Valpak Direct Marketing Systems Privacy Policy https
TABLE OF CONTENTS
- Introduction and Scope
- Personal Information Collection
- How We Collect Personal Information
- Automated Data Collection Tools
- Why We Collect Personal Information
- How We Share Personal Information
- Opting In/Opting Out Of Disclosures To Third Parties
- Children's Personal Information
- How We Protect and Store Personal Information
- US Consumer Data Privacy Rights
- Submitting Data Subject Rights Requests (DSRRs)
- Updates to This Privacy Policy
- Contact Us
Introduction and Scope
Thank you for visiting www.valpak.com (the "Website"), which is owned and operated by Valpak Direct Marketing Systems, LLC ("Valpak", "we", "us", "our"). Valpak respects your privacy and values your trust. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you interact with our digital platforms, print mailers, coupons, promotions, or marketing services (collectively, "Valpak Services").
This Privacy Policy does not apply to any information you may provide to us through other means, such as, in mailings (electronic or otherwise) or telephone calls. Please read this Privacy Policy carefully to understand our online privacy practices. By using Valpak Services, you agree to the way we collect, use, manage, share, or otherwise process your personal data and accept the Valpak Terms of Use and this Privacy Policy.
The Valpak Services are currently only available in the United States and, therefore, this Privacy Policy is designed to comply with applicable United States' consumer privacy protection laws.
Personal Information Collection
We collect several categories of information about you, which include:
Contact Data: Personal identifiers, such as your name, postal address, email address, telephone number, business name, business postal and email addresses, and telephone phone numbers.
Sensitive Personal Information: In some cases, we collect certain personal information that may be considered "sensitive", such as your race, religion, gender, ethnicity, age or non-specific age; and other demographic personal information, such as personal or household income.
Public Records: Information that is lawfully made available from federal, state, or local government records and publicly accessible records related to residential real estate transactions.
Usage Data: Geographic information such as your geographic location by digital internet protocol (IP) address, browser type, operating system, length of visit, page views and website navigation paths. The source of this usage data is our analytics tracking system.
How We Collect Personal Information
We collect personal information in two main ways, including our direct interactions with you and by automated tracking technologies and tools as described below.
Registration Information: Some Valpak Services require users to register with us and create user accounts on our platforms. To do so, we will ask you for certain personal information as part of the registration process to set up your account and after registration, we will use this information to communicate with you. If you do not agree to our Terms of Use and this Privacy Policy, please do not register for such Valpak Services.
Publications: Some Valpak Services offer you the opportunity to subscribe to email newsletters, receive deal alerts and other matters related to Valpak Services. We process your personal information for this purpose based upon your consent and to satisfy our contractual obligations to you.
Promotional Events: From time to time, we or businesses we work with may offer you an opportunity to enter contests, sweepstakes or other promotions. If we offer these opportunities through Valpak Services we will use the information you are required to provide to operate such promotional events. If these contests, sweepstakes or promotions are offered by third-party businesses, then such third-parties shall be responsible for the collection and processing of your personal information under their own terms and conditions.
Social Media: The Website may contain or include links to social media channels that contain message boards, chat rooms, personal web pages or profiles, forums, blogs, bulletin boards, discussion or comments areas, and other interactive features where you may post, submit, publish, display or transmit to other users or other persons (hereinafter, "post") content or materials on or through the Website and/or social media channels ("User Contributions").
All User Contributions must comply with the Content Standards stated herein. Please be mindful that any User Contributions on the site will be considered non-confidential and non-proprietary. By providing any contributions on the Website or related social media channels, you grant the Valpak Companies, and our Service Providers, and each of their and our respective licensees, successors and assigns the right to use, reproduce, modify, perform, display, distribute and otherwise disclose to third parties any such material for any purpose. We cannot control how your posting may be used by third parties.
Content Standards: These content standards apply to any and all User Contributions made on the Website or through our related social media channels. User Contributions must in their entirety comply with all applicable federal, state, local and international laws and regulations. Without limiting the foregoing, User Contributions must not:
- Contain any material which is defamatory, obscene, indecent, abusive, offensive, harassing, violent, hateful, inflammatory or otherwise objectionable.
- Promote sexually explicit or pornographic material, violence, or discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.
