MSNI, Inc., (“MSNI,” “we” or “us”) deploys a wide range of data gathering, management, analytic and marketing services specifically geared to help our marketing partners direct relevant, data-driven marketing communications—including direct mail, inserts, email, digital, mobile and social media campaigns—to their customers and prospects, based on those consumers’ interests, activities and demographics.

MSNI is committed to protecting the information of its clients, as well as the customers and prospective customers of its marketing partners, and making all parties aware of our practices regarding the privacy of their information.
The DMA is associated with the Digital Advertising Alliance (“DAA”), and we adhere to the DAA’s Self-Regulatory Principles for Online Behavioral Advertising.

1. Types of Data That We Obtain

MSNI receives data from a variety of consumer and business-to-business marketing companies and services, data compilers and suppliers. We may also obtain data through public sources, such as census data and other public records. And we may also collect certain information when you visit our website(s) or our marketing partners’ website(s).
• This data may include Personally Identifiable Information (“PII”) and attributes linked to PII, as may be the case for demographic or interest-based data associated with PII. When we refer to PII we mean first and last name, postal address, telephone number or email address. Attributes linked to PII may include demographic, lifestyle and behavioral information, such as expressed interests and past purchases.
• We likewise may collect and/or connect information about consumers’ interests, online and offline activities (including website visits) or demographics that we may group into aggregated “Audience Segments.”
MSNI does not collect or use sensitive information such as Social Security numbers, credit card numbers, bank account numbers or medical information.
• MSNI deploys individual identifiers that we, or our marketing partners, create that are derived from PII but have been de-identified, through various means.
• MSNI may receive non–PII (e.g., pages viewed, browser type, time and date of visits) from visitors to our or our marketing partners’ websites. This data may be used to improve the operation of these websites, improve visitors’ experience to the websites, to identify or remediate possible threats to the website’s security, and for other operational and management purposes, as well as for “retargeting” relevant offers to visitors based on their web browsing activity.
• MSNI may also collect or receive information about consumers’ visits to websites and information regarding advertising exposure (“web log data”). Web log data may include browser type, IP address, type of ad served, and date of ad delivery. This information is used to optimize ad campaigns and measure their effectiveness. Web log data may also be used to provide ads about goods and services that are most likely to be of interest to individuals. Except as otherwise indicated in this Privacy Policy, we may combine, link or aggregate the various data we collect or obtain.

2. Use of Data

MSNI deploys marketing data for various purposes, including:
• Targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing;
• Measuring the effectiveness of both online and offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases;
• Analyzing and optimizing our marketing partners’ proprietary databases;
• Creating defined audience segments based on common demographics and/or shared interests or preferences (e.g., sports enthusiasts, frequent travelers, business leaders); these audience segments may consist of our marketing partners’ proprietary 1st party data, as well as 3rd party information and MSNI’s own proprietary data;
• “Retargeting” via direct mail, email, display, mobile and/or social media to the visitors to a marketing partner’s website (including both customers and prospective customers); in order to do this, we may deploy anonymous unique identifiers that enable the “retargeting” of consumers based on their web browsing experience, in a privacy sensitive manner;
• Related data services, such as (but not limited to) verification, record look-ups, anti-fraud, and other analytics and database tools.

3. Respect for Consumer Privacy and Choice

MSNI continually strives to enable its marketing partners to make good, responsible use of available marketing data without compromising consumer privacy or security. MSNI embraces and endorses the industry’s highest standards, and adheres to the following:
Email Marketing — We comply with CAN-SPAM and established email advertising and content guidelines. Consumers may always opt-out of MSNI email databases.
Audience Segments — We do not collect or work with social security numbers or personal medical records. Nor do we knowingly collect any information from (or offer our services to) children under the age of 13;
Opt-Out — We provide (or provide access to) multiple opt-out methods;
Notice — We require our online partners to provide appropriate notice and choice to their own customers and users as required by applicable legal standards and industry best practices.

4. Your Opt-Out Rights

Please reach us at our contact page to opt out of MSNI’s cookie-based marketing services for this website. If you wish to opt out of other third party ad platforms and ad networks (including ones we work with and may have transferred data to in the past), we also recommend visiting the opt-out pages offered by the Network Advertising Initiative and the DAA’s AboutAds program. Opting-out in this way will not prevent you from seeing ads; it will prevent targeted ads customized to what ad exchanges (and as to our opt-out, we) believe are most likely to be relevant and of interest to you.

5. How We Share Data with Third Parties

MSNI may share information it collects or receives, including PII, with customers, marketing services and platforms, and service providers that we retain, in order to provide the services we have described above (or other services we may add).
Partners: We may share information, including PII and Audience Segments, with business and data partners to help provide more tailored targeted communications. Likewise, we may do so for analytical purposes, to measure campaign performance, or inform future campaigns, or to handle, analyze, or segregate the PII and other data that we handle for customers.
Corporate transfers: If MSNI or its significant assets are acquired by or merged into another entity, our information will be transferred to that entity.
Affiliates, parent companies and subsidiaries: MSNI may share some or all of the information in our possession with our affiliated or subsidiary companies.
As Required by Law or to Protect Any Party: MSNI may disclose information if we believe that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or safety of MSNI or any other party.

