IMS Privacy Policy,Last Updated: June 5, 2023,ThisPrivacy Policy describes,among other things, how Interactive Marketing Solutions (IMS), ,Corp.(“IMS,” “we,” “us,”or“our”)treatspersonaldatawecollectfromoraboutyouinconnection,withourServices,and what rightsyou may have regarding such information. This Privacy Policy ,only applies totheims-dm.com&amp. DMAChoice.org websites and any otherfeaturesrelated to the ,IMSservices, includinglists, emails and programs, offered,or operated by the IMStherein,(collectively, “Services”).,PLEASE READ THIS PRIVACY POLICY CAREFULLY. IF YOU DO NOT AGREE WITH ,THIS PRIVACY POLICY, YOU MAY NOT USE OUR SERVICES.,Table of Contents,1.Information We C ollect,2.How We Use Information,3.Sources of Information,4.Disclosures to Other Parties,5.Cookies and Other Trackers,6.Third Party Websites and Services,7.Security,8.Your Choices,9.Your Colorado Privacy Rights,10.Our Sites are Not Intended for Children,11.Changes to Privacy Policy,12.We Process and Store Information in the United States,13.Contact Us,1.INFORMATION WE COLLECT,We collect contact information.For instance, wemaycollect names, street addresses, telephone ,numbers, email addresses,and other contact information you provide.We also collect the contact ,-2-,informationprovidedabout other membersof your household,deceased individuals, or others you ,may care for when requesting Services on their behalf. ,We collectpayment, transactionprofile and preference information.We may collect ,information about which types of services youareinterested in, including whether you wish to ,opt-out of promotional direct mailings, email, orphone call lists. We may also collect information ,about your relationship to a personfor whom you request Services, which may include individuals ,you care foror who are deceased.Your paymentinformationis collected by or on our behalf when ,you subscribe, register andpayforor renewour Services.We also record the date of your ,registration and collect your password and other login information you submit to us.,We collect device, internet and network activity information.When you use or access the ,Services, we may collect information about the browser, device and operating system you are ,using, such as your IP address. We may also embed technologies such as pixelsin the emails and ,other communications we or our vendors send to you to help us understand how you interact with ,those messages, such as whether and when you opened a message or clicked on any content within ,the message. We collect location information.We collect information about your location when ,you use or access theServices, such as your IP address. We may also collect your address when ,you register for the Services, make payments,or update your account.,We collect demographic information/protected classifications.For example, in connection ,with certain Services, we may collect the information you submit about you or others in order to ,receive Services.,2.HOW WE USE INFORMATION,We use information to provide our Services. For instance, we may use your information to ,register you and provide our Services.We may also use your information to update and ensure our ,records are accurate. We use information to communicate with you about our relationship. ,For example, you may contact us with a question or for more information and we will use your ,contact information (which includes personal/businessdatasuch as an email address) to respond,to your question or request. ,We use information to test, analyze, develop, improve, and provide our Services. When you ,access or visit our Services, we and our vendorsmay use technology(e.g., such as cookies, tags, ,pixels,or similar technology)that can recognize, collect and/or transmit information that is ,associated with your device, operating system, browser,or network. This information may be used ,by usor our vendors, for analytical purpose or totest, enhance, secure,or otherwise improve our ,Services.,We use information to comply with our obligations, administer our Services, or as otherwise ,required or permitted by law.For example, we may use information to administer the Services, ,such as troubleshooting, data analysis orfor internal operations.We may also use your information ,for general compliance purposes and to operate our businessoperationson a day-to-day basis.,We use information for security, safety, and due diligence purposes.For example, we may use ,information to protect our organization, business partners, customersand their respective ,-3-,personnelor any other person.We may also use information to protect our Services, as well as to ,detect and investigate unlawful, prohibited,or harmful activities.,We use information to verify requests made pursuant to this Privacy Policy and for other ,verification purposes.We will use certain pieces of information to verify your identity if you ,make requests pursuant to this Privacy Policy. The verification steps and the pieces of personal ,data that we request may vary depending on the sensitivity and nature of your request.,We use information as otherwise disclosed from time to time or permitted by law. We may ,use personal data to create deidentified or aggregated data which does not identify you or any other ,individual, or