We collect contact information. For instance, we may collect names, street addresses, telephone numbers, email addresses, and other contact information you provide. We also collect the contact information you provide about other members of your household, deceased individuals, or others you may care for when requesting Services on their behalf.
We collect payment, transaction, and preference information. We may collect information about which types of services you are interested in, including whether you wish to opt-out of promotional direct mailings, email, or phone call lists. We may also collect information about your relationship to a person for whom you request Services, which may include individuals you care for or who are deceased. Your payment information is collected by or on our behalf when you register and pay for or renew our 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 pixels in 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 the Services, 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, which may include age and date of death.
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 data such 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 vendors may 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 us or our vendors, for analytical purpose or to test, 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 or for internal operations. We may also use your information for general compliance purposes and to operate our business operations on 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, customers and their respective personnel or 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.
We collect information directly from you. For example, we collect information if you contact us, register for an account, 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 passively collect information about you and your devices. We collect information using these tracking tools when you interact with our Services (including our emails) that we or 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 engage to work on our behalf. For example, vendors that host or maintain our Services or 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.
We may receive information about you from someone acting on your behalf. We collect information submitted to us about household members, or others who are deceased, or may have caregivers or persons acting on their behalf in order to receive our Services. If you believe someone has improperly acted on your behalf, please contact us by email at ethics@ana.net.
We share your information with vendors and service providers who perform services on our behalf. We may disclose your information to our vendors we 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 to send emails 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 a threat 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 change in our corporate structure, such as with a merger or acquisition, we may include information as part of that transaction and/or the negotiation and diligence related to that transaction or our organization in general.
We may share your information with our subscribers to provide the services you requested. We may disclose your personal data to third party organizations that subscribe to or otherwise use our services for purposes of providing the Services you requested, such as your name, email address, mailing address, and other contact and demographic information which may include prefixes, suffixes, age, and date of death.
We may share information for other reasons we may describe to you from time to time or as permitted or required by law.
We may use cookies, web beacons, pixels, and other trackers as described in this Privacy Policy, including to recognize a user's device each time it is used and to visit our Services. Cookies can also track how you use our Services, and your preferences for features and functions.
You can disable or turn off certain cookies by changing the settings on certain Internet browsers or devices. If you block cookies, certain functionality of the Services may become impaired or disabled. For instance, by changing these settings you may later be required to 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 browser or if you clear your cache, you will delete settings associated 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.
If you click on a link to a site or service other than our Services, you may be taken to a website we do not control. This Privacy Policy does not apply to such other websites or services, and we encourage you to read the privacy notices that apply to them carefully.
While we strive to protect your information, we cannot guarantee the security of your information and your communications when using our Services.
In general, we offer you the ability to opt out of receiving emails and other communications from us in the future. Our email communications will provide you with instructions and the procedures you can use to opt out when applicable. Even if you opt out of receiving messages, we still may communicate with you as it relates to the Services, including but not limited to responses to your questions or inquiries.
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 maintain your personal data. You can also request access to that personal data.
Right to Portability. You can request that we provide a copy of the personal data we have collected or otherwise maintain about you in a portable format, 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 can request that we correct inaccurate personal data that we have collected about you. To the extent not prohibited by applicable 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 opt out from having their 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 you targeted 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 produce legal or other, similarly significant effects that concern you.
Exercising Your Rights. To submit your requests, please send us an email at ethics@ana.net, or write to us at the address listed below under the Contact Us section. Indicate in your message that 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 authenticate your request in accordance with applicable law. The authentication process will 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 Us section, and we will respond to your appeal as further detailed in our communication back to you.
Our websites and 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 data to us, please notify us at ethics@ana.net. You may be required to provide verifiable identification that you are the child's parent or legal guardian.
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 data as set out in the updated Privacy Policy.
Information we collect may be transferred to, processed in, or stored in the United States. Our Services are subject to United States laws, which may not afford the same level protection as those in other countries.
For questions about this Privacy Policy please email us at ethics@ana.net or write to us at Attention: DMAchoice Privacy Policy, ANA Center for Ethical Marketing | 2020 K Street NW, Suite 660 | Washington, DC 20006, and please specify you are inquiring about the DMAchoice website or services to help us better assist and respond to your questions.