt-out form by writing Anteriad at the address below, sending an
e-mail to us at privacy@Anteriad.com or via a Form.
To request an opt-out form by mail, write to:
Privacy Officer
EU-US Data Privacy Framework Opt-Out
Anteriad LLC
2 International Drive, Rye Brook, New York NY10573
ONWARD TRANSFER
Since we share Personal Data with third parties as referenced above, we comply
with the notice and choice principles as described above for all data disclosed
or transferred to a third party. We take reasonable and appropriate steps
designed to ensure that the third party effectively processes the Personal Data
transferred in a manner consistent with our obligations under the Principles.
When we use data processors to perform processing tasks on our behalf and at our
direction and instruction, we require our data processors either:
* • Subscribe to the Data Privacy Framework (in the case of US-based
processors), comply with the General Data Protection Regulations (in the case
of EU, UK or Switzerland -based processors), or another adequacy finding (in
the case of processors in countries outside the US, EU, UK, or Switzerland);
or
* • Enter into a written agreement with us requiring the data processor(s) to
process the data only for limited and specified purposes and to provide the
same level of protection as Anteriad.
In cases of onward transfer to third parties, we may be liable for the acts of
the third party that are in violation of the Data Privacy Framework Principles.
SECURITY
We have an information security policy in place designed to protect Personal
Data from loss, misuse, unauthorized access, disclosure, alteration, and
destruction. Our Chief Information Security Officer is primarily responsible for
conducting investigations into any alleged computer or network breaches,
incidents or problems and ensuring that proper disciplinary action is taken
against those who violate our Information Security Policy.
DATA INTEGRITY
We take reasonable steps designed to ensure the information transferred from the
EU, the UK or Switzerland to the United States is reliable, accurate, and
complete. The steps we take to assure data integrity are based on the purposes
for which the Personal Data is used.
ACCESS
An individual may request access to the Personal Data processed pursuant to the
Data Privacy Framework we maintain in our information products. Individuals have
the right to learn whether data about him or her is found in our information
products and to correct, amend or delete that information when it is inaccurate.
This right applies only to Personal Data about the individual making the request
and is subject to other limitations as defined by law. Individuals can request
access by writing or sending an email request to privacy@Anteriad.com.
Privacy Officer
Anteriad LLC
3 International Drive
Rye Brook, New York NY10573
Anteriad’s Privacy Officer will explain the process for making an access
request. In order to confirm the identity of the individual and the necessary
information to retrieve the individual’s information, Anteriad’s Privacy Officer
will provide a form for the individual to fill out, sign, and return to
Anteriad.
We agree to process all reasonable requests for access within a reasonable time
period but reserve the right to deny access or limit access in cases where the
burden or cost of providing access would be disproportionate to the risks to the
individual’s privacy or when the request is manifestly unfounded or excessive.
RECOURSE, ENFORCEMENT AND LIABILITY
We have Annual Data and IT Security Awareness Certification requirements for
each of our employees. This training includes our Data Privacy Framework
compliance program implementation. Our employee policies contain clear
statements that training and annual refresher courses in our privacy practices,
including our participation in the Data Privacy Framework, are required and
failure to complete such training and annual refresher courses may result in
discipline up to and including termination. Part of this program includes a
certification log which provides an objective review of employee compliance with
our Data Privacy Framework certification training.
Individuals who wish to make inquiries, file a complaint, or who take issue with
our Data Privacy Framework practices or policies as described herein should
contact Anteriad’s Privacy Officer at privacy@Anteriad.com.
Anteriad’s Privacy Officer will explain the process to be followed when filing a
complaint.
We are subject to the investigatory and enforcement powers of the U.S. Federal
Trade Commission. In addition, we agree to cooperate with local EU Data
Protection Authorities or the Swiss Federal Data Protection and the UK
Information Commissioner to resolve a dispute concerning an alleged breach of
the Data Privacy Framework Principles.
