ALC, Inc. (“ALC,” “we” or “us”) deploys a wide range of data gathering, management, analytic and marketing services specifically geared to help our marketing partners direct relevant, data-driven marketing communications—including direct mail, inserts, email, digital, mobile and social media campaigns—to their customers and prospects, based on those consumers’ interests, activities and demographics.
ALC is committed to protecting the information of its clients, as well as the customers and prospective customers of its marketing partners, and making all parties aware of our practices regarding the privacy of their information.
- The responsible use of marketing information can be beneficial to consumers, providing them the opportunity to learn about relevant and appropriate products and services and make informed buying decisions.
- Marketing information and data should be used to benefit consumers and enhance their ability to form mutually rewarding relationships with marketing organizations.
- Consumers should be provided with notice, choice and education about the use of personal information; consumer preferences and requests should be honored as they relate to marketing data and information.
ALC works closely with major industry trade associations and organizations that are at the center of privacy issues and advocacy. ALC is an active member of the Direct Marketing Association (DMA), (online at www.the-dma.org). The DMA is associated with the Digital Advertising Alliance (“DAA”), and we adhere to the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. You may click here to learn more about how to opt-out of ALC’s services.
1. Types of Data That We Obtain
ALC receives data from a variety of consumer and business-to-business marketing companies and services, data compilers and suppliers. We may also obtain data through public sources, such as census data and other public records. And we may also collect certain information when you visit our website(s) or our marketing partners’ website(s).
- This data may include Personally Identifiable Information (“PII”) and attributes linked to PII, as may be the case for demographic or interest-based data associated with PII. When we refer to PII we mean first and last name, postal address, telephone number or email address. Attributes linked to PII may include demographic, lifestyle and behavioral information, such as expressed interests and past purchases.
- We likewise may collect and/or connect information about consumers’ interests, online and offline activities (including website visits) or demographics that we may group into aggregated “Audience Segments.”
ALC does not collect or use sensitive information such as Social Security numbers, credit card numbers, bank account numbers, or personal financial or medical information.
- ALC deploys individual identifiers that we, or our marketing partners, create that are derived from PII but have been de-identified, through various means. In delivering our services, we do not place PII into or associate PII with online cookies.
- ALC may receive non–PII (e.g., pages viewed, browser type, time and date of visits) from visitors to our or our marketing partners’ websites. This data may be used to improve the operation of these websites, improve visitors’ experience to the websites, to identify or remediate possible threats to the website’s security, and for other operational and management purposes, as well as for “retargeting” relevant offers to visitors based on their web browsing activity.
- ALC may also collect or receive information about consumers’ visits to websites and information regarding advertising exposure (“web log data”). Web log data may include browser type, IP address, type of ad served, and date of ad delivery. This information is used to optimize ad campaigns and measure their effectiveness. Web log data may also be used to provide ads about goods and services that are most likely to be of interest to individuals.
2. Use of Data
ALC deploys marketing data for various purposes, including:
- Targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing;
- Measuring the effectiveness of both online and 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 marketing partners’ proprietary databases;
- Creating defined audience segments based on common demographics and/or shared interests or preferences (e.g., sports enthusiasts, frequent travelers, business leaders); these audience segments may consist of our marketing partners’ proprietary 1st party data, as well as 3rd party information and ALC’s own proprietary data;
- “Retargeting” via direct mail, email, display, mobile and/or social media to the visitors to a marketing partner’s website(including both customers and prospective customers); in order to do this, we may deploy anonymous unique identifiers that enable the “retargeting” of consumers based on their web browsing experience, in a privacy sensitive manner;
- Related data services, such as (but not limited to) verification, record look-ups, anti-fraud, and other analytics and database tools.
You may learn more about companies that engage in various types of online targeted and retargeted advertising, by visiting the DAA’s opt out page at http:// www.aboutads.info/choices/.
You may click here to opt-out of ALC’s marketing services platform.
3. Respect for Consumer Privacy and Choice
ALC continually strives to enable its marketing partners to make good, responsible use of available marketing data without compromising consumer privacy or security. ALC embraces and endorses the industry’s highest standards, and adheres to the following:
Online Marketing Services — We do not place PII (as opposed to a unique identifier) into cookies. When working with data partners, we “hash” all PII they receive from us into a non-human readable, de-identified form. In recognition of the importance of separating online data (e.g., web browsing data) collected across websites from PII, we employ other, sophisticated technical, operational and legal means to segregate databases containing PII from that data.
