Commerce Signals Privacy Notice

This notice was last modified on and has an effective date of June 28, 2024.

This Privacy Notice (“Notice”) provides information about how Commerce Signals, Inc. (“Commerce Signals,” “we,” “us,” or “our”), a subsidiary of Trans Union LLC (“TransUnion”), handles personal information and describes the rights you may have regarding your personal information. This Notice applies when you interact with https://www.commercesignals.com/ or another Commerce Signals-branded website that links to this Notice (the “Sites”). Use of our online and offline services constitutes your agreement to the terms of this Notice. If you do not agree with the terms of this Notice, please do not use our services.

This Notice does not cover practices of other TransUnion businesses or products, nor your interactions with us as a job applicant. Please see those respective privacy notices for more information on those privacy practices.

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Notice at Collection: We collect personal information as detailed in this Notice. The categories of personal information that we collect are listed below under “Personal information we collect,” and the purposes for which we collect and use personal information are listed below under “Purpose for collecting and use of personal information.” To learn more about your privacy rights, including your right to opt out of the sale or sharing of your personal information, please navigate to the “Privacy rights and choices” section below. Our retention practices are outlined below under “Retaining personal information.”

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1. Personal information we collect

In the past 12 months, we may have collected the following categories of personal information from you:

Information You Provide Directly. We may collect the following categories of data from you directly, such as when you fill out a form on the Sites; sign-up to receive direct marketing communications on the Sites; sign-up to a feature that we offer on the Sites and you provide your personal information in connection with that feature; attend an event that we or one of our affiliates (a “TransUnion Company”) has organized; or communicate with us (for example, on a social media platform or by sending us an email):

• Identifiers, such as name, physical address, email address, and telephone number;
• Any other information that you choose to provide to us, such as the reason for an inquiry submitted to us or your product preferences; and
• Professional and employment-related information, such as titles, business addresses, and contact details about our customers and their representatives.

Information Collected Automatically. When you visit our Sites, we may collect the following categories of data by automated means from the devices and browsers that you use:

• Internet or Other Electronic Network Activity Information. We collect information such as your device ID or advertising ID; IP address; operating system name and version, browser type and version, domain, and other system settings; the language your system uses and the country and time zone where your device is located as well as the computer type (Windows or Macintosh), screen resolution, device manufacturer and model, and the name and version of the platform you are using; the address of the web page that referred you to our Sites; and information about your interaction with the Sites, such as which pages you visit.
• Cookies & Similar Tracking Technologies. We collect this information using technologies such as cookies, non-cookie-based tokens, web server logs, tracking pixels, and web beacons. Cookies are files that websites send to your computer or other Internet-connected device to identify your browser uniquely or to store information or settings in your browser. Non-cookie-based tokens are encoded URL-based identifiers that track email click-thru activity or time-sensitive password reset keys and will work in scenarios where cookies are disabled, or a session has not been initiated. Some of these technologies are necessary to ensure the site functions properly, and some enable us to deliver an individualized online services experience. Please see the “Privacy Rights and Choices” section below for information about your choices with respect to cookies.
• Social Media Widgets. The Sites may include social media functions, such as X, LinkedIn, and Facebook widgets. These widgets may collect information about which pages you visit on the Sites and the IP address of the device you use to connect to the Internet. The widgets may also set a cookie to ensure the features are functioning properly. Social media functions and widgets are hosted either by a third party or directly on the Sites. Your interactions with the social media functions and widgets located on the Sites are governed by the privacy policies of the companies that provide them. If you use any of the social media functions or widgets on our Sites, we strongly suggest you review the privacy policies of the companies that provide those functions and features.

Information Collected From Third Parties. Where permitted by law, we may also acquire personal information about you from third parties, such as TransUnion Companies or third-party marketing agencies. We may also source personal information from publicly available profile information (such as your preferences and interests) on third party social media sites (such as Facebook and X). We may also collect personal information in other contexts that we will notify you of at the time.

2. Purpose for collecting and use of personal information

We may collect the above categories of personal information for different purposes. For example, we may use it in the following ways: 

• Respond to your inquiry, contact you about your request, ask a question, provide announcements about products and future events, conduct surveys, and to contact you for other reasons related to offering and improving our services;

• Administer and facilitate use of the Sites, improve website performance, evaluate how you interact with the Sites, and customize and enhance your visits to our Sites, such as by recognizing you as a customer or previous visitor to our Sites, identifying your preferences on the Sites, or pre-populating forms;
• Operate, evaluate, and improve our business and develop new products and services;
• Perform market research;
• Advertise and market our products and services and determine the effectiveness of our advertising and marketing; and
• Analyze our products, services, and websites.

We may also use the information for security purposes and to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We may also use your personal information for other purposes disclosed at the time you provide your personal information or otherwise with your consent.

3. Disclosing personal information for business purposes

We may disclose the above categories of personal information to third parties for the following business purposes:

Third-Party Vendors and Service Providers. We may disclose personal information to service providers that perform services on our behalf (such as payment service providers, analytics providers, and hosting providers and advisers) for a variety of business purposes, including to facilitate the provision of our Sites or other services to you or for advertising or analytics purposes.