from which your identity cannot reasonably be ascertained. We may use and disclose ,this anonymous or aggregated data as we choose, unless prohibited by law.,We may also use information as we may notify you from time to time.,3.SOURCES OF INFORMATION,We collect information directly from you.For example, we collect information if youcontact ,us,register for anaccount, or sign up for Services.,We collect information from your devices.We and our vendors use tracking tools such as,browser cookies and web beacons to passivelycollect information about you and your devices. ,We collect information using these tracking tools when you interact with our Services(including ,our emails) that weor our vendors send to you. To learn about your choices for these tracking ,tools, read Section 5 of this Privacy Policy.,We receive information from vendors we engageto work on our behalf.For example, vendors ,that host or maintain our Servicesor send emails for us may give us information. Our analytics ,providers may also provide us with information.,We combine information.We may combine information that we have collected offline with ,information we collect online. Or we may combine information we get from another party with ,information we already have.We may also aggregate your information with other information to ,understand preferences and trends over time.,DMAChoice.orgmay receive information about you from someone acting on your behalf.,We collect informationsubmitted to us about householdmembers, or others who are deceased, or ,may have caregivers or persons acting on their behalf in order to receive ourServices. If you ,believe someone has improperly acted on your behalf,please contact us by email at,ethics@Ana.net.,4.DISCLOSURESTO OTHERPARTIES,We share yourinformation with vendors and service providers who perform services on our ,behalf.We maydisclose your information toourvendorswe engage for the purpose of ,administering, operating, hosting, developing, configuring, maintaining,and providing internal ,support for our Services. We may also share information with vendors we engage tosend emails ,-4-,for us, provide analytics, investigate unlawful or harmful activity,or provide digital security ,services.,We will share your information for safety and security purposes, if we think we have to in ,order to comply with the law, or to protect ourselves, or others.For example, we may share ,your information when we are compelled by a governmental agency, law, regulation, a court,or ,other legal process;in order to enforce any law, regulation, our Terms of Use;to safeguard against ,athreat to safety, property, interests or rights of us or others;and to investigate, respond to or ,resolve problems or inquiries or defend our interests.,We may share your information with a successor to all or part of our organization.If there ,is a changein our corporate structure, such as witha mergeroracquisition, we may include ,information as part of that transaction and/or the negotiation and diligence related to that ,transactionor our organization in general.,In the operation of DMAChoice.org wemay share your information with our subscribers to ,provide the services you requested.Wemay disclose your personal data to third party ,organizations that subscribe to or otherwise use our servicesfor purposes of providing the Services ,you requested,such as your name, email address,mailing address,and other contact and ,demographic informationwhich may include prefixes, suffixes, age, and date of death.,We may share information for other reasonswe may describe to you from time to time or as ,permitted or required by law.,5.COOKIES AND OTHER TRACKERS,We may use cookies, web beacons, pixels,and other trackersas described in this Privacy Policy, ,including to recognize a user’s device each time it is usedandto visit our Services. Cookies can ,also track how you use our Services, and your preferences for features and functions.,You can disable or turnoffcertain cookiesby changing the settings on certain Internet browsers,or devices. If you block cookies, certain functionality of the Servicesmay become impaired or ,disabled.For instance, by changing these settingsyoumay later be requiredto re-enter certain ,information each time you visit or attempt to use our Services.The way to control your cookies ,settings depends on the tool. Certain browsers can be set to reject browser cookies. See the “help” ,section of your particular web browser for more details on rejecting, blocking, and deleting ,cookies. Please keep in mind that if you choose to delete cookies from that browseror if you clear ,your cache, you will delete settingsassociated with that browser and will need to set your ,preferences again. ,Our “Do Not Track” Policy.Some browsers have “do not track” features that allow you to tell a ,website not to track you. These features are not all uniform. We do not currently respond to those ,signals.,6. THIRD PARTY WEBSITES AND SERVICES,-5-,If you click on a link to a siteor service other than our Services, you maybe taken to a website we do not ,control. This Privacy Policy does not apply tosuch other websites or services, and we encourage you to ,read the privacy noticesthat apply to themcarefully.,7.SECURITY,While we