Last Revised: January 1, 2020
Table of Contents
Information We Collect
How We Use Your Information
How We Disclose Your Information
Retention & Storage of Your Information
Links to 3rd Party Sites
How to modify your Information or Preferences
Changes to this Policy
Catalina Marketing Corporation and its subsidiaries (“Catalina”, “Group”, “we”, “us”, or “our”) know that you care about how your personal information is used and shared, and we take consumer privacy seriously. For more than 35 years we have employed the highest standards of protection for the personal information we collect or maintain across the globe. We continuously strive to strengthen our personal information protection measures to maintain the consumer trust that is paramount to our continued success and to that of our business partners and clients.
Catalina provides mobile, online and in-store personalized digital media solutions, including in-store and digital coupons and shopper-based communications. Under the European Union General Data Protection Regulation (“GDPR”), when applicable, Catalina Marketing Corporation is the data controller responsible for processing Catalina Personal Information collected on the Site.
Information We Collect and Use
We collect and use Catalina Personal Information to administer and improve our Site, to process your requests, to provide our products and services, for any specific purpose described at the time of collection, and for the purposes described below.
- Personal identifiers. We collect personal identifiers (such as your name, telephone number(s), and email address(es), as well as internet or network activity, cookies, and geolocation) you submit to us when you request a demonstration, post comments or reviews, or participate through the Q&A forum through a Site. We use this information to provide and improve our services and for marketing purposes.
- Commercial Information. We receive commercial information from our clients, and we use this information to perform our services and for marketing purposes.
- Content of submissions. We receive the information you submit to us when you contact us, post to our social media pages, and submit information through our customer service forms. We use this information for communications, to improve our services, and for marketing purposes.
- Professional or employment information: We receive information you submit on our careers page on the Site. This may include contact details, personal details, education details (including qualification, attendance at educational establishments and training received), and professional and employment details (including details of previous roles), information from public records, job preference information, and any other information you submit in connection with your application.
- Inferences: We draw inferences from the personal information we collect, and these inferences are used for the same purposes as for which the information was collected.
Our third-party partners may collect and combine information collected on the Site with other information about your online activities over time, on other devices, and on other websites or apps, if those websites and apps use or share data with the same partners.
With respect to any social media pages that we may use, please see the privacy policies and any cookie policies of the applicable social media providers as to their automatic data collection practices.
How We Disclose Your Information
We may disclose the Catalina Personal Information we collect (as described above) for our business and commercial purposes to assist us in providing services, to comply with the law, or to improve our marketing efforts, and as further described below.
- Vendors and Service Providers. We disclose any of the Catalina Personal Information we process to third-party vendors, service providers, contractors or agents who support us in providing the Site and our services.
- Our affiliates within the Catalina group of companies. We disclose Catalina Personal Information to our affiliates in order to provide the Site and our services, and for administrative purposes.
- In Response to Legal Process. We may disclose the information we process with law enforcement, the courts, our advisors, attorneys, and others who participate in the legal process in order to comply with the law, including in connection with a judicial proceeding, court order, subpoena, or other legal requirement.
- Merger, sale, or other asset transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, Catalina Personal Information may be shared under an obligation of confidentiality in connection with the negotiation of such transaction, and your Catalina Personal Information may be sold or transferred to the persons and/or entities assuming control of such business unit and our advisors as part of such a transaction.
- De-identified Information. We share aggregated and de-identified information with third parties for marketing or for research and other business purposes.
Retention and Storage of Catalina Personal Information
Catalina will store and retain your information as long as reasonably necessary and in accordance with our data retention policy, to provide our services, fulfill our internal business requirements, and to comply with legal obligations including as set forth under a contract involving such Catalina Personal Information.
Catalina has implemented and will maintain reasonable measures to protect the privacy and security of Catalina Personal Information. Our Global Security and Privacy (GSAP) organization focuses on the privacy and security of Catalina Personal Information, and we treat our clients' and customers' data with the same level of care and protection as our own. For example, we follow industry practices in implementing a layered defense strategy to safeguard Catalina Personal Information. However, despite our best efforts, no information transmitted over the internet or stored electronically is 100% secure.
Links to Third-Party Sites
Our Site is intended for a general audience and is not intended for use by children under the age of 18. We do not knowingly collect Catalina Personal Information from any visitor under the age of 18. If we become aware that information from a child under 18 has been collected without the consent of such child's parent or guardian, we will promptly delete such information. If you are a parent of a child under 18, and you believe that your child has provided us with Catalina Personal Information about himself or herself, please contact us at firstname.lastname@example.org.
INTERNATIONAL DATA TRANSFERS
You understand that we may transfer your Catalina Personal Information to Europe, the United States, and other countries, to the extent permissible under applicable law, and accordingly, your Catalina Personal Information may be subject to privacy laws in other jurisdictions. Please see the provisions below under “Individuals located in the EEA” regarding transfers from the European Economic Area.
