Privacy Policy

Last Revised: January 1, 2020

Table of Contents

Introduction
About Us
Information We Collect
How We Use Your Information
How We Disclose Your Information
Our Use of Cookies & Other Tracking Mechanisms
Retention & Storage of Your Information
Security
Links to 3rd Party Sites
Children
Advertising Preferences
Your Rights
How to modify your Information or Preferences
Contact Us
Changes to this Policy

Introduction

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.

Our privacy program guides the way we conduct business each day. This Privacy Policy applies to the personal information we collect from individuals who visit the website on which this Privacy Policy is posted or our social media pages (together, our "Site"). This Privacy Policy explains how we store, use, disclose and protect personal information we collect and how you can exercise your rights regarding your personal information. By using or accessing our Site, you agree to the collection, storage, use and disclosure of your personal information as described in this Privacy Policy.

Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or household (collectively in this Privacy Policy “Catalina Personal Information”).

About us

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.

Information automatically collected. When you visit a Site (other than social media pages), we and certain third parties, including analytics providers and advertising networks, collect Catalina Personal Information by automated means, such as through the use of cookies, web beacons, and web server logs. We and these third parties may collect personal identifiers (such as IP address and device identifiers and characteristics like your browser type and operating system) and your browsing activity on the Site (including the links you click, the length of time you visit our Site, and the referring URL or website that led you to our Site).

We use cookies and similar technologies to learn how you use our Site so we can provide and improve the Site and our related services and to provide personalized content and advertising to you on our Site and other websites and online services. Under the GDPR, when applicable, the basis for processing this Catalina Personal Information is the performance of the contract with you (i.e. to fulfill your request), as well as our legitimate interest in being able to provide and improve the functionalities of our Site and to provide you with information we think will interest you. In some cases, the basis for processing may be your consent provided upon accepting our cookie alert when you arrived at the Site.

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.

You can see more specific information about cookies and other technology in the Cookie Policy for the Site you are using. You may see the Cookie Policy for www.catalina.com at https://www.catalina.com/cookie-policy/.

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.

Information collected from third-parties. Catalina works closely with many third parties and receives and processes Catalina Personal Information/Information from such third parties. Catalina protects Catalina Personal Information obtained from third parties in accordance with the practices and policies described in this Privacy Policy, in addition to the obligations and restrictions imposed by the third-party source of the Catalina Personal Information. For example, we may receive demographic data to enhance our database to tailor the advertising, content and information that we may send or display to you and to improve our services and Site. The basis for processing this Catalina Personal Information is your consent or the adequate performance of the contract with you or between you and these third parties.

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.
  • To Protect Us and Others. We may disclose Catalina Personal Information we process where we believe it is necessary to investigate, prevent or take action regarding illegal or unauthorized activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use, or as evidence in litigation in which we are involved.
  • 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.

Security

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.

From time to time, the Site will provide links to third-party websites. These links are provided as a convenience to you. The third-party websites are operated by the respective third parties with their own privacy policies. This Privacy Policy does not apply to such other websites or to the use that those third parties make of your information. Catalina has no control over the content displayed on such websites, nor over the measures, if any, that are taken by such websites to protect your information.

Children

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 privacy@catalina.com.

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

Cookies: We implement a cookie banner on the Site to notify visitors that their data is being collected and will be used for certain purposes, and to obtain consent to collect and use the data. The help feature on most browsers will provide you with information about how to change browser settings to notify you when you receive a new cookie, how to delete cookies, or how to disable cookies altogether. You may use our Site if you have disabled cookies. Note, however, that without cookies you may not be able to use all the features of the Site. Note that our Site does not respond to browser do-not-track signals and your device may not give you the ability to control cookies. You can see our Cookie Policy at https://www.catalina.com/cookie-policy/.

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 privacy@catalina.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 privacyteam@catalina.com.

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 privacyteam@catalina.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.

We do not sell Catalina Personal Information collected through our website for monetary consideration; however, in the prior 12 months, we have permitted third parties to use Catalina Personal Information for their business and commercial purposes that may not directly benefit Catalina (such as for their or others’ marketing purposes). This may be considered a “sale” of Catalina Personal Information under the CCPA. As addressed in the notices of the third-party cookie providers identified on our Cookie Policy, some of those third parties may use cookies and similar technologies to collect and use the following categories of Catalina Personal Information: personal identifiers (including device identifiers), commercial transaction information, Site browsing activities, and inferences drawn from these categories. We do not knowingly sell or permit the sale of the Catalina Personal Information of individuals under the age of 16.

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.

If you have any questions regarding this Privacy Policy, you may contact the Catalina Data Protection Officer at DPO@catalina.com.

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 privacyteam@catalina.com. If you have registered for an account with us, you may update your Catalina Personal Information by logging into your account.

Contact Us

If you have any other questions about this Policy, please contact us through our Site or by email us at privacyteam@catalina.com.

Changes to this Policy

We reserve the right, at our discretion, to modify our privacy practices and to update and make changes to this Privacy Policy at any time. If we make any changes, we will change the last revised date above and post the new Privacy Policy here: https://www.catalina.com/privacy-policy/any changes will be effective immediately upon the posting of the revised policy. If we make any material changes, we will let you know through the Site or by email or other communication. You should consult this Privacy Policy regularly for any changes.