Affiliates. We may disclose personal information to other TransUnion Companies for a number of reasons, including because you have requested information about our affiliates’ products and services.

Business Transfers. We may disclose your information in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Legal Purposes. We may disclose personal information about you (a) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, and (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity.

We do not sell your personal information for money. However, some of our Sites may use standard analytics and advertising tools that enable our analytics and marketing partners to collect Internet or other electronic network activity information, including to serve you advertisements that are relevant to you based on your activity across our services and other sites (“targeted advertising”). You can exercise your right to opt-out of our sale or sharing/processing of your personal information for targeted advertising and make other choices related to our use of these technologies using the Cookies Settings link located in the footer of our website.

4. Our products and services

We also collect and use data to provide our products to our customers, including our audiences, insights, measurement, and enrichment products. To provide these products, we rely on commercial data that has been de-identified before we receive it, including by removing names, email addresses, and other similar identifiers. We treat this data as de-identified because we maintain policies and technical measures to avoid tying this data to such identifiers. We may also collect demographic data from third-party vendors and identifiers from our customers (including online advertising identifiers) to provide these products, and we may also derive inferences from the data we have collected. 

To provide these products, we may disclose pseudonymous identifiers to affiliates or third-party vendors performing services on our behalf. We do not otherwise disclose this data to third parties except in an aggregated manner, such as when we disclose aggregated marketing or measurement insights to our customers.

5. Privacy rights and choices

We offer you certain choices about how we communicate with you and what information we obtain from you. You may have the following choices related to your personal information:

Opt Out of Marketing Communications. You may opt out of marketing communications from us by following such instructions as may be provided in the communication. We also recommend that you visit the Association of National Advertisers (ANA) and register on their consumer website:
https://www.dmachoice.org/.

Cookies & Online Tracking Technologies. You generally have the ability to accept or decline most types of cookies. Most web browsers give you a choice to modify your browser settings to decline some or all non-necessary cookies. We provide you choices to manage your privacy and selling/sharing in the cookie notice displayed on our website. Not accepting cookies may make certain features of the site unavailable to you. In addition, you may be able to opt through certain of our analytics and marketing partners. For example, to learn how to opt out of Google Analytics, visit: https://tools.google.com/dlpage/gaoptout. Some of these opt-out mechanisms must be exercised on each device and browser that you wish to have opted out. We do not respond to browser Do Not Track requests.

Analytics Disclosure: We use Google Analytics 360, including Google Tag Manager and Google Ads. If you would like to learn more about Google Analytics, or opt out of this data collection and sharing activity, please use this link: https://www.google.com/policies/privacy/partners/. Please visit our Cookies and Similar Technologies Notice for information regarding our tracking technologies.

Targeted Advertising. You may choose to opt out of digital advertising of many companies through the NAI’s Consumer Opt-Out Program or DAA’s Consumer Choice Page. By clicking on the “Opt-Out” links below, you will be directed to the respective third-party website where your computer will be scanned to determine who maintains cookies on you. At that time, you can either choose to opt out of all targeted advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintain a cookie on your machine.

• Network Advertising Initiative (NAI) Opt-Out: https://www.networkadvertising.org/managing/opt_out.asp
• Digital Advertising Alliance (DAA) Opt-Out: https://optout.aboutads.info

Consent. As allowed by applicable law, you may withdraw consent you previously provided to us.

Jurisdiction-Specific Privacy Rights and Choices

Depending on where you live, you may have certain additional rights, including:

• Access to your personal information in a portable format, or other information about our data processing practices;
• Deletion of the personal information we have collected from you;
• Correction of the personal information we have collected about you; and
• Opt-out of the sale or sharing/processing of your personal information for targeted advertising.

We do not discriminate against you based on your exercise of your privacy rights, although some of the functionality and features available on our Sites may change or no longer be available to you. You may also have the right to appeal a denial of your privacy rights. If you live in a jurisdiction where you have the right to appeal any denials of your requests, you may file your appeal using the same mechanisms discussed below.

Note that we do not process sensitive personal information, or process personal information for profiling in furtherance of decisions that produce legal or similarly significant effects.

Access, Deletion, and Correction Rights. You or your authorized agent may exercise your access, deletion, and correction rights by contacting us via the methods in the “Contact information” section below. We may ask you to provide information that will enable us to verify your identity in order to comply with your request. You may designate an authorized agent to make a request on your behalf. We may request that you provide your authorized agent with signed, written permission demonstrating that they have been authorized by you to act on your behalf.

Sale and Sharing/Processing for Targeted Advertising. You may exercise your right to opt-out of our sale or sharing/processing of your personal information for targeted advertising using the mechanism described in the Cookie Settings section above.

We also support the Global Privacy Control, which is a browser-based opt-out preference signal that communicates your privacy preferences to the websites you visit. For more information on the Global Privacy Control, please visit their website here. Note that because the Global Privacy Control and other choices available to you may be a browser-based mechanism, your opt-out preferences will apply only to the browser from which you exercised that choice. You are welcome, however, to enable the Global Privacy Control on all of your browsers and devices.