- Involve commercial activities or sales, such as contests, sweepstakes and other sales promotions, or advertising.
Operations & Security: We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders and requests, providing Valpak Services, researching and developing new direct marketing promotional products or services, creating and maintaining our databases and business records. We may also process your personal data for operational security purposes to address fraudulent or other suspicious activity.
Automated Data Collection Tools
We use cookies, pixels and other similar technologies (collectively referred to as "cookies") to provide and improve our Valpak Services, to tailor your website experience, and to show personalized ads. Cookies are useful because they allow a website to recognize a user's device.
You can manage which cookies are placed on your device by:
Using browser controls: The Help menu on the menu bar of most browsers will tell you how to enable or prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or visiting the website of its manufacturer. Please be aware that if you disable or delete certain cookies our website will not work properly.
Functional Cookies: Cookies are small files that a website or its service provider transfers to your computer's hard drive through your web browser (if you permit) that enables the website's or service provider's system to recognize your browser and capture and remember certain information. Users may refuse to accept browser cookies but note, this may affect your access to certain parts of our Website. Unless you have adjusted your browser to refuse cookies, our system will issue cookies when you browse our Website. You can manage your browser's cookie setting through the "options" menu on most commercially available web browsers, including options to set your browser to notify you before accepting a cookie or to disable cookies entirely. Of course, if you set your browser not to accept cookies, you may not be able to take advantage of the personalized features enjoyed by other users of our Service.
Required Cookies: Required cookies are necessary to permit the basic features of the website to function. We use some cookies that are required for the delivery of Services on our website. Cookies are a necessary component to allow us to maintain and improve user safety and security while browsing and using our website. Required cookies allow us to authenticate registered user accounts, enable users to log into various parts of our website with a single login attempt, and determine our website's traffic and demographics. Required cookies are not used for marketing purposes.
Flash Cookies: Flash cookies collect and store information about your preferences and navigation to and from our Website. Flash cookies are not managed by the same browser settings as cookies.
Web Beacons: Our website and emails may contain small electronic (web beacons) that allow us to receive real time statistics on user interactions such as the number of users visiting our Website, emails opened by users, and any other statistical user information.
Clickstream Data: Clickstream data is a detailed log of how you navigate through our Website during a specific task. Generally, the log contains the pages visited, the time spent on each page, how you arrived on the page, and where you went next. In the aggregate, clickstream data is a great resource to provide real time feedback on how we can improve our website and what features you enjoy and which may cause confusion.
Web Servers: Our web servers automatically collect limited information about your computer configuration or your mobile device when you use our Service, including the type of browser software you use, the operating system you are running, the resolution of your computer monitor or mobile device, the Website that referred you, the type of device you're using, and your IP address. Your IP address is a numerical address that is used by computers and mobile devices connected to the Internet to identify your computer or mobile device so that data (such as the web pages you want to view) can be transmitted to you. We also use IP address information for systems administration and troubleshooting purposes. Your IP address alone does not tell us who you are. We use this information to deliver our web pages to you upon request, to tailor our Service (including ads distributed through our Service) to the interests of our users, and to measure traffic within our Service.
Third-party Cookies: When you use our Website and Apps, you may notice content provided by a company other than us. Also, if you "share" Valpak content with friends through social networks, such as Facebook, X, and YouTube, these social networks may place cookies on your browser. We have no access to or control over cookies used by these companies or third-party websites. If you would like to opt out of cookies created by "sharing" Valpak content through social networks, we suggest you check those third-party websites for more information about their cookies and how to manage them.
Why We Collect Personal Information
We collect your personal information for the following business and/or commercial purposes:
To improve our website services, marketing, customer relationships and experiences.
To deliver relevant content and advertisements to you and measure the effectiveness of our advertisement.
To make suggestions to you about goods or services that may be of interest to you.
To provide you with customer support services.
To provide you with a personalized user experience.
To analyze customer usage patterns, conduct research, improve and develop our Valpak Service offerings.
To protect, establish, exercise or defend our rights and to defend against lawsuits.
To secure our Valpak Services and data processed bia our Valpak Services, and to prevent, detect, and investigate unlawful or unwanted behavior, including crime and fraud.
To comply with legal and regulatory requirements and cooperate with regulators and government authorities.
