Data Privacy, Security and Oversight Is Important To Us
Complete Mailing Lists and its domains which include CompleteMailingLists.com and CML-LLC.com provide clients with a wide variety of data services. These services help them and the platforms and partners they work with to reach their target audiences, and provide more relevant marketing and communications. Communications channels for which we provide data include direct mail, email, display, mobile and multi-media. These services are described in greater detail throughout this website.
Complete Mailing Lists is in business as a processor of data. Data is acquired through relationships we have with other companies such as data suppliers, business partners (such as ad networks and other online partners), data services providers, agencies and our clients. We nonetheless provide this Privacy Policy as a service to those who want to learn more about the data we handle and how it is used.
Complete Mailing Lists is a member of the Direct Marketing Association (“DMA”), and we adhere to the principle that consumers should have choices regarding how marketers use their data and market to them. For information about how to opt out of our database, or out of certain services provided by our business partners, please go to our section titled “Your Data Choices and Opt Out Rights.”
The Types of Data That We Obtain and Use
Complete Mailing Lists receives data from, and handles data on behalf of, a variety of consumer-facing companies, applications and services, business-facing companies, and data compilers and suppliers. We also may obtain data through public sources, such as census data and other public records. Some of the data we receive, use and make available is Personal Information (“PI”) or is linked to PI. PI includes, for instance, name, postal address, telephone number or email address. In addition, some of our services involve using and making available “business to business” data, which is obtained from a number of sources, including public directories, filings and publications, surveys and subscriptions. We also collect certain information when you visit our website, www.completemailinglists.com, as described in the below section titled “Data Collected On Our Website”.
Our Services, and How We Use Personal Information
We use and make available Personal Information for various purposes. For instance,
We help marketers to deliver, target and optimize direct mail and email campaigns, display, mobile and social media marketing;
We help marketers to measure the effectiveness of ad campaigns (online and offline), such as 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;
We sometimes create sets of consumer attributes – categories of personal interests that are grouped together based on common interests or preferences (“Data Segments”). These Data Segments may be associated with a person, household, or when used online, a unique online identifier, such as enjoying sports, travel, living in a middle-class neighborhood, or being a member of a certain profession. Marketers may use these Data Segments to tailor more relevant ads and offers to groups of users, or to learn more about their own customers and improve their own databases.
We provide other data services, such as (but not limited to) verification, record look-ups, anti-fraud services, B2B records and services, and other analytics and database tools.
Sometimes, we may use Personal Information and Data Segments to help marketers and other data platforms perform “cross-channel” marketing – analyzing, locating and creating potential marketing “audiences” through multiple channels, e.g., web and mobile, or TV/radio. Sometimes, we may use Personal Information and Data Segments to help marketers and other data platforms perform “cross-channel” marketing – analyzing, locating and creating potential marketing “audiences” through multiple channels, e.g., web and mobile, or TV/radio.
In addition, when we work with online marketing applications such as through web-based, mobile, or cable TV technologies, these marketing applications may de-identify Personal Information (such as by creating a “hashed” version of an email address, or another associated identifier) in order to reach consumers through online display media. These marketing applications use cookies and similar technologies, often associated with unique online identifiers. Similarly, when we interact with consumers online, such as through a website or online ad or an email, we may employ cookies and similar technologies, which also may contain unique online identifiers. To learn more about these technologies, please go to the below section titled “About Cookies, Web Pixels, & Similar Technologies", and to opt out of the use of these technologies by many marketing applications that employ them for third party behavioral tracking and similar types of ad targeting, please go to the below section titled “Your Data Choices and Opt-Out Rights.”
The above is not necessarily an exclusive description of the ways we may employ Personal Information and other data. (You may learn more about our products and services by reviewing descriptions of our services on our website.) Generally, however, by permitting marketers to reference Personal Information and other data when they send offers to their customers and others, we do so to help increase the likelihood that marketers will send relevant and desired, rather than unwanted offers, content, coupons and ads.
Data Collected On Our Website
This website itself is primarily directed to businesses that may wish to use our services, but we welcome consumers who want to know more about our services. When you access this website or engage with us by email, we may collect the following information:
Personal Information – When you provide us with information through our website, such as to request or download information, sign up for a newsletter, event or service, or log in to a service or application we provide, we may request and you may provide certain PI to us. We may use your PI for any business purpose, including to administer your account and provide you services, to send communications and administrative emails, to respond to your inquiries, and to send marketing and product update messages. We may also use it to analyze how customers are using our website or services.