strive to protect your information,we cannot guarantee the security of your information ,and your communications when using our Services.,8.YOUR CHOICES,In general, we offer you the ability to opt out of receiving emails and other communications from ,us in the future. Ouremailcommunications will provide you with instructions and the procedures ,you can use to opt out when applicable.Even if you opt out of receivingmessages, we still may ,communicatewith you as it relates tothe Services, including but not limited toresponses to your ,questionsor inquiries.,9.YOUR COLORADOPRIVACY RIGHTS,If you reside in Colorado, you can also make the following more specific requests with respect to ,your personal data:,Right to Know and to Access. You can request that we confirm whether we collect or otherwise ,maintainyour personal data. You can also request access to that personal data.,Right to Portability.You canrequest that we provide a copy of the personal datawe have ,collected or otherwise maintain about youin a portableformat, subject to certain exceptions.We ,are not required to fulfil your portability request more than twice per calendar year.,Right to Delete. You have the right to request that we delete your personal data, subject to certain ,exceptions. ,Right to Correct. You canrequest that we correct inaccurate personal datathat we have collected ,about you. To the extent not prohibited byapplicable law, we may respond with instructions on ,how you could correct your personal data. ,Right to Opt-out.Colorado residents may also have rights to optout from havingtheir personal ,data processed for purposes of “targeted advertising,” “selling,” or certain “profiling.”For ,purposes of this Section, “targeted advertising” refers to collecting personal data obtained from ,your activities across unaffiliated sites for purposes of sending youtargeted advertising. “selling” ,means the exchange of your personal data for monetary or other valuable consideration. and ,“profiling” means the automated processing of personal data for purposes of analyzing, evaluating ,or predicting personal aspects related to your economic situation, health, personal preferences, ,interests, reliability, behavior, location or movements in our decision making process that would ,producelegal or other, similarlysignificant effectsthat concern you.,Exercising Your Rights.To submit your requests, please send us an emailat ethics@ana.net,or ,write to us at the address listed below under the Contact Ussection. Indicate in your message that ,-6-,you are a Colorado resident making a “Colorado Privacy Right Request.” Please include your full ,name and sufficiently describe your request. We will take reasonable steps to authenticateyour ,requestin accordance with applicable law. The authentication processwill vary depending on the,type of request,sensitivity of the personal data and whether you have an account with us. Colorado ,residents may designate an authorized agent to make an opt-out request on their behalf. When ,submitting the request, please ensure the authorized agent is identified as an authorized agent, ,identifies you and the request demonstrates the authorized agent has sufficient authority to act on ,your behalf.,We may deny certain requests and will explain why and how to appeal our decision in our response ,back to you, as required by applicable law. After receiving our explanation, if you would like to ,appeal our decision, you may do so by email or write to us at the address listed below under the ,Contact Ussection, and we will respond to your appeal as further detailed in our communication ,back to you.,10.OUR SITES ARE NOT INTENDED FOR CHILDREN,The DMAChoice and IMS websitesand any other Services are not intended for children under 13 ,years of age. If you are a parent or legal guardian and believe your child under the age of 13 has ,provided their personal datato us, please notify us atethics@Ana.net. You may be required to ,provide verifiable identification that you are the child’s parent or legal guardian.,11.CHANGES TOOURPRIVACY POLICY,We may edit, amend, modify,and update our Privacy Policy at any time by posting updated text ,on or links to our websites or other Services.When we make material changes to our Privacy ,Policy, we will notify you by posting a notice on our website and as otherwise required by ,applicable law. Your continued use of our website and Services means that you acknowledge the ,collection, use and disclosure of your personal dataas set out in the updated Privacy Policy.,12.WE PROCESS AND STORE INFORMATION IN THE UNITED STATES,Information we collect may be transferred to, processed in, or stored in the United States. Our ,Servicesare subject to United Stateslaws, which may not afford the same level protection as those ,in othercountries.,13.CONTACT US,For questions about thisPrivacy Policyplease email us at solutions@ims-dm.com, or writeto us ,at Attention: IMSPrivacy Policy, Interactive Marketing Solutions, Corp| 1177 Summer Street| ,Stamford, CT 06905, and please specifyyou are inquiring about the IMSor DMAChoice websites ,or servicesto help us better assist and respond to your questions.,Interactive Marketing Solutions, Corp.





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