6. Cookie Technology Cookies and how we use them

MSNI uses industry-standard technologies, including cookies and similarly functional technologies. We may work with third parties to provide or enhance our services (e.g. for purposes of retargeting and tailoring ads, or placing browser cookies). These partners may set and access their own cookies, pixel tags and similar technologies on your device, which may have cookies with varying expiration period. Those partners may, likewise, collect various types of anonymous or de-identified information about your browser, device, or browsing activities through use of these cookies.
Cookies are small data files that contain a string of characters, such as an anonymous unique browser identifier. Cookies are stored on your computer or other device and act as anonymous tags that identify your device, but not you personally. Our (or other companies’) servers send your device a cookie when you visit a website. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access these web pages, pixel tags generate a generic notice of the visit and permit us to set or read our cookies. Pixel tags are used in combination with cookies to anonymously track the activity on a site by a particular device. When you turn off cookies, pixel tags simply detect an anonymous website visit.
We and other online marketing platforms may use cookies to, among other things, “remember” you, determine visitor patterns and trends, collect information about your activities on our clients’ sites, or interact with the advertising you see. We use cookies to provide relevant content to you and replace non-relevant communications with ads that better match your interests.

Disabling Cookies

Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of our services and other services may be difficult to use or become inoperable.
In providing our services, we work with certain third-party companies that use techniques other than HTTP cookies to recognize your computer or device and/or to collect and record information about your web surfing activity, including those integrated with our services. These technologies may not respond to browser settings that block conventional cookies. You may opt out of many of these types of technologies by visiting the NAI’s opt out page at https://www.networkadvertising.org.

7. Data Collected Through Our Website Information Collected

MSNI collects information from users of our website(s) (including any page on which this Privacy Policy is posted), including:
• The domain name and IP addresses of users’ web browsers.
• Aggregate information on what user’s access, utilize or visit.
• Information, including PII, voluntarily provided by you, such as survey information, requests for information, credit card information, mailing addresses and email addresses.

How MSNI uses the Information We Collect Through Our Website

We use the information we collect through our website(s) to do the following:
• Provide services to you
• Respond to and communicate with you (including regarding news and updates about our services)
• Send you offers and ads for products and services of partner brands, or other offers we believe may be of interest to you
• Perform data analyses (including market research)
• We may combine the Information with other information we obtain from third parties, publicly available sources, and any other product or service we provide to further improve the relevance and effectiveness of products, and advertisements offered, including (but not limited to), those provided on or through our services.
• We may use IP addresses to help diagnose problems with our servers and to administer our website(s). We also may use IP addresses to help identify visitors to our website(s) for the duration of a session and to gather demographic information about our visitors. We may use clickstream data to determine how much time visitors spend on each web page of our website(s), how visitors navigate through the website(s), and how we may tailor our website(s) to better meet the needs of our visitors. We also use the information for compliance with our legal obligations, policies and procedures, including the enforcement of our Terms and Conditions.

How MSNI Shares the Information We Collect Through Our Websites

We may sometimes share or otherwise disclose the Information we collect about you, as described in this Privacy Policy or otherwise disclosed to you when you provide us with the information, including as follows:
• We may share the Information with service providers who help us deliver the services you request or we provide.
• We may share the Information to communicate with you and market to you, including through email, direct mail or display media.
• We will disclose your PII (or other information) if we believe in good faith that we are required to do so by law, regulation or other government authority or to protect the rights, safety or property of ourselves or any person or entity. We may also cooperate with law enforcement agencies in any official investigation and we may disclose any Information to the requesting agency in doing so.
• If we or all or substantially all of our assets, are purchased by another company (such as in a merger, consolidation, restructuring, the sale of stock and/or assets, or other corporate change or financing transaction), the Information in our possession will likely be transferred to the successor entity. We also may share the Information during the course of any due diligence process.
MSNI’s website(s) use cookies and similar technologies, both for its internal and operational purposes and to market to you (such as to retarget ads to you when you visit other sites across the Internet).

8. Links

This website may provide links to other websites that MSNI thinks users will find interesting or useful. MSNI is not responsible for the privacy practices of these other sites or companies.

9. Security and Data Integrity

MSNI takes steps to help ensure that the data we possess is housed and transmitted securely. This may include various types of physical and electronic security, including firewall protections, encryption, hashing or truncation of data, and access controls to PII. While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we employ efforts to ensure that this does not occur.

10. International Users

We may store, transfer, and process your data on servers located anywhere in the world, including inside or outside the United States or the European Union. Please note that the privacy laws, regulations, and standards of the United States and some other countries may not be equivalent to the laws in your country of residence. By using MSNI, Inc., Services  or by providing us with your information, you consent to this collection, transfer, storage, and processing of information to and in the United States.

GDPR: General Data Protection Regulations (GDPR) is a law that was adopted by the European Parliament in April 2016 and is enforceable as of May 25, 2018. The regulation applies to the collection, processing and movement of personal data for individuals residing in 32 European States (28 EU States + 4 in the EEA European Economic Area) listed as follows: Austria, Belgium, Bulgaria, Croatia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Rep. of Cyprus, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland and United Kingdom.

While in full compliance with the applicable, United States laws and regulations, MSNI, Inc., supports GDPR efforts to protect the privacy and data security of the EU citizens as they are residing in their subscribing country. To that extent, efforts are made to monitor and identify the data of EU citizens, isolating those records for special consideration and treatment.

11. Changes to this Privacy Policy

From time to time, we may update this policy. Please check back for any changes to this policy.

12. Digital Listening is trademarked and it’s term meaning, DigitialListening.com and EmailListening.com, including all of the Kazmash and Zagdat Intelligence along with SmartValidate and SmartSocial are owned exclusively by MSNI, Inc.

13. Contact Us

If you have questions related to this policy, or regarding MSNI’s products or services, please contact us.