How We Share Personal Information
Where relevant and necessary, we may disclose your personal information to the following types of parties:
Service Providers: We may retain other companies and individuals ("Service Providers") to perform functions on our behalf consistent with this privacy statement. Examples include, but are not limited to, data analysis firms, customer support specialists, email vendors, and web hosting companies. Service Providers may be provided with access to personal information needed to perform their functions but may not use such information other than on our behalf and in accordance with this privacy statement. In addition, in some instances, you may be offered the opportunity to consent to the sharing of your information with a Service Provider such as an event or promotion co-sponsor. If you consent, we will share your information with such Service Provider and the information you provide may be used by such Service Provider for their own purposes and in accordance with their own policies. We will identify any co-sponsor(s) in the official rules for the promotion.
Group Companies: Your personal information may be shared with certain affiliated companies that support us in providing the Valpak Services.
Our Business Customers: If you choose to receive products or services from our business customers who link their websites to our Website. In such cases, our business customers may have access to and process your personal information. We also share your personal information where you direct us as part of the Valpak Services to share your personal information with another users or to our business customers.
Regulatory Authorities: Your personal information may be shared with law enforcement agencies, courts, regulators, government authorities, and other similar public authorities or third parties when necessary to comply with a legal obligation or when we have a legitimate business interests to do so, for example, to protect our or a third party's rights and interests.
Professional Advisors: We may share your personal information when we have legitimate business interest to do, for example, obtain legal advice or to assist us with a criminal or regulatory investigation.
Business Transactions: When we are engaged in business transactions such as investments, reorganizations, restructuring, mergers, bankruptcy, insolvency events, joint ventures, sale of shares or assets, or like events.
Opting In/Opting Out Of Disclosures To Third Parties
In certain places on this Service (for example, when registering as a user of this Service, managing your account, or participating in activities like promotional contests), we may ask you to consent to the sharing of your information with third parties with which we have business relationships. If you provide such consent (for example, by checking a box or by some other means), we will make your information available to such third parties as described in the consent form so that they, we, or both may contact you directly regarding special offers, promotions, products or services that may be of interest to you.
You agree that, subject to applicable law, we may use your information to contact you for customer service, to inform you of important changes or additions to our Service or the services offered over our Service and to send you administrative notices or any communications relevant to your use of our Service.
If you have subscribed to one of our email newsletters, you will always have the opportunity to unsubscribe from future mailings (for example, by clicking on an unsubscribe link in an email newsletter).
Children's Personal Information
This Service is not directed at children under the age of 13, and we will not knowingly allow anyone under age 13 to register with our Valpak Service or to provide any other personal information. If you are under the age of 13, please do not provide us with any personally identifying information about yourself (such as your name, your email address or your phone number). If we become aware that we have collected any personally identifying information from a user under the age of 13, we will remove such information from our records as soon as possible.
How We Protect and Store Personal Information
We have implemented technical and organizational security measures to protect your personal information. These measures are aimed at ensuring the integrity, confidentiality, and availability of your personal information and to protect it against unlawful or unauthorized destruction, loss, alteration, use, disclosure, or access. These measures include access controls, controlled administration of user rights, and storing personal information on servers and in databases operated by us or by our selected Service Providers on our behalf. We endeavor to select Service Providers we believe are committed to data security and are contractually they are obligated to provide appropriate data security protections for the data they process for us.
Valpak retains personal information only as long as necessary to achieve the purposes outlined above, meet contractual and legal obligations, and resolve disputes.
We also encourage you and all Valpak Service users to take reasonable measures on their own to protect their personal information and keep all their passwords, whether given or chosen, confidential.
Although we take measures to protect your personal information, no security system is impenetrable. We cannot guarantee the security of our servers or databases, nor can we guarantee that personal information you supply cannot be intercepted while being transmitted to us over the Internet. The transmission of personal information is at your own risk. We are not responsible for the circumvention of or tampering with any privacy setting or security measure contained on the Website.
US Consumer Data Privacy Rights
Across the United States (US) certain states grant consumers certain rights regarding their personal information. As of the Effective Date of this Privacy Policy, these US states include California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rode Island, Tennessee, Texas, Utah, and Virginia.