In compliance with the EU-US Data Privacy Framework (EU-US DPF), the UK
Extension to the EU-US DPF Principles, Anteriad commits to resolve complaints
about your privacy and our collection or use of your personal information
transferred to the United States pursuant to the DPF principles. European Union,
Swiss and United Kingdom individuals with DPF inquiries or complaints should
first contact Anteriad at: Privacy@anteriad.com
Anteriad has further committed to refer unresolved privacy complaints under the
DPF Principles to an independent dispute resolution mechanism, Data Privacy
Framework Services, operated by BBB National Programs. If you do not receive
timely acknowledgment of your complaint, or if your complaint is not
satisfactorily addressed, please
visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for
more information and to file a complaint. This service is provided free of
charge to you.
If your DPF complaint cannot be resolved through the above channels, under
certain conditions, you may invoke binding arbitration for some residual claims
not resolved by other redress mechanisms.
See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2.
14. DATA RETENTION
Anteriad retains the non-personal user data we collect for all of our products
and services for purposes of interest-based advertising for up to thirteen (13)
months from the date of its collection.
We will also only retain your personal data for as long as we believe it is up
to date, i.e. as long as it is associated with a business that is included in
our database. We verify our data periodically and if we learn that you are no
longer involved with a business that is in our database, we will remove your
data from our records.
Customer Data We will retain this information for as long as needed to provide
services to any one of our customers or as otherwise authorized, directed, or
permissioned by our Customers. In addition, Anteriad will retain this personal
information as necessary to comply with our legal obligations, resolve disputes,
and enforce our agreements. In the event we are processing data for our
Customer, we will take Client instruction.
Other Data We will retain this information for the duration of our business
relationship and afterwards for as long as is necessary and relevant for our
legitimate business purposes, in accordance with permitted applicable laws and
regulation. Where we no longer need your personal information, we will dispose
of it in a secure manner (without further notice to you).
15. CHILDREN’S PRIVACY
Children Under the Age of 16
Our Website is not intended for children under 16 years of age. No one under age
16 may provide any information to or on the Website. We do not knowingly collect
personal information from children under 16. If you are under 16, do not use or
provide any information on this Website or on or through any of its features. If
we learn we have collected or received personal information from a child under
16 without verification of parental consent, we will delete that information. If
you believe we might have any information from or about a child under 16, please
contact us at privacy@anteriad.com.
California residents under 16 years of age may have additional rights regarding
the collection and sale of their personal information. Please
see your-california-rights for more information.
16. YOUR CALIFORNIA PRIVACY RIGHTS
If you are a resident of California, the California Consumer Protection Act
(CCPA)/California Privacy Rights Act (CPRA) provides certain rights of
disclosure, access and deletion of your Information as described below in the
“Addendum for California Residents” at the end of this Privacy Policy.
17. CONTACT US
Anteriad has a designated privacy contact. If you have questions related to
this Privacy Policy, or regarding our products or services, please contact us:
Attn: Privacy Officer
Anteriad, LLC
2 International Drive, Suite 300,
Rye Brook, NY 10573, USA
Email: privacy@Anteriad.com
We appreciate your comments and questions regarding Anteriad’s privacy
practices.
———————————————————————
ADDENDUM FOR CALIFORNIA RESIDENTS
CALIFORNIA PRIVACY RIGHTS
NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] – CALIFORNIA CONSUMER PRIVACY ACT
(CCPA)/ CALIFORNIA PRIVACY RIGHTS ACT (CPRA)
Pursuant to the California Consumer Privacy Act (“CCPA”), California Privacy Act
(“CPRA” and together with the CCPA, “CCPA/CPRA”) and other California privacy
laws, we are providing the following information to visitors, users, and other
who reside in the State of California (“consumers” or “you). This Addendum
supplements the information in the Privacy Policy. However, this Addendum is
intended solely for, and is applicable only as to, California Consumers: if you
are not a California Consumer (or a resident of California), this does not apply
to you, and you should not rely on it.
In the below tables and sections, we describe (as required by the CCPA/CPRA):
1. Our Collection of Personal Information – the types of Personal Information
(which the CCPA/CPRA defines broadly) that we collect, the types of sources
we collect it from,
2. Our Disclosure and Sale of Personal Information – the types of recipients to
whom we disclose or sell Personal Information.
