Privacy Policy

Last updated: September 2024

At Andrews Wharton Inc. (“we”, “our”, or “us”), your privacy is of the utmost importance. Thank you for taking the time to read our privacy policy (the “Privacy Policy”). This Privacy Policy sets out how we collect, use, process, store, and disclose your personal information on our website, https://www.andrewswharton.com/ (the “Website”), and in providing our marketing services to our corporate customers including direct marketing, enhancing data, data hygiene, analytics, and market research (collectively, the “Services”). By accessing and using our Website or Services you freely and expressly consent to the collection, use, processing, storage, and disclosure of your personal information as set out in this Privacy Policy.

When We Collect Information
Types of Personal Information We Collect
How We Use Your Information
How We Disclose Your Personal Information
Your Privacy Choices
Use of Cookies and Tracking Technologies
Security
Retention
U.S State-Specific Disclosure
California Consumer Disclosure
Children’s Privacy
Third-Party Links On Our Website
Changes To This Privacy Policy
Contact Us

WHEN WE COLLECT INFORMATION

We may collect personal information about you in the following ways:

● When you visit our Website.

● From public record and publicly available information.

● From website directories.

● From data resellers.

● When you fill out surveys.

● When you use our Services.

● When you sign up for our email newsletter or other communications.

● When you contact us.

TYPES OF PERSONAL INFORMATION WE COLLECT

Information you provide us directly:

● Contact details such as your name, email address, postal address, and phone number.

● Demographic information including gender, age, ethnicity, income.

● Employment Information.

● Education Information.

● Inferences related to preferences or potential interests.

● Information from your inquiries into our Services or the services of our partners.

● Information you provide when interacting with our Website such as signing up for email communications.

Please note, we do not directly collect personal information about you unless you voluntarily submit that information to us such as through our online forms, contact pages, by email, when you chat with us, by seeking employment with us, or through some other means.

Information we automatically collect:

● Metadata and analytics for your use of our Services, including IP address, device information, date/time of visits, new or returning visits, products viewed, page response times, URL clickstreams, how long you stay on our pages, what you do on those pages.

● We may use cookies, beacons, pixel tags, and other similar technologies to collect additional information automatically as you interact with the Services and to personalize your experience with our Services. Learn more about our cookie use below.

Information from third parties:

● We may also engage third parties to provide additional information about individuals, including contact information, demographic information, employment information, and education information. In addition, third parties may provide us with consumer mobile advertising IDs (“MAIDs”), or their proprietary identifiers such as connected TV identifiers.

We may also make inferences about you such as your interests that we believe are relevant to you and your household based on the information we have collected.

We may collect data that may constitute sensitive personal information. For example, we may collect information about a consumer’s mental and physical health - this information is self-reported by the consumer. In addition, we may collect precise geolocation, and infer a consumer’s ethnic origin and religious and political beliefs.

HOW WE USE YOUR INFORMATION

We use the personal information we collect for the following purposes:

● To operate and improve our Website.

● To provide our Services, for example, providing email hygiene and deployment services, licensing data for advertising purposes, providing advertising audience modeling and analytics, and generating marketing leads.

● For customer support.

● To communicate with you, including via our newsletter.

● For marketing and advertising.

● For other business and legal purposes, such as to detect and prevent fraud, to collect amounts owing to us, and to maintain business records.

● With your consent.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose your information with your consent. We may also share your information with our corporate affiliates, as well as vendors or service providers who:

● Help us communicate with you.

● Manage and optimize our Website and Services.

● Provide marketing and advertising services.

In addition, we may disclose your information where there is legal reason, for example:

● We may share your personal information in order to: (1) protect the legal rights of our company, our employees, our agents, and our affiliates; (2) protect the safety and security of our customers; (3) detect and protect against fraud; and (4) comply with law or legal process.

● We may share your personal information as part of a business transition. We may also share your personal information with prospective purchasers exclusively to evaluate the proposed transaction. We may also share your personal information with another company that buys the assets or stock in us. That company may use and disclose personal information for purposes similar to those described in this Privacy Policy.

Lastly, in order to provide our Services to our corporate customers, we may sell or share your personal information to the following categories of third parties:

● Advertising Networks

● Advertising/Marketing Companies

● Apparel & Accessory Companies

● Automotive Companies

● Business Service/Agencies

● Business to Business Companies

● Communication Services Companies

● Consumer Data Resellers

● Consumer Packaged Goods Companies

● Consumer Services Companies

● Data Analytics Providers

● Educational Institutions & Companies

● Electronics Companies

● Energy & Utility Companies

● Financial Services Companies

● Food & Beverage Companies

● Gift Product Companies

● Health & Wellness Product & Service Companies

● Lifestyle & Interest Product Companies

● Manufacturing Companies

● Marketing Data Companies

● Not for Profit Organizations

● Operating Systems & Platforms

● Parenting Product Companies

● Public or Government Entities

● Publishing Product Companies

● Social Networks

● Technology/Computer Software Companies

● Telecommunications Companies

● Travel, Leisure, & Entertainment Companies

Please note, we may disclose de-identified, aggregate, or anonymous information for any purpose. This means that the information we disclose does not identify specific individuals, or is combined with other data to protect your privacy.