Email Marketing — We comply with CAN-SPAM and established email advertising and content guidelines. Consumers may always opt-out of ALC email databases;
Audience Segments — We do not collect or work with social security numbers, personal medical or financial records, or with financial or insurance account information. Nor do we knowingly collect any information from (or offer our services to) children under the age of 13;
Opt-Out — We provide (or provide access to) multiple opt-out methods;
Notice — We require our online partners to provide appropriate notice and choice to their own customers and users as required by applicable legal standards and industry best practices.
4. Your Opt-Out Rights
Please click here to opt out of ALC’s cookie-based Online Marketing Services. On that Opt-Out Page, we provide information and opt-out choices for cookies that are set by our partners, through their domains. For these cookie-based opt-outs (but not for ALC’s email-based opt-out), please note that if you browse the web from multiple browsers or devices, you will need to opt out from each browser and/or device to ensure that we withhold our Online Marketing Services on all of them. For the same reason, if you procure a new device, change browsers or delete the ALC cookie (or clear all cookies), you will need to perform this opt-out function again.
If you wish to opt out of other third party ad platforms and ad networks (including ones we work with and may have transferred data to in the past), we also recommend visiting the opt-out pages offered by the Network Advertising Initiative and the DAA’s AboutAds program. As described at greater length on our Opt-Out page, (and at the above industry-sponsored pages), opting-out in this way will not prevent you from seeing ads; it will prevent targeted ads customized to what ad exchanges (and as to our opt-out, we) believe are most likely to be relevant and of interest to you.
5. How We Share Data with Third Parties
ALC may share information it collects or receives, including PII, with customers, marketing services and platforms, and service providers that we retain, in order to provide the services we have described above (or other services we may add).
Partners: We may share information, including PII and Audience Segments, with business and data partners to help provide more tailored targeted communications. Likewise, we may do so for analytical purposes, to measure campaign performance, or inform future campaigns, or to handle, analyze, or segregate the PII and other data that we handle for customers.
Corporate transfers: If ALC or its significant assets are acquired by or merged into another entity, our information will be transferred to that entity.
Affiliates, parent companies and subsidiaries: ALC may share some or all of the information in our possession with our affiliated or subsidiary companies.
As Required by Law or to Protect Any Party: ALC may disclose information if we believe that such disclosure is necessary to (a) comply 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 ALC or any other party.
6. Cookie Technology
Cookies and how we use them
ALC uses industry-standard technologies, including cookies and similarly functional technologies. ALC cookies do not contain PII, and they expire within 24 months (and often over a shorter time span than that).
We may work with third parties to provide or enhance our services (e.g. for purposes of retargeting and tailoring ads, or placing browser cookies). These partners may set and access their own cookies, pixel tags and similar technologies on your device, which may have cookies with varying expiration period. Those partners may, likewise, collect various types of anonymous or de-identified information about your browser, device, or browsing activities through use of these cookies.
Cookies are small data files that contain a string of characters, such as an anonymous unique browser identifier. Cookies are stored on your computer or other device and act as anonymous tags that identify your device, but not you personally. 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 these web pages, pixel tags generate a generic notice of the visit and permit us to set or read our cookies. Pixel tags are used in combination with cookies to anonymously track the activity on a site by a particular device. When you turn off cookies, pixel tags simply detect an anonymous website visit.
In providing our services, we work with certain third-party companies that use techniques other than HTTP cookies to recognize your computer or device and/or to collect and record information about your web surfing activity, including those integrated with our services. These technologies may not respond to browser settings that block conventional cookies. You may opt out of many of these types of technologies by visiting the NAI’s opt out page at http://www.networkadvertising.org.
7. Data Collected Through Our Website
- The domain name and IP addresses of users’ web browsers.
- Aggregate information on what users access, utilize or visit.
- Information, including PII, voluntarily provided by you, such as survey information, requests for information, credit card information, mailing addresses and email addresses.
How ALC 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
- Send you offers and ads for products and services of partner brands, or other offers we believe may be of interest to you
- Perform data analyses (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 the information for compliance with our legal obligations, policies and procedures, including the enforcement of our Terms and Conditions.
How ALC Shares the Information We Collect Through Our Websites
- We may share the Information with service providers who help us deliver the services you request or we provide.
- 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.
This website may provide links to other websites that ALC thinks users will find interesting or useful. ALC is not responsible for the privacy practices of these other sites or companies.
9. Security and Data Integrity
ALC 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 PII. While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we employ efforts to ensure that this does not occur.
From time to time, we may update this policy. Please check back for any changes to this policy..
11. Contact Us
ALC has a designated privacy officer. If you have questions related to this policy, or regarding ALC’s products or services, please contact us.
750 College Road East, Suite 201, Princeton, NJ 08540
We appreciate your comments on ALC’s privacy practices.
Last updated: September 18, 2015