3. Our Business Purposes – our business purposes for (a) collecting and (b)
sharing Personal Information, which are generally the same.
4. Your California Privacy Rights and Choices – what rights you have under the
CCPA/CPRA, for instance, to request that we “opt out” your information from
our marketing database (also called “do not sell” rights), or to request
categories and personal information that we may have collected about you.
The following sets forth the categories of information we collect and purposes
for which we may use California Consumers’ personal information:
1. OUR COLLECTION OF PERSONAL INFORMATION
Depending on how you interact with us, we may collect about you the categories
of information summarized in the table below. The following table also describes
how we collect and use such categories of information.
Category
Categories of Sources
Identifiers, e.g., name; alias; postal address; mobile ad identifiers; IP
address; telephone number; email address; social network handles
* Data compilers and consumer data resellers, informational and retail websites
(“Commercial Source Categories”)
* Public records and other publicly available sources
* Government entities
* Social networks
Characteristics of protected classifications under California or US law
(inferenced or actual, including self-reported)
E.g., race; color; religion; sex/gender; pregnancy, marital status; military or
veteran status; national origin; ancestry; age (over 40) (may be inferenced,
actual or self-reported)
* Commercial Source Categories
* Public records and other publicly available sources
* Government entities
* Social networks
Commercial or transactions information
E.g., products or services purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies.
* Commercial Source Categories
* Public records and other publicly available sources
Internet or other electronic network activity information
E.g., browsing history; online interests.
* Commercial Source Categories
Geolocation data
* Commercial Source Categories
Professional or employment-related information
E.g., current or past job history or job title.
* Commercial Source Categories
* Public records and other publicly available sources
Inference Data
E.g., consumer information or preferences.
* Commercial Source Categories
2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION
We will share the information collected from and about you as discussed above
for various business purposes, with service providers and with third parties
including our customers. The chart below how and with whom we share or disclose
personal information, and whether (based on the CCPA/CPRA’s definition of
“sell”) we believe we have “sold” a particular category of information in the
prior 12 months.
Category
Categories of Third Parties We Share With
Whether We “Sold” This Category of Personal Information in the Last 12 Months
Identifiers, e.g., name; alias; postal address; mobile ad identifiers; IP
address; telephone number; email address; social network handles
* Data compilers and consumer data resellers, consumer goods retailers,
informational and retail websites, content publishers, non-profit
organizations, business-to-business services and organizations, consumer
surveys and survey companies, affiliate networks (“Commercial Recipient
Categories”)
* Advertising networks and media platforms, political campaigns, internet
service providers, data analytics providers
* Social networks
Yes
Characteristics of protected classifications under California or US law
(inferenced or actual)
E.g., race; color; religion; sex/gender; pregnancy, marital status; military or
veteran status; national origin; ancestry; age (over 40) (may be inferenced,
actual or self-reported)
* Commercial Recipient Categories
* Advertising networks and media platforms, political campaigns, internet
service providers, data analytics providers
* Social networks
Yes
Commercial or transactions information
E.g., products or services purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies.
* Commercial Recipient Categories
* Advertising networks and media platforms, political campaigns, internet
service providers, data analytics providers
* Social networks
Yes
Internet or other electronic network activity information
E.g., browsing history; online interests.
* Commercial Recipient Categories
* Advertising networks and media platforms, political campaigns, internet
service providers, data analytics providers, and social networks
Yes
Professional or employment-related information
E.g., current or past job history or job title.
* Commercial Recipient Categories
* Advertising networks and media platforms, political campaigns, internet
service providers, data analytics providers
* Social networks
Yes
Inference Data
E.g., consumer information or preferences.
* Commercial Recipient Categories
* Advertising networks and media platforms, political campaigns, internet
service providers, data analytics providers
* Social networks
Yes
Location data
* Geolocation information, e.g., tied to a device identifier.
