Commerce Signals Online Privacy Notice
Last Updated: July 5, 2022
Commerce Signals Inc. (“Commerce Signals” or “we”), a subsidiary of TransUnion LLC (“TransUnion”), respect your concerns about privacy. This Online Privacy Notice (the “Notice”) applies to personal data we collect on https://www.commercesignals.com/ or any Commerce Signals-branded website that links to this Notice (the “Sites”). The Notice describes the types of personal data we obtain, how we use the personal data, and with whom we share it. We also describe the rights you may have and how you can contact us about our privacy practices.
- How We Obtain Information About You
We may collect personal data that you choose to provide to us through the Sites, including, but not limited to, your first and last name, physical address, e-mail address, or telephone number, 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 data in connection with that feature;
- Attend an event that we or a TransUnion affiliate has organized; or
- Communicate with us (for example, on a social media platform or by sending us an email).
When you visit our Sites, we also may collect certain information by automated means 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. Your browser may tell you when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies, you may not be able to use all of the features of our Sites. Non-cookie-based tokens are encoded URL-based identifiers that track e-mail 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.
We may also collect personal data in other contexts that we will notify you of at the time.
- Information We Obtain
Information That You Provide to Us
Personal data that you provide directly to us will be apparent from the context in which you provide it, for example:
- If you fill out a form on our Sites, you will generally provide your name, contact details and any other information requested by the form, such as the reason for your enquiry or your product preferences;
- If you sign up to receive electronic marketing communications from us, you will generally provide your name, email address and other contact information, and your product preferences;
- If you sign up to a feature on our Sites, you will generally provide your name and contact information and any other information necessary to access the feature.
Each form on our Sites varies in the information required and collected. You may choose to provide additional information within fields that are not required.
Information That We Collect Automatically
Our web servers may log information such as your 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 (such as the application) you are using. The web server logs may also record information such as the address of the web page that referred you to our Sites and the IP address of the device you use to connect to the Internet. They may also log information about your interaction with the Sites, such as which pages you visit. To control which web servers collect information by automated means, we may place tags called “web beacons” — small files that link web pages to particular web servers and their cookies. We may also collect information from your browser and use it in conjunction with data gathered from forms and e-mails to help us understand and respond to your needs.
“Do Not Track” Signals
Your browser settings may allow you to transmit a “Do Not Track” signal to websites and online services you visit. Like many other websites and online services, we do not currently process or respond to “Do Not Track” signals from your browser or to other mechanisms that enable choice. Both we and others (such as our service providers) may collect personal data about our visitors’ online activities over time and across third-party websites.
Social Media Widgets
The Sites may include social media functions, such as the Blog, Twitter, 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.
If you are a LinkedIn member and you visit our Sites from LinkedIn, our Sites may use tracking pixels — transparent graphic images placed on web pages — which, in combination with cookies, collect information contained within your LinkedIn profile as well as your access of and interaction with the web pages that contain the pixels. Commerce Signals works with LinkedIn to provide Sponsored Updates and advertisements to your LinkedIn news feed. If you complete a form on our Sites you may receive Sponsored InMails in your LinkedIn email account based on your visits to the Sites and your perceived interests. To learn how to opt out of Sponsored InMail, navigate to Privacy & Settings in your LinkedIn account, choose the “Communications” tab, and then click “Turn on/off Partner InMail” to disable Sponsored InMails.
Information That We Obtain From Third Parties
Information that we collect from third parties will generally consist of publicly-available profile information (such as your preferences and interests), for example from public social media posts.
- How We Use Information That We Obtain
Information That You Provide to Us
We may use personal data that you provide to us to respond to your inquiry, for example, to contact you about your request, ask a question, provide announcements about products and future events, conduct surveys, consider your application for employment, and contact you for other reasons related to offering and improving our services. We use the personal data for these purposes because we have a legitimate business interest in providing services to our customers and other interested individuals that is not overridden by your interests, rights and freedoms to protect personal data about you.
In addition to the uses discussed above, we may also use the personal data you provide on our Sites to:
- evaluate how you interact with the Sites;
- identify visitor preferences on the Sites;
- operate, evaluate, and improve our business;
- develop new products and services;
- perform market research;
- advertise and market our products and services;
- determine the effectiveness of our advertising and marketing;
- analyze our products, services, and websites;
- administer the Sites.
We use the personal data for the purposes described above because we have a legitimate interest in operating and improving our business that is not overridden by your interests, rights and freedoms to protect personal data about you.
We may also use the information 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 use personal data for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by law that applies to us.
Information That We Collect Automatically
To learn how to opt out of Google Analytics, visit: https://tools.google.com/dlpage/gaoptout.
Other Uses of Information
In addition to the uses described above, we may use personal data that you provide to us or that we collect for other purposes.
- Information We Share
We do not sell or otherwise disclose personal data that you provide to us or that we collect on our Sites, except as described here. We may share personal data you provide to us or that we collect on the Sites:
- Service providers that perform services on our behalf.
- With a purchaser of Commerce Signals (or the majority of its assets), a merger or internal acquisition; and
- Other companies in the TransUnion group.
We may share personal data with other members of the TransUnion of companies for a number of reasons, including because you have requested information about our affiliates’ products and services.
We may share personal data with service providers that perform services on our behalf such as payment service providers, analytics providers, hosting providers and advisers. All service providers have entered into legally binding agreements requiring them to use or disclose personal data only as necessary to perform services on our behalf or comply with applicable legal requirements. In addition, we may disclose personal data 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, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (d) 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).
- How Long We Keep Information
The time period for which we keep personal data depends on the purpose for which we collected it. In all cases we keep it for as long as necessary to fulfill the purposes for which we collected it. We will then delete the personal data, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).
- Your Rights and Choices
We offer you certain choices about how we communicate with you and what information we obtain from you. As allowed by applicable law, you may withdraw consent you previously provided to us. We will apply your preferences going forward. You may exercise these choices by contacting us as specified in the “How to Contact Us” section below.
- Updates to Our Online Privacy Notice
We may update this Notice periodically and without prior notice to you to reflect changes in our personal data practices or relevant laws. We will post the updated version and indicate at the top of the notice when it was most recently updated.
- How to Contact Us
If you have any questions or comments about this Notice or any issue relating to how we collect, use, or disclose personal data, or if you would like us to update information we have about you or your preferences, you may contact us:
By e-mail at: firstname.lastname@example.org
In writing at:
Commerce Signals, Inc
Attention: Chief Privacy Officer
50 Main St.
White Plains, NY 10606