Source and Use of Information. Merkle provides the framework for organizations to apply database marketing strategies to their marketing programs across mass, direct and digital media. Using a variety of quantitative, information-based solutions, Merkle works with clients to plan, design, execute and measure fully integrated customer relationship marketing (CRM) and digital media buying solutions that allow our clients to market products and services more effectively.
Information is at the core of Merkle’s business. Merkle obtains marketing information (including information about consumers and businesses) from and through our clients. Merkle also acquires marketing information from third parties to be used by our clients. Many of our client solutions involve various uses of information, including the storage, exchange, transfer, management, analysis and/or reporting of such information. Merkle does not collect data directly from consumers except for information collected as part of our clients’ marketing and digital advertising programs.
Privacy Philosophy. Merkle is committed to ensuring that the information provided by clients and third parties is secure while in our care and will be used responsibly. Like our clients, we recognize that the privacy of consumers is paramount in our business, so we continuously seek ways to protect and ensure appropriate use of information related to consumers while promoting policies within the industry that do the same.
Our philosophy around consumer privacy and information security is derived in part from a core objective – earn and maintain our clients’ trust to use information in a way that benefits both businesses and individuals, while protecting the privacy of consumers. Our objective is premised on the beliefs that:
- The use of marketing information is beneficial to consumers and ultimately provides more effective marketing communications, products and services to consumers.
- Marketing information and data should only be used to benefit consumers and their ability to form mutually beneficial relationships with marketers (i.e., our clients).
- Consumers should be provided with notice, choice and education about the use of personal information, and consumer preferences and requests should be honored as they relate to marketing data and information.
- The enforcement of opt-in and opt-out processes is essential to meet consumer preference and choice.
Digital Media and Interest Based Advertising. Merkle engages in Interest Based Advertising on this website and with the solutions that we offer our clients. Interest Based Advertising is the collection of data across multiple non-affiliated websites and mobile applications for the purpose of creating interest segments to be used for ad targeting and content customization. For example, if you visit this website, we or one of our advertising partners may record your visit in a cookie which may result in your seeing a targeted ad when you visit a different website. For more information about interest based advertising and the ability opt-out from this practice across multiple companies, please visit http://www.aboutads.info/choices/.
Merkle makes available a subset of our offline data available for use by our clients and partners in an online environment to help augment the solutions we offer. We use reasonable privacy controls and adhere to standards such as the DAA code when we onboard this offline data into a digital setting. Similarly, where our solutions are able to infer that two or more browsers or devices are likely to belong to the same user or household, we may note in our systems that those browsers or devices are linked. Some media buying platforms such as Facebook enable Merkle to purchase media for our clients using personal information such as email addresses, and Merkle takes steps to honor the privacy restrictions imposed by those platforms.
Merkle utilizes several different technologies that enable our solutions to do a more effective job of targeting, measuring and reporting on the digital advertising campaigns run by our clients. For example, we use tracking technologies such as pixel tags, cookies, web beacons, statistical identifiers and mobile o/s advertising identifiers such as Apple’s IDFA, the Android Advertising ID and other pseudonymous information. For more information about cookies and web beacons, please visit www.allaboutcookies.org. Statistical identifiers are created when our systems read pseudonymous information about your computer or device, including the user agent, IP address, installed fonts, and the browser and operating system of your computer and device. Statistical identifiers enable our systems to determine within a reasonable level of certainty that they are encountering the same computer or device, including in environments where third-party cookies are not supported.
Opting Out of Interest Based Advertising. Merkle enables users to opt-out from certain uses of information in a digital environment. If you want to opt-out from our solutions from the browser you are currently using, click here and our systems will attempt to place an opt-out cookie on your computer. You may also visit http://www.aboutads.info/choices/ to have the option of opting out of many of Merkle’s partners. Please note that if you clear cookies from your browser, you may need to renew your opt-out choice. The mobile operating systems (e.g., Android and iOS) have their own opt-out mechanisms that apply IBA in mobile app environments. To exercise this opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). While Merkle does not respond to Do Not Track signals, when our systems detect the presence of our opt-out cookie or a mobile o/s opt-out indicator, our solutions will stop engaging in IBA for the opted out browser or device. And if we have linked two or more browsers or devices as described above, our systems will attempt to sever the link for the opted out browser or device.
Opting Out of Direct Mail and Telemarketing. Responsible marketing companies respect your choice to not receive direct mail advertising. Merkle uses Direct Marketing Association (DMA) resources to suppress the names and addresses of individuals who have notified the DMA that they do not want to receive advertising by mail.
If you would like to opt out of direct mail advertising, send your complete name and address to: DMA Mail Preference Service P.O. Box 643 Carmel, NY 10512
Responsible marketing companies respect your choice to not receive telemarketing calls. Merkle uses DMA resources to suppress the phone numbers of individuals who have notified the DMA that they do not want to receive telemarketing calls.