To the extent that we otherwise sell or share personal information outside our use of standard analytics and advertising tools, you may request to opt out by contacting us below.

Human Resources Data – California Only. If you are a California resident seeking to exercise your privacy rights regarding either human resources data (collected from current or former employees or applicants as part of the application process or employment relationship) or business-to-business customer data (collected from business customers or representatives in the performance of services or marketing outreach) please submit a request via the contact methods in the “Contact information” section below.

Business-to-Business Data – California Only. If you reside in California, you may also have these rights if you have a commercial relationship with Commerce Signals. If you are a customer of, or otherwise have a business-to-business relationship with, Commerce Signals, you can submit a privacy request via the contact methods in the “Contact information” section below.

6. Privacy requests via authorized agent

Using an authorized agent (with or without power of attorney) to submit an opt-out request: In order to submit an opt-out request on behalf of another, please provide written permission, signed by the applicable requestor, authorizing the agent to submit the opt-out request. The name of the agent submitting the request must match the name on the authorization.

In order for us to locate the requestor’s record, please also include the requestor’s first and last name (middle name optional) and their address (including unit number, city, state, and zip code). You may also provide the requestor’s Social Security number and date of birth. While those fields are optional, this information makes it easier for us to locate the requestor’s information and complete the request.

Using an authorized agent without power of attorney to submit a verifiable privacy request for access, correction, or deletion of a requestor’s personal information: In order to submit a verifiable request for access, correction, or deletion on behalf of another, an authorized agent without power of attorney must provide one item from each of the two sections below.

1. Signed permission from the applicable requestor authorizing the agent to submit the verifiable privacy request on their behalf, including a description of the type of privacy request(s). The name of the agent submitting the request must match the name of the authorization.
2. The applicable requestor must verify their own identity directly with us by submitting information or documentation that provides sufficient proof of identification, such as:

     a.  a Social Security number or a copy of a Social Security card issued by the Social Security Administration,

     b.  a certified or official copy of a birth certificate issued by the entity authorized to issue the birth certificate, or

     c.  a copy of a driver’s license or an identification card issued by the motor vehicle administration or any other government issued identification.

This secondary identification must include or reference the same name as stated in the signed permission form. The submission must also include sufficient information for us to locate the requestor’s file.

Using an authorized agent with power of attorney to submit a verifiable privacy request for access, correction, or deletion of a requestor’s personal information: In order to submit a verifiable request for access, correction, or deletion on behalf of another, an authorized agent with power of attorney must provide the valid power of attorney executed under applicable law. The submission must also include sufficient information for us to locate the requestor’s file.

Documentation may be sent via the contact methods in the “Contact information” section below.

To protect the confidentiality of your data, you and/or your authorized agent may choose to submit your data using confidentiality features offered by your email provider.

All personal information provided as part of this process will be deleted after verification has been completed.

7. Personal information of children

Our services are not intended for use by nor directed to individuals under the age of eighteen (18). If we learn that we have collected or received personal information from individuals under the age of eighteen (18), we will delete the personal information or otherwise comply with applicable law. We do not knowingly sell personal information of children under the age of eighteen (18).

Parent or Guardian Privacy Opt-Out Request (child under 18 years)

If you believe we have collected personal information from individuals under the age of eighteen (18), a parent or guardian may make a data privacy opt-out request (subject to limitations and exceptions under applicable law) via the contact methods in the “Contact information” section below.

8. Securing personal information

We maintain a comprehensive information security program with administrative (policies, standards, and processes), physical, and technical controls designed to protect the confidentiality, integrity, and accessibility of personal information.

9. Retaining personal information

We retain personal information for as long as necessary to fulfill the purposes for which it was collected or processed, as previously described in this Notice, and consistent with applicable laws. For instance, we retain personal information, collected through our services and websites, for as long as a user’s account is active or as needed to provide services to our customers.

When determining retention periods, we consider our relationship with users and their information, the nature and sensitivity of the information, and what is reasonably necessary and proportionate to provide and improve our services. We also adjust retention periods to comply with our legal, reporting, or accounting obligations, to resolve disputes, and to enforce our agreements. We regularly review our retention periods and assess our data minimization practices, retaining the least amount of information for the shortest retention period, while still upholding all our obligations.

10. Corporate reorganization

In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, we may share your personal information. We may also share your personal information if we undergo bankruptcy or liquidation, in the course of such proceedings.

11. Links to other sites or services

This Notice does not apply to other third-party sites or services. If you click on a link or browse to a third-party site from our site/service, your activity and interaction is subject to that third-party’s rules and policies. We recommend reviewing the privacy statements on those other sites to understand their privacy practices and make an informed decision regarding your use or interaction with their site/service.

12. Contact information

If you have questions or concerns regarding this Notice, our privacy practices and the protection of your personal information, or the privacy rights and choices available to you, you may contact us in the following ways:

Email	[email protected]
Phone	1-866-310-8783
Postal Mail	Commerce Signals Attn: Privacy Office 50 Main Street White Plains, NY 10606 USA

13. Notice changes and effective date

This Notice is subject to change at any time. If we make any changes to this Notice, we will post the revised Notice on this page with its effective date.