Non-Personal Information – Whether or not you sign up for an account or provide us with Personal Information, we may collect other information when you visit our website. This may include:
The type of browser and operating system you have used to access the website, a time-stamp, and other browser or device information;
Your IP address (which is a number automatically assigned to your computer when you access the Internet and can be used to derive your general geographic location);
Your clickstream data and any URL referral information (such as any website or social media platform that referred you to our website);
What part(s) of our website you visit, click and view, and how long you view it;
A unique identifier, which we may associate with a cookie, device identifier or similar technology.
We may collect or store the above information by using cookies, web beacons, and similar technologies, and may target or retarget ads to you using those cookies, device identifiers, or similar technologies, when you browse the Internet or use your mobile device. We may combine any information including Personal Information you provide to us.
While we would be sorry to see you go, you can unsubscribe from our corporate emails by accessing the “opt out” or “unsubscribe” (or similar) link we provide in the footer of each email that we send. Keep in mind, however, that even if you delete your account, we may retain your Personal Information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our agreements and policies, and take other actions permitted by law. Note that even if you unsubscribe or opt-out, we may still send you communications related to your use of and transactions with our services.
About Cookies, Web Pixels, & Similar Technologies
This section provides more information about cookies and similar technologies that we and our business partners may use, and how they work.
Cookies. Cookies are small text files that websites and other online services use to store information about users on users’ own computers. For instance, cookies can be used to store sign-in credentials so that you don’t have to enter them each time you return to a website, or to store other information to make web viewing more customized or efficient upon future visits. Cookies also may store a unique identifier tied to your computer so that web services and content and advertising networks can recognize you across visits to different websites. You can configure your internet browser to warn you each time a cookie is being sent or to refuse all or certain cookies completely. However, this may interfere with the functionality of your web browsing or your ability to fully use many websites.
Pixels or Web Beacons. Pixels or web beacons may also communicate information from your Internet browser to a web server. Pixels can be embedded in web pages, videos, or emails, and can allow a web server to read certain types of information from your browser, check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the Web beacon, the IP address of your computer, and the URL of the web page from which the Web beacon was viewed.
We sometimes work with third parties to 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.
We also may place cookies when you open an email that we send, in order to help understand how email recipients respond to email campaigns, or to learn more (or help our clients learn more) about those recipients.
When you visit our website, we (or a partner we work with) may place cookies to help us target or re-target marketing to you when you visit other websites or web or mobile applications – for instance, to tell you about our services, events and other information about our company.
Please note that our business partners may also use cookies and pixels, which we have no control over. For instance, we sometimes provide our or our clients’ proprietary data lists to companies that de-identify Personal Information and Data Segments and associate them with online cookies or similar technologies (such as mobile identifiers). Some of these partners may also associate online cookies with mobile identifiers (or other device identifiers) in order to associate use identities across browsers, devices, or technologies.
Third Parties: Data Sharing and Working Relationships
Complete Mailing Lists may share data, including Personal Information and Data Segments, as follows:
Agents and Service Providers: We may share data, including Personal Information and Data Segments, with agents, business partners and service providers who work on our behalf, or to help us provide services requested by our customers, including to perform any of the services described in this Privacy Policy. We may do so, for instance, to help send or target advertising on behalf of our clients (or ourselves), for analytical purposes, to measure campaigns, or inform future campaigns. We may do so to facilitate the sending of display media, email, or other requested services.
Partners: We may share data, including Personal Information and Data Segments, with business and data partners (such as business partners who provide to marketers their own applications or data services) or with clients, to help provide more tailored advertising and for analytical purposes.
Corporate transfers: If Complete Mailing Lists or its significant assets are purchased by another entity, our data will likely be transferred to that entity, including for due diligence prior to any such potential purchase.
Domains and Subsidiaries: We may share some or all of the data in our possession with affiliated or subsidiary companies. Our affiliates and subsidiaries include Political & Fundraising Lists, LLC, PFL-LLC.net and PoliticalFundraisingLists.net.
As Required by Law or to Protect Any Party: Complete Mailing Lists may disclose data if we believe in good faith 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 Complete Mailing Lists or any other party.
Data We Collect on Our Website: We use data that you provide to us on our website to market, and we may use this data for our business purposes. For instance, if you provide us with your name and email address, we may put your into our proprietary database and send you newsletters about our company, our services, and events. We will provide you a way to opt out of these emails, usually through a link in the email footer.