If you would like to opt out of telemarketing calls, send your complete name, address and telephone number to: DMA Telephone Preference Service P.O. Box 1559 Carmel, NY 10512
Information Management. Merkle provides information management and marketing services designed to help companies improve their marketing strategies and programs. These services may involve third parties and may utilize cookies, web beacons, or other tracking or retargeting mechanisms. When we provide these services to our clients, we process information according to the terms and conditions of the contract with our clients. Accordingly, Merkle relies upon the instructions of its clients with respect to the use of marketing information and ultimately our clients advise us as to a consumer's preferences or opt-in/opt-out choices.
Information Products. Merkle hosts and maintains various third-party data on behalf of our clients. When Merkle provides data products to our clients we adhere to the terms and conditions defined by third party suppliers of such data.
Advocacy and Compliance. Merkle works closely with major industry trade associations and organizations that are at the center of privacy issues and advocacy. Merkle adheres to the Digital Advertising Alliance (DAA) Self-Regulatory Codes as applicable to our business. To learn more about the DAA programs click here. Merkle’s executive staff have served on various DMA committees. Merkle is also a member of numerous professional marketing associations. We utilize and support MD5 encrypted suppression files.
Transfer, Processing and Storage of Personal Information. As Merkle is a global organization, we may transfer your personal information to Merkle in the United States of America, to any Merkle group company, or to third parties and business partners. By using our websites and solutions or providing any personal information to us, you consent to the transfer, processing, and storage of such information outside of your country of residence where data protection standards may be different.
Processor on Behalf. Merkle acts as a processor on behalf of its clients, providing customized services that enable organizations to manage their customer information efficiently in such ways as reducing data-processing timeframes, increasing marketing efficiency, and applying database marketing strategies. Merkle processes marketing information of its clients and on behalf of its clients. In this capacity as a processor on behalf, Merkle acts on the instructions of its clients and does not control or share such data without direction from the client.
Merkle previously certified under the U.S.-E.U. Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland, though does not rely on the Safe Harbor in order to comply with EU law. For such data processing, Merkle takes appropriate steps, in accordance with EU data protection law, to apply appropriate safeguards of protection, such as the Standard Clauses approved by the European Commission.
Following the ruling of the European Court of Justice on October 6, 2015 regarding the validity of the Safe Harbor, and in light of evolving regulatory frameworks, Merkle may participate in other frameworks approved by relevant regulatory authorities from time to time.
Data Security. Merkle will not disclose to third parties personal data processed in this capacity, except as permitted or required by the processing agreement or as otherwise required by law. Merkle has reasonable security measures in place to help protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
Information Security. Merkle has implemented reasonable, industry-standard security policies, standards and practices designed to protect information from internal and external threats. The degree of protection for each piece of information is based on the risk and consequences associated with having that information compromised. While no security measures will provide for absolute security, all Merkle employees responsible for the management of information have the responsibility to adhere to Merkle’s documented security controls, which are developed commensurate with the understood risk.
Website Privacy. Visitors to Merkle’s website may be given the opportunity to receive information about Merkle’s products and services by becoming registered users. When a visitor registers with us, the visitor provides certain information in order to receive marketing literature, white papers and newsletters from Merkle or Merkle’s partners. Online visitor preferences are respected through the use of opt-in and opt-out processes. Merkle and its partners may use this information for their business purposes.
We may use Google Analytics and other partners for the following purposes:
- Google Analytics Demographics and Interest Reporting. Merkle uses data from Google's Interest-based advertising or third-party audience data (such as age, gender and interests) with Google Analytics to inform our marketing strategy.
Visitors can opt out of Google Analytics for Display Advertising and customize Google Display Network ads using Google's Ad Settings page.
Visitors can opt out of Google Analytics using this browser add-on.
For visitors to Merkle’s web site who are interested in working for us, Merkle collects the personal information that you provide when applying for open positions through our online career center. You may receive additional information from Merkle regarding your application at the address you provide.
We do not use any of the personal information you provide to Merkle to request information about Merkle’s products and services as part of your application for employment or for any other purpose. We do not sell or rent such information.
Governance. Merkle is committed to the issue of consumer privacy and has created a Security Governance Council (Council) led by executive management. The vision of the Council is to advance thoughts, ideas and capabilities around the use and security of information at Merkle.
The Council proactively engages in advocacy, compliance and emerging trends in information security and privacy. The Council oversees and supervises the implementation of all Merkle security and privacy policies.
7001 Columbia Gateway Drive
Columbia, MD 21046
email: [email protected]
Copyright © 2016, Merkle Inc. All Rights Reserved.
Effective Date: November 15, 2016