MARKETING PREFERENCES AND OPT-OUT
U.S. residents can opt out of receiving personalized advertisements on their browser or device from advertisers or other advertising networks who are members of the Digital Advertising Alliance (DAA) (www.aboutads.info/choices) or the Network Advertising Initiative (NAI) (www.networkadvertising.org/choices/). Note that when you opt out of personalized advertising, you may still continue to see online advertising on the Site and you may still see ads on other websites and online services.
Email marketing opt-out: Following receipt of an email marketing opt-out request from you, we will take reasonable steps to prevent further email marketing to you. If you opt-out of marketing communications, you will continue to receive transactional communications about your purchase(s), and other administrative information. Please note that removal of user information from our database or "opting-out" will not stop marketing or advertising content that has already been generated for distribution or is otherwise queued for transmission to you prior to the time when we can implement your request. Upon opting out, your information will remain in our database, but will be marked as inactive so you do not receive marketing materials from us.
If any questions remain about these processes, you can e-mail us at email@example.com. If you have registered for an account with us, you may update your Catalina Personal Information by logging in to your account.
Your Privacy Rights
Certain jurisdictions impose specific legal requirements and data subject rights with respect to Catalina Personal Information, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to review, correct, and delete Catalina Personal Information we have about you, or to consent or withdraw consent to certain uses or sharing of Catalina Personal Information.
Please note that, when you make a request, we may require that you provide information and follow procedures so that we can verify your identity (and so that we can determine the applicable jurisdiction). We will respond to your request within the time period required by applicable law. However, we may not always be able or required to comply with your request, in whole or in part, and we will notify you in that event. As permitted by applicable law, we may charge a reasonable fee to help cover the cost of responding to your request, and we will inform you of the fee before completing your request. Specific provisions for some jurisdictions are set forth below.
We will take steps to verify your identity and jurisdiction and determine whether the request is authentic, before we process your request. The verification steps we take may differ depending on the request you make. Where possible, we will attempt to match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us do so.
Catalina has developed a privacy portal to handle data subject rights requests. Should you have any questions or concerns about our portal please contact firstname.lastname@example.org.
The following links provide access to our consumer and data subject request portal to facilitate you exercising your privacy rights.
If you are a Catalina European or Japanese customer (Retailer), you may click here.
If you are a Catalina U.S. customer (Retailer), you may click here.
If you are a C-Wallet, Coupon Network, or Cellfire customer you may click here.
If you are a Catalina employee, applicant, or former employee, you may click here.
If you are a California resident and wish to exercise your right of Do Not Sell My Data, you may click here.
California Residents. If you are a California resident, you may have certain rights in relation to our processing of Catalina Personal Information as to which we are a “business” under the California Consumer Privacy Act (“CCPA”). A California consumer has the following rights under the CCPA: to request additional information about our data collection, use, disclosure, and sales practices in connection with the consumer’s personal information; to request the specific personal information collected about the consumer during the previous 12 months; and to request the deletion of the personal information we have about the consumer (subject to various exceptions and limitations). To make a request you may email us at email@example.com or contact us through the request portal using the links above. In most cases, you will be required to provide your name and business contact information, including business email address so that we can verify your request, and in some cases additional information may be required. A California consumer also has the right to direct us to not sell the consumer’s personal information. To make an opt-out request, please go to Do Not Sell My Info. A California consumer may not be discriminated against for exercising the consumer’s California privacy rights.
Under the CCPA, California consumers may use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that demonstrates authorization to submit a request for the California consumer. An authorized agent must follow the process described above to make a request, and we will also (a) require the authorized agent to verify the agent’s own identity and (b) confirm the agent’s authority with the California consumer about whom the request was made.
Individuals located in the EEA. You are entitled at any time to request information about your Catalina Personal Information that we store, and request that we rectify, erase or restrict the processing of your information or object to the processing of your information. An objection to data processing only has future effect and may require that the contractual relationship between us be terminated – because we cannot fulfill our obligations to you without processing your information. You also have the right to data portability, if the EU General Data Protection Regulation (GDPR) applies to your Catalina Personal Information.
You may also at any time withdraw any consent given, with future effect.
Further, you may submit a complaint to the responsible data protection supervisory authority if you believe that we cannot sufficiently help you.
We may transmit Catalina Personal Information collected from individuals located in the EEA to countries outside of the EEA that do not offer the same level of protection with respect to Catalina Personal Information as required in the EEA and where there is no adequacy decision by the European Commission. Catalina takes a variety of steps, including implementing approved data transfer tools like standard contract clauses approved by the European Commission or by choosing recipients that are Privacy Shield certified or have BCRs in place, to help ensure your rights and protections travel with your Catalina Personal Information. If you have any inquiries about our handling of your Catalina Personal Information, or would like to obtain more information about the respective data transfer tools used, please contact us at DPO@catalina.com.
How to Modify Your Information or Preferences
Catalina has provided in this Policy information on how you can change your preferences, including opt-outs, with respect to marketing or advertising by Catalina. If you have any questions, you can e-mail us at firstname.lastname@example.org. If you have registered for an account with us, you may update your Catalina Personal Information by logging into your account.
If you have any other questions about this Policy, please contact us through our Site or by email us at email@example.com.
Changes to this Policy