The following is intended to explain consumers' rights and our obligations generally under these laws, but we also encourage you to contact the Attorney General's office in your state of residence for further information. Find your State's Attorney General at: Find my AG - National Association of Attorneys General.
Depending on your state of residence, you may have the following rights:
Right to Know/Access: Request details about the personal information we collect, use, and share.
Right to Delete: Request deletion of your personal information, subject to legal exceptions.
Right to Correct: Request correction of inaccurate personal information.
Right to Opt-Out: Opt-out of targeted advertising, sale, or sharing of personal information.
Right to Limit Use of Sensitive Information: Restrict use of sensitive data for secondary purposes.
Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.
Submitting Data Subject Rights Requests (DSRRs)
Depending on the scope of privacy rights in your state and the verification requirements imposed by such laws, you may exercise your rights by contacting Valpak at: www.valpak.com/privacy-center.
Valpak will verify your identity as is permitted by the laws that apply and in accordance with Valpak's DSRR policies and procedures. Authorized agents must provide proof of authorization and identity before Valpak can process the request. We do not respond to bulk DSRRs by mass market disseminators without such proof.
Updates to This Privacy Policy
We may change the terms of this privacy statement or introduce new terms and conditions from time to time, in which case we will post an updated version of this privacy statement on this Service and will update the "Last Updated" date above to reflect the date the changes take effect. By continuing to use this Service after we post any such changes, you accept this privacy policy, as modified.
Contact Us
Valpak Privacy Office: www.valpak.com/privacy-center
California Consumer Privacy Act Rights
The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (together "CCPA") grants rights to California consumers and imposes corresponding obligations on businesses subject to CCPA as described in in this Section.
The following is intended to explain a consumer's rights and our obligation under CCPA for the Valpak business activities within the scope of this Privacy Policy.
Right to Know/Request for Access to Personal Information
As a consumer under CCPA, you have the right to request that Valpak disclose what personal information it collects, uses, discloses, and sell/shares about you. We call this your "right to know." To take advantage of your right to know, you can submit a request by filling out a request online at: www.valpak.com/privacy-center.
You can also submit your request by mail to:
The CCPA permits Valpak to verify your identity in responding to your right to know request. This will require you to provide certain personal information for validation as well as satisfactorily answer a series of authentication questions administered through our consumer portal. If you call or mail us and request a consumer access report, a Valpak associate will call you to administer an authentication test in which you will be required to answer certain questions to verify your identity.
If we are unable to satisfactorily verify your identity, we will be unable to fulfill your right to know request. In that case, please see the information below concerning Valpak's data collection, maintenance, and sale practices.
Types of Personal Information Valpak Collects, Discloses, Sells, or Shares
| Categories of Personal Information Collected | Personal Identifiers: Name, postal, email, IP addresses, telephone numbers, internet activity, geolocation-based on zip code, |
|---|---|
| Sensitive Personal Information: Race, religion, gender, ethnicity, age | |
| Financial & Property Information: Income category, real property characteristics such as purchase price, ownership period, & type of residence | |
| Automated Data: Device information, browser types, IP address, browsing activities, operating systems, |
| Categories of Sources of Personal Information Collected | Public Records: Real property recordation & assessment records, website directories & listings, professional license records, |
|---|---|
| Surveys & Questionnaires: | |
| Credit Bureaus (where permitted by law): Identifying information, address validation | |
| Aggregated Purchase Information: | |
| Demographic Marketing Information: |
| Categories of Third Parties with Which Personal Information is Sold or Shared | Business Customers: Mailing lists purchasers for direct mail and digital advertising, coupon distributions, surveys, & promotionals campaigns |
|---|---|
| Advertisers: Without consent, aggregated personal information only shared with advertisers to illustrate audience reach |
| Categories of Service Providers, Contractors, and Affiliates with Whom Personal Information is Disclosed for a Business Purpose | Cloud computing and storage vendors; security contractors; consultants, analysis providers, marketing analytics platforms; programmatic advertising platforms; social media publishers; email vendors; and other technology vendors |
|---|
Valpak does not collect biometric information from consumers who are not Valpak employees. Also, Valpak does not collect sensory information such as voice, visual, thermal, olfactory, neural or similar sensory information. Valpak does not engage in profiling in furtherance of "decisions that produce legal or similarly significant effects."
