EU-US and Swiss-US Privacy Shield Policy
Infogroup recognizes that the EU and Switzerland have established certain protections regarding the handling of EU Personal Data and Swiss Personal Data, including requirements to provide adequate protection for EU Personal Data transferred outside of the EU, and Swiss Personal Data transferred outside of Switzerland. To provide adequate protection for certain EU Personal Data and Swiss Personal Data about corporate customers, clients, suppliers, and business partners received in the US, Infogroup has elected to self-certify to the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework, collectively administered by the US Department of Commerce (collectively, “Privacy Shield”). Infogroup has an affirmative commitment to comply with the Privacy Shield Framework, and it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability
For purposes of enforcing compliance with the Privacy Shield, Infogroup is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov. To review Infogroup’s representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: https://www.privacyshield.gov/list.
Personal Data Collection and Use, Including Data Transfers Received From Third Parties
• to fulfill marketing communications; and
• performing analytics and reporting requirements as determined by our clients
We may receive certain Personal Data directly from our clients or receive Personal Data directly from end users, as agreed upon between Infogroup and our clients. The types of Personal Data processed for these purposes include:
• Names and email addresses; and
• End user behavioral data in connection with their interaction with the communications using pixels and similar technologies.
As part of providing its services, Infogroup may also collect CRM Data fields that we process about the employees of our clients for relationship management purposes including name, company email address, and role. Infogroup may also collect EU Personal Data in regard to human resources (“HR”) with respect to our employees based in the EU. Infogroup will only access and use EU Personal Data and Swiss Personal Data in ways that are compatible with the purposes for which Infogroup, or its contractual third parties, collected it, or for purposes the individual later authorizes. Before we use your EU Personal Data or Swiss Personal Data for a purpose that is materially different than the purposes for which we collected it, or for other purposes for which you provided it to our contractual third parties, or that you later authorized, we will provide you with the opportunity to opt out. Infogroup maintains reasonable procedures to help ensure that EU Personal Data or Swiss Personal Data is reliable for its intended use, accurate, complete, and current.
Data Transfers to Third Parties
Third-Party Agents or Service Providers. We do transfer EU Personal Data or Swiss Personal Data to certain third-party agents or service providers with whom we have entered written agreements and which agreements addresses data privacy and security policies and procedures that requires all contractual parties to ensure that your EU Personal Data or Swiss Personal Data is protected with the same level of protection the Privacy Shield requires. These third parties may fall within the following categories:
• Storage solutions
• Campaign management tools
• Data hygiene services
• Website tracking, content creation, data management, and reporting
• Email rendering and testing
• API management
• Employee and customer training modules
• Web production
• Quality Assurance
We also may transfer your EU Personal Data or Swiss Personal Data to one of our affiliated entities within our corporate group, when we have taken steps to ensure that your EU Personal Data or Swiss Personal Data is protected with the same level of protection the Privacy Shield requires. In cases of onward transfer to third parties of EU Personal Data or Swiss Personal Data that is received pursuant to the EU-US Privacy Shield, Infogroup may be potentially liable in certain circumstances.
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your EU Personal Data or Swiss Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
Infogroup maintains reasonable and appropriate security measures to protect EU Personal Data and Swiss Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
You may have the right to access the EU Personal Data or Swiss Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EU Personal Data or Swiss Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Questions or Complaints
You can direct any questions or complaints about the use or disclosure of your EU Personal Data or Swiss Personal Data to us at PrivacyTeam@Infogroup.com. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EU Personal Data or Swiss Personal Data within 45 days of receiving your complaint. If you are unsatisfied with the resolution of your complaint, please contact the independent recourse mechanism listed below:
|HR RECOURSE MECHANISM
EU Data Protection Authorities (DPAs)
|NON-HR RECOURSE MECHANISM
Digital & Marketing Association
Privacy Shield Program for Consumers
Infogroup has further committed to cooperate with EU and Switzerland data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship. . Infogroup commits to cooperate with the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from Switzerland in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs or Swiss DPAs for more information or to file a complaint. The services of EU DPAs and Swiss DPAs are provided at no cost to you.
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with Infogroup and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority (DPA) and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).
If you have any questions about this Policy or would like to request access to your EU Personal Data or Swiss Personal Data, please contact us in writing as follows: PrivacyTeam@Infogroup.com, fax (402) 836-7055 or by mail at Infogroup Inc., Privacy and Data Security Officer, 1020 E 1st Street, Papillion, NE 68046. You can also reach us via telephone at (402) 836-3377.
Changes To This Policy
We reserve the right to amend this Policy from time to time consistent with the Privacy Shield’s requirements.
Effective Date: 5-16-2019
Last Updated: 5-16-2019
Previous Update: 12-1-2017