No
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 customers, our agents and
affiliates, its users and/or the public. We likewise may provide information to
other companies (which may include, but are not limited to, global entities
engaged in payment transaction processing, other related payment services, and
multinational Fintech and AdTech companies) and organizations (including law
enforcement) for their own fraud protection and identification verification 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 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.
Sharing of Aggregate 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.
3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION
Generally speaking, we collect and share the Personal Information that we
collect for the following purposes, as we also have described in our Privacy
Policy and/or our website.
OUR PURPOSES FOR COLLECTING, USING AND SHARING PERSONAL INFORMATION
Data marketing services, for example:
* Generally, creating data marketing tools and products for our marketer
clients, as more fully described in our Privacy Policy (and on our
websites). This includes our provision of datasets, data “appends”
(connecting data across datasets), data “scoring” (providing inferences about
potential consumer behavior), data hygiene services (helping customers to
evaluate, validate and correct personal information they hold), and security
and anti-fraud services (helping customers to identify potentially fraudulent
activity).
* Helping our Clients identify and understand their consumers better, by
providing insights about them and managing loyalty programs, as well as
providing financial and other scoring products.
* Assisting our Clients through our Services to provide their current and
prospective customers with better service, improved offerings, and special
promotions, for instance, advising on which current or prospective customers
are most likely to be interested (or disinterested) in certain offers.
Online targeting, for example:
* Creating or helping to create 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 or other 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.
* Assisting Clients in creating “identity” graphs, to help locate users across
various channels, such as based on common personal, device-based, or
network-based identifiers (e.g., IP address, email address).
Additional marketing services, for example (which may overlap with “data
marketing services” above):
* 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
Operating our Services, for example:
* Improving, testing, updating and verifying our own database.
* Developing new products.
* Operating, analyzing, improving, and securing our Services.
Other internal purposes, for example:
For internal research, internal operations, auditing, detecting security
incidents, debugging, short-term and transient use, quality control, and legal
compliance.
We sometimes use the information collected from our own website, from social
networks, from other “business to business” interaction (such as at trade shows)
or from data compilers for the above, as well as for our own marketing purposes.
4. YOUR CALIFORNIA RIGHTS AND CHOICES
Without being discriminated against for exercising these rights, California
residents have the right to request that we disclose what personal information
we collect from you, to delete that information, and to opt-out of the sale of
your personal information, subject to certain restrictions. You also have the
right to designate an agent to exercise these rights on your behalf. This
section describes how to exercise those rights and our process for handling
those requests. (To the extent permitted by applicable law, we may charge a
reasonable fee to comply with your request.)
Sometimes, we act only as a “service provider” to our clients (for instance, if
they provide information to us for analytics, processing or other data
management services), in which case any consumer requests for opt-out, deletion
or access to data must be made through that client: we will forward any such
requests to a named client, as feasible, but we recommend making any requests
directly to the company you wish to direct the request to.
A. RIGHT TO “OPT-OUT” OF THE SALE OF YOUR PERSONAL INFORMATION
California residents may opt out of the “sale” of their personal information.
California law broadly defines what constitutes a “sale” – including in the
definition making available a wide variety of information in exchange for
“valuable consideration.”
Depending what information we have about you, and whether we have included any
of it in our marketing products and services, we may have sold (as defined by
California law) certain categories of information about you in the last 12
months, as described in the above table in Section II of this Addendum,
titled OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION.
B. RIGHT TO REQUEST ACCESS TO YOUR PERSONAL INFORMATION
California residents have the right to request that we disclose what categories
of your personal information that we collect, use, or sell. As explained in
Section (D) below, you may also request the specific pieces of personal
information that we have collected from you. (We may withhold some personal
information where the risks are too great to permit disclosure of the
information.)
C. RIGHT TO REQUEST DELETION OF YOUR PERSONAL INFORMATION
As explained further in Section (D) below, you may also request that we delete
any personal information that we collected from, such as if you have been a
customer of ours. (Note that this is different from your right to “opt out” of
us selling your personal information, which is described below; also note that
we do not generally collect personal information directly from consumers.)