Disclosure and Sale of Personal Information
During the last year, Valpak has sold personal information is has collected to its clients and advertisers (e.g., "third parties" under CCPA), for Valpak's and their business and commercial purposes. More specifically, Valpak discloses personal information to its clients to enable and improve their marketing and advertising campaigns by identifying potentially interested consumers to measure the effectiveness of the marketing and advertising campaign. Valpak does not sell personal information to individual consumers.
During the last year, Valpak has disclosed personal information to service providers and contractors (e.g., cloud computing and storage vendors; security contractors, and consultants), for Valpak's own operational business purposes. Valpak does not sell personal information about consumers to any third party under the age of 18 for the purpose of marketing or advertising directly to the minor. Moreover, Valpak's service solutions are not available to individuals, especially to any individual under the age of 18.
Right to Correct and Delete Personal Information
Under the CCPA, California consumers have a right to request correction or deletion of personal information about that Valpak has collected or maintained. As permitted by CCPA regulations, Valpak will treat correction requests as a request to delete. To take advantage of your right to delete, you may submit a request via our online consumer portal, which is found at: www.valpak.com/privacy-center.
You may also submit your request by mail or visit: www.valpak.com/privacy-center .
Our mailing address is:
The CCPA requires Valpak to verify your identity in responding to your right to delete requests. To do so, you may need to send us certain personal information to compare and match the data we have about you. We have up to 45 calendar days from the day your request is received to respond to your request to know, correct, or delete with a possible 45-day extension if we notify you of a delay.
Right to Op Out
Consumers have a right to opt out from Valpak selling or sharing their personal information for marketing purposes. To take advantage of your right to opt out, you may submit a request to: www.valpak.com/privacy-center.
You may also submit your request by mail or through www.valpak.com/privacy-center .
Our mailing address is:
Universal Opt-Out Mechanisms (UOOMS) and Global Privacy Controls (GPC)
The CCPA requires covered businesses to treat user-enabled global privacy control (GPC) as a valid consumer request to opt out of the sale or sharing of their personal information for online tracking technologies (i.e., targeted advertising, sales, or sharing). Consumers can learn more about UOOMs and GPCs by visiting: Global Privacy Control — Take Control Of Your Privacy.
Right to Limit Use of Sensitive Personal Information
Valpak may use Sensitive Personal Information as a part of its marketing and advertising products. Under CCPA, California consumers have a right to request a business limit use of "Sensitive Personal Information" about them that Valpak has collected or maintained. "Sensitive Personal Information" includes (1) a consumer's social security number, driver's license, state identification card, or passport number: (2) a consumer's account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to a consumer's account; (3) a consumer's precise geolocation; (4) a consumer's racial or ethnic origin, religious or philosophical beliefs, or union membership status; (5) the contents of a consumer's mail, email, and text messages unless the business is the intended recipient of the communication; (6) personal information of a consumer related to their health; and (7) personal information concerning a consumer's sex life or sexual orientation. Valpak will treat a request to limit our use of sensitive personal information as a request to delete.
Consumers have a right to limit use of their sensitive personal information which will be treated like a request to delete, you may submit a request here: www.valpak.com/privacy-center.
You may also submit your request by mail or visiting: www.valpak.com/privacy-center .
Our mailing address is:
Right to Non-Discrimination
The CCPA protects California consumers who exercise their rights from discrimination. Valpak will not discriminate against consumers who exercise any of their data rights under the CCPA,
Right to use Authorized Agents to Exercise Rights
The CCPA allows California consumers to use authorized agents to submit requests to Valpak on their behalf. Valpak requires consumers using Authorized Agents to submit a written authorization notifying Valpak that an Authorized Agent has been appointed. Authorized Agents' request will result in Valpak reporting the actions it has taken to the consumer directly.
How to Contact Us for More Information
If you have any questions regarding your rights under CCPA or Valpak's data collection, use and disclosure practices, you may contact us as provided below.
For our Valpak Consumer Privacy Center, visit: www.valpak.com/privacy-center .
Our mailing address is:
Information for California Consumers
You may contact the California Attorney General (https://www.oag.ca.gov), or the California Privacy Protection Agency (https://www.cppa.ca.gov), for more information.