Data Transfers to Third Parties
We do transfer EU Personal Data to certain third-party agents or service providers with whom we have entered written agreements and which agreements addresses data privacy and security policies and procedures that requires all contractual parties to ensure that your EU Personal Data is protected with the same level of protection the Privacy Shield and the California Consumer Protection Act requires. We also may transfer your EU Personal Data to one of our affiliated entities, when we have taken steps to ensure that your EU Personal Data is protected with the same level of protection the Privacy Shield and the California Consumer Protection Act requires.
Right to Access Personal Data
You may have the right to access the EU Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield and the California Consumer Protection Act. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EU Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Your Data Choices and Opt-Out Rights
Opting Out of Complete Mailing Lists’ Database. Click the 'Do Not Sell My Personal Information' link at the bottom of any of our website pages and provide all of the requested information, to opt out of the Complete Mailing Lists database. If you are an organization requesting the opt-out on behalf of a consumer, you must first provide us with a certification of good standing from your US state of incorporation. Once verified, we will accept opt-out requests via the methods listed on the Do Not Sell My Personal Information page. We also recommend that you provide us with other addresses you have lived at in the past five years, which may help us to opt you out even if we have not yet acquired your current address information. If you decide to opt out in this way, we will stop using data in Complete Mailing Lists proprietary databases to help our customers send or tailor ads and content to you, including through email, direct mail or online display marketing. (It usually takes us between 30 to 60 days to process this opt out through all of our databases.) Doing so will not opt you out of our customers’ or our partners’ databases, only data in Complete Mailing Lists’ own database – so other companies that we work with may still send ads, offers and content to you.
Opting Out of Online Targeting. 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 recommend visiting the opt-out pages offered by the Network Advertising Initiative and the DAA’s AboutAds program. Opting out through the above methods will cause one or more opt-out cookies to be set on your browser or device, to indicate that you have opted out. Opting out in this way won’t prevent you from seeing ads: but it will in many cases lead the companies listed to stop customizing ads based on inferences they have made about you or your interests. Note that opt-outs are browser-specific, so opting out on one browser will not affect a second browser or device that you use. For the same reason, if you buy a new device, change browsers or clear all cookies, you’ll need to perform this opt-out task again.
Unsubscribing from Our Emails. In addition, when we send an email to you (whether on our behalf or on behalf of a client), we will provide a way for you to opt out of receiving emails from us in the future. Usually, this appears as an “unsubscribe” or “opt out” link in the footer of the email.
Right To Invoke Binding Arbitration
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with Complete Mailing Lists and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority (DPA) and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).
Disclosures for National Security or Law Enforcement
Under certain circumstances, we may be required to disclose your EU Personal Data or Swiss Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
Liability in Cases of Onward Transfer of Data
In cases of onward transfer to third parties of EU Personal Data that is received pursuant to the EU-US Privacy Shield and the California Consumer Protection Act, Complete Mailing Lists may be potentially liable in certain circumstances.
Data Security & Integrity
Complete Mailing Lists takes steps to ensure that the data we possess is housed and transmitted securely. These steps may include various methods of physical and electronic security, firewall protections, encryption and hashing of data, and access controls to PI. However, neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, so this Privacy Policy does not guarantee against that possibility.
California Residents - California Consumer Protection Act (CCPA) Compliance
The California Consumer Protection Act (CCPA) of 2018 focuses on four principle aspects of data privacy:
Disclosure
The Right To Be Forgotten
Non-discrimination
Access
Complete Mailing Lists adheres to the principles and requirements set forth in the CCPA regarding scope of data collection and use, responsiveness to requests for deletion of Personal Data, fairness with regard to non-discrimination based on opting out of data collection and use, and transparency with regard to accuracy of data held and informed consent pertaining to use.
California Privacy Rights
California Civil Code Section 1798.83 permits clients and customers of Complete Mailing Lists who are California residents to request certain information regarding and/or opt-out of our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write to us at the following address:
Privacy & Data Security Officer
Complete Mailing Lists
190 East Post Road
White Plains, NY 10601
(855) 913-0715
California Minor Content Removal
If you are a resident of California, under 18 and a registered user of our services, you may ask us to remove content or information that you have posted to these services by contacting us. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
California Do Not Track Disclosure
Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Do Not Track browser settings or signals. For information about Do Not Track, please visit: www.allaboutdnt.org.
For more information about the California Consumer Protection Act, visit https://oag.ca.gov/privacy/ccpa
Contact Us
If you have questions or concerns about Complete Mailing Lists’ privacy efforts or data products, please contact us:
Email: privacy-inquiries@completemailinglists.com
Postal Mail:
Privacy & Data Security Officer
Complete Mailing Lists
190 East Post Road
White Plains, NY 10601
Phone: (855) 913-0715