However, we may retain personal information for certain important purposes, such
as (a) to protect our business, systems, and users from fraudulent activity, (b)
to address technical issues that impair existing functionality (such as
de-bugging purposes), (c) as necessary for us, or others, to exercise their free
speech or other rights, (d) to comply with law enforcement requests pursuant to
lawful process, (e) for scientific or historical research, (f) for our own
internal purposes reasonably related to your relationship with us, or to comply
with legal obligations. Additionally, we need certain types of information so
that we can provide our Services to you. If you ask us to delete it, you may no
longer be able to access or use our Services.
D. HOW TO EXERCISE YOUR ACCESS, AND (IF APPLICABLE) DELETION RIGHTS
Access: California residents may exercise their California privacy rights by
sending an email to privacy@Anteriad.com, submitting their removal request
through our form, or by contacting us at 1-800 368 7602.
Because it is required by California law (and also, for security purposes), we
will verify your identity – in part by requesting certain information from you
or by requesting you demonstrate possession of a particular identification
method (such as an email account) — when you request to exercise your California
privacy rights. For instance, if you request categories or specific pieces of
personal information we have received about you, you may need to confirm your
possession of such an identifier (such as an email address) or to provide a
piece of identification that confirms you are the person you claim to be.
Once we have verified your identity, we will respond to your request as
appropriate:
* Where you have requested the categories of personal information that we have
collected about you, we will provide a list of those categories.
* Where you have requested specific pieces of personal information, we will
provide the information you have requested, to the extent required under the
CCPA/CPRA and provided we do not believe there is an overriding privacy or
security concern to doing so.
Deletion: Where you have requested that we delete personal information that we
have collected from you, we will seek to confirm whether your request is for an
“opt out” or a “deletion”: because “opt out” or “do not sell” rights enable us
to maintain your information for “suppression” purposes – i.e., to prevent us
from selling information about you in the future (which is what many consumers
requesting “deletion” actually desire to occur), we try to explain this in order
to ensure we are meeting consumers’ preferences. (In addition, “deletion”
rights only apply to information that we have collected “from” consumers – which
does not apply to much of the information in our databases.)
E. RIGHT TO NON-DISCRIMINATION
We do not deny to you, charge different prices for, or provide a different level
of quality of goods or services to you, if you choose to exercise these rights.
F. INFORMATION ABOUT PERSONS UNDER THE AGE OF 16
We do not knowingly collect personal information from minors under 16 years of
age in California unless we have received legal consent to do so. If we learn
that personal information from such California residents has been collected, we
will take reasonable steps to remove their information from our database (or to
obtain legally required consent).
G. AUTHORIZED AGENTS
You may also designate an agent to make requests to exercise your rights under
CCPA/CPRA as described above. We will take steps both to verify the identity of
the person seeking to exercise their rights as listed above, and to verify that
your agent has been authorized to make a request on your behalf through
providing us with a signed written authorization or a copy of a legally
sufficient power of attorney. We likewise may require that you verify your own
identity, depending on the type of request you make.
H. NOTICE TO EMPLOYEES/APPLICANTS
As you have self-reported that you are a resident of California, we are serving
notice that the Company collects and retains certain information about you.
California’s Consumer Privacy Act (“CCPA”) and California Privacy Rights Act
(“CPRA”) provides California employees and applicants with certain rights:
* Knowledge of information collected;
* Deletion of information collected;
* Opt-out of information collected;
* Opt-in of information collected;
* Correction of information collected;
* Go to court;
* Limit use of information collected;
* Not to be discriminated or retaliated against for exercising rights under the
law.
Where We Get Your Information From. The Company collects information about you
from the following sources: 1) you; 2) prior employers, references, recruiters,
job-related social media platforms; 3) third-party sources of demographic
information; 4) third-party companies, such as background check companies; and
5) claim administrators and investigators. Depending on the Company’s
interactions with you, we may or may not collect all of the information
identified about you.
