It does not apply to information collected by:
Personal information means information that specifically identifies an individual person, such as name, mailing address, email address, phone number, or account number. It may also include other information about you, such as gender, date of birth, or other demographic information, or about your use of the Site, such as IP address or cookies, if that other information is linked to your personal information.
Listrak collects personal information that you provide to us. For example:
We also collect some of your information automatically when you visit this Site or log on to the Platform. For example, this Site collects your Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referring/exit pages, the files viewed on our Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data and records the pages that you visit and other information about your activity on the Site. The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized Service, including by enabling us to:
Like many other websites, we ask you to allow us to use “cookies” and other technologies to remember information about you and improve your browsing experience on our Site. If you reject cookies, you may still use our Site, but your ability to use some features or areas of our Site may be limited. The technologies we use for this automatic data collection may include:
We also may receive your information from another party that has collected it from you, such as our clients or your employer, so that we can contact you or so that you can access our Services in furtherance of their business. Their collection of your information is governed by their own privacy policies. If you believe that we received your personal information and you would like to request that it be removed from our database, please contact us at firstname.lastname@example.org.
Listrak may use your personal information to:
Listrak may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may also disclose your personal information:
Listrak may also use personal information for internal purposes, such as to monitor the performance of its Platform, or to track the effectiveness of and improve its Services. Listrak may also share aggregate, deidentified, or pseudonymous data with third parties.
Listrak follows generally accepted standards to protect personal information and information submitted by our clients, both during transmission and once we receive it. Listrak maintains all information in systems protected by firewalls and other security technologies. These measures are designed to protect information from loss, misuse, or unauthorized alteration. Listrak employs various information security mechanisms and internal policies and procedures to protect information from disclosure to unauthorized third parties. Listrak routinely audits its practices and policies to meet industry standards for data protection. Listrak provides an encrypted, password-protected mechanism for logging in, viewing, uploading, and extracting client data on our Platform.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site. The information you share in public areas may be viewed by any user of the Site.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the site.
Personal information provided to Listrak by its clients remains the property of its clients. If you have any questions about the security of your personal information, you can contact us at email@example.com.
Our Site is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Site. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Site or through any of its features, register on the Site, use any of the interactive or public comment features of this Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at firstname.lastname@example.org or 877-362-4556.
As part of our commitment to maintaining the privacy of your personal information, Listrak complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce.
Listrak has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) regarding the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. Listrak has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) regarding the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.
Listrak is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Listrak acknowledges potential liability in cases of onward transfer of personal data to third parties who do not meet the criteria as set forth in this Policy. Listrak complies with the EU-U.S. DPF Principles and Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU or Switzerland, including the onward transfer liability provisions.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. This third-party dispute resolution program is specifically designed to resolve EU-U.S. DPF and Swiss-U.S. DPF-related complaints with no cost to you. If neither Listrak nor our third-party dispute resolution provider resolves your complaint, you may pursue resolution through the methods provided by the EU-U.S. DPF Principles annexes thereto.
You have the right to access personal information about you that Listrak has collected through this Site by sending a request for access to email@example.com or calling our toll-free number 877-362-4556. You can also request that we correct or delete any such information by using the same methods. To verify that the request is authentic, we will match the identifying information provided by the requestor to the personal information of the requester already maintained. For example, we may require that the requester send such request from the email address associated with the personal information. While we will comply reasonably and respond to your request within the timeframe required by applicable law, we may need to retain some of your information for our own record keeping or to fulfill a legal obligation. You will not receive discriminatory treatment should you decide to exercise any rights set forth in this Policy.
You have the rights (i) to restrict the processing of your sensitive personal information; (ii) to opt out of the sale of your personal information; (iii) to opt out of the sharing of your personal information for cross-contextual behavioral advertising, targeted advertising, and sales; and (iv) to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects to you.
You have the opportunity to choose (i.e., opt out) whether your sensitive personal information is (i) to be disclosed to a third party, or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you.
You may exercise any of these rights by sending a request to firstname.lastname@example.org or calling our toll-free number 877-362-4556.
Listrak’s clients use our Platform to contact consumers. If your information was collected by one of Listrak’s clients or some other third party, you must contact that party with any questions or concerns about its use of your personal information. That party’s privacy practices may differ from those of Listrak. This Policy is not intended to supersede or govern the privacy policies and practices of Listrak’s clients or any other third party.
Listrak, as a Service Provider, collects information under the direction of our clients and has no direct relationship with the individuals whose personal information may be processed as part of providing our Services. Any requests that Listrak receives while acting as a Service Provider will be denied and the consumer will be directed to submit the request directly to the Listrak client. Listrak may transfer personal information to vendors that help us provide Services. Access to your personal information by these vendors is limited to the information reasonably necessary for the vendor to perform its limited function for us. These vendors must abide by our data privacy and security requirements and are not permitted to use your personal information for any other purpose. Representative business processes that our vendors assist us with include:
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”
For more details about the personal information that we have collected, including the categories of sources, please see below.
We obtain the categories of personal information listed above from the multiple categories of sources, including you directly, internet service providers, data analytic providers, and operating systems and platforms. For additional details about the methods and manner of collection, see the “How your information is collected” section, above.
We collect this information for the business and commercial purposes described in the “What we do with your information” section above.
We share this information with the categories of third parties described in the “Disclosure of your information” section, above. Within the preceding twelve (12) months we have shared or disclosed the following categories of personal information with our trusted service providers or third parties:
Listrak does not sell (as that term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies for our advertising purposes as further described in our “How your information is collected” section, above.
Subject to certain limitations, the CCPA provides California consumers a right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at email@example.com. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
You have the right to know and see what data we collected about you. This includes:
You have the right to request that we delete the personal information we have collected from you (and direct our service providers to do the same), subject to certain exceptions, including when such information is necessary to complete your transaction or to provide you the requested services. We may deny your deletion request if we cannot verify the request or if retaining the information is necessary for us or our service provider(s) to:
You have the right not to be discriminated against for exercising any of the rights listed above. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
To request access to or deletion of your personal information, or to exercise any other data rights under California law, please contact us at firstname.lastname@example.org. You may also utilize the link on our website, www.listrak.com.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may also make a request to know or delete on behalf of your child. You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You do not need to create an account with us to submit a request to know or delete. We will only use personal information provided in the request to verify the requestor's identity or authority to make it.
We aim to respond to a consumer request for access or deletion within ten (10) days of receiving requests for disclosure or deletion with information on how the request will be processed. If we need additional time the reasons for that will be stated to you within the ten days. Any substantive response to the request will be given within 45 days of receiving a verified request.
We will deliver our written response by mail or electronically, matching how we received the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
If you subscribe to our email newsletter(s), we will use your name and email address to send our marketing/update emails to you. You may choose to stop receiving our marketing/update emails by following the unsubscribe instructions in those emails, or you can contact us at email@example.com.
You may also contact us as follows:
Postal Address: Listrak, 100 West Millport Road, Lititz, PA 17543