The Personal and Sensitive Personal Information That We Are Collecting. We are
collecting the following information:
* Identifiers, such as name, government-issued identifier (e.g., Social
Security number), and unique identifiers (e.g., employee ID);
* Personal information, such as legal name, signature, SSN, physical
characteristics or description, address, telephone number, passport number,
driver’s license or state identification card number, passport number,
federal identification authorizing work in the United States, access and/or
passcodes, insurance policy number, education, employment, employment
history, bank account number, other financial information, medical
information, or health insurance information;
* Characteristics of protected classifications under California or federal law,
such as age, marital status, gender, sex, race, color, disability,
citizenship, primary language, immigration status, military/veteran status,
disability, request for leave, and medical conditions;
* Commercial information, such as transaction information and purchase history
(e.g., in connection with travel or other reimbursements);
* Internet or network activity information, such as browsing history and
interactions with our online systems and websites and any personal
information that you provide while accessing the Company’s computer systems,
such as personal credit card information and passwords;
* Geolocation data, such as device location from usage of the Company’s
devices;
* Biometric information related to access to the Company’s secured access
points;
* Audio, electronic, visual, and similar information;
* Professional or employment-related information, such as work history and
prior employer;
* Non-public education information; and
* Inferences drawn from any of the Personal and Sensitive Personal Information
listed above to create a profile or summary about, for example, an
individual’s preferences and characteristics.
How Your Personal and Sensitive Personal Information is Used. We may use
Personal and Sensitive Personal Information:
* To operate, manage, and maintain our business;
* For hiring, retention, and employment purposes;
* To otherwise accomplish our business purposes and objectives, including, for
example:
* Emergency services;
* Conducting research, analytics, and data analysis;
* Maintaining our facilities and infrastructure;
* Quality and safety assurance measures;
* Conducting risk and security controls and monitoring;
* Protecting confidential and trade secret information;
* Detecting and preventing fraud;
* Performing identity verification;
* Performing accounting, audit, and other internal functions, such as
internal investigations;
* Complying with the law, legal process, and internal policies;
* Maintaining records;
* Claims processing;
* Responding to legal requests for information and subpoenas; and
* Exercising and defending legal claims.
* Any other purposes authorized by the California Privacy Protection Agency,
California or Federal law.
We may or may not have used Personal and Sensitive Personal Information about
you for each of the above purposes.
Sharing of Personal Information. We only share your information with the
following current third-party entities:
* US payroll provider (ADP)
* Health & welfare benefit registration platform (Employee Navigator)
* Health & welfare benefits insurance broker (IMA)
* Employee benefit carriers (UnitedHealthcare, Optum, Unum, Advanced Benefit
Strategies)
* 401(k) plan recordkeeper (Principal)
* 401(k) plan third party administrator (Prime Pensions, Inc.)
* 401(k) plan advisor (Pallas Capital Advisors)
* Applicant Tracking System (Greenhouse)
* Corporate Learning Management System (Cornerstone)
* Legacy Performance Review System (Darwinbox)
* Employee Travel & Expense Platform (Emburse Certify)
* Corporate Intranet (Jostle)
* Background Screening Services (Good Hire/Checkr, HireRight)
* Email Licensing Platform (Microsoft)
* Telephone Extension Service (OneBox)
* Lenders for Employment Verifications (Employee Selected and Authorized)
The Company may also use other third-party companies to operate, manage and
maintain our business.
Selling of Personal Information. The Company DOES NOT sell your personal
information.
Data Retention. The Company retains the information it receives about you for a
period of seven (7) years, unless a shorter or longer period is required by
California or Federal law.
For Inquiries and/or to Submit Requests for Information, Deletion or Correction.
Please contact Heather Buxton, Chief People Officer,
914-368-1112, hbuxton@anteriad.com, 2 International Drive, Rye Brook, NY 10573
for inquiries about the Company’s policy, or to submit your requests for
information, deletion or correction.
For more information, about Data that the Company collects, stores and
transfers, please refer to the Company’s Privacy Policy.
Anteriad respects your privacy and strives to uphold all applicable privacy laws
in our business relationship with you.
2 International Drive
Rye Brook, New York 10573
914-368-1000
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