YOUR PRIVACY CHOICES

You have the right to exercise the following choices with our use of your personal information:

● Access the personal information we maintain about you.

● Delete the personal information we maintain about you.

● Correct inaccurate personal information we maintain about you

● Opt out of certain uses of your personal information, notably:

○ Email marketing. You can unsubscribe to our email list by clicking the unsubscribe link at the bottom of marketing emails.

○ Tailored advertising using third party cookies. Please refer to the ‘Use of Cookies and Tracking Technologies’ section below to learn how to opt out of tailored ads.

○ Connected TV (CTV) advertising. CTV opt-out mechanisms are CTV provider specific. You can learn how to update your advertising preferences with your CTV provider by visiting: https://www.networkadvertising.org/internet-connected-tv-choices/.

○ Tailored advertising using MAIDs. MAIDs are operating system specific, you can update your preferences in your Android/iPhone settings. You can also exercise an industry-wide opt-out by visiting https://youradchoices.com/control.

You can exercise these rights by contacting us at privacy@andrewswharton.com.

USE OF COOKIES AND TRACKING TECHNOLOGIES

Like many companies, we use cookies and similar technologies (such as clear gifs, web beacons, tags, and similar technologies) to collect information about your browsing activities, your interactions with websites and our Services, and to serve tailored ads and for the purposes described in this Privacy Policy. There are a number of ways to opt out of having your online activity and device data collected through these services, which we summarize below:

● Opting out of cookie use in our Cookie Preferences. You can opt out of cookies via our cookie preference banner.

● Blocking Cookies In Your Browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

● Advertising Industry Opt-Out Tools. You can also use these opt-out options to limit use of your information for interest-based advertising online or in apps by visiting http://optout.aboutads.info.

Please note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

SECURITY

We protect information we collect about you by maintaining physical, electronic and procedural safeguards designed to prevent unauthorized access to user data retained in our servers, however, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. We take reasonable precautions to protect your information both online and offline. The servers on which we store data are kept in a secure environment.

RETENTION

We will retain your information for as long as your account or inquiry is active or as needed to provide you with the website or any requested services, and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your Personal Information, we may continue to retain and use aggregate or anonymous data previously collected and/or anonymize or aggregate your Personal Information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.

U.S STATE-SPECIFIC DISCLOSURE

Some U.S. states have enacted comprehensive privacy laws. The California Consumer Privacy Act, as amended by the California Privacy Rights Act or “CPRA” (collectively, the “CCPA”),the Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), Utah Consumer Privacy Act (“UCPA”), and Oregon Consumer Privacy Act (“OCPA”), Texas Data Privacy and Security Act (“TXDPSA”), and Montana Consumer Data Privacy Act (“MTCDPA”) create additional privacy obligations for businesses and provide their residents with additional privacy rights.

Additional Privacy Rights:

In addition to the rights granted above, if you are a resident of California, Virginia, Colorado, Connecticut, Utah, or Oregon, you have the right to:

● Opt out of the ‘sale’ or ‘share’ of your personal information for targeted advertising. We sell/share personal information to provide marketing services to our customers. In addition, some third party cookies placed on our website may be considered a ‘sale’ or ‘share’. You may opt out of such cookies as detailed in ‘Use Of Cookies And Tracking Technologies’ section (above).

● Sensitive personal information. Residents of California and Utah have the right to opt out of the collection and use of their sensitive personal information; Residents of Virginia, Connecticut, Colorado, and Oregon have the right to opt in to the use of their sensitive personal information. Some of the information we process (detailed above) may be considered sensitive personal information. Where required by law, we only process sensitive personal information where we have your consent.

You can exercise these rights by contacting us at privacy@andrewswharton.com or via the ‘Your Privacy Choices’ webpage.

Controller/Business Designation:

Under U.S. state privacy law, we operate as a ‘Controller’ and a ‘Business’ under CCPA.

Appeal:

If we deny your privacy request, you may appeal that decision by emailing us at privacy@andrewswharton.com. If you are still unsatisfied with our response, you have the right to file a complaint with your state attorney general.

Texas Required Data Broker Disclosure:

The entity maintaining this website is a data broker under Texas law. To conduct business in Texas, a data broker must register with the Texas Secretary of State (Texas SOS). Information about data broker registrants is available on the Texas SOS website.

CALIFORNIA CONSUMER DISCLOSURE

Definitions:

The terms “Business Purpose(s)”, “Personal Information”, “Sell” (or “Sale”), “Service Provider(s)” and “Third Parties” have the meanings given in the California Consumer Privacy Act of 2018 (CCPA). These term references and disclosures are limited to this section of the Privacy Policy and designated exclusively for California Consumers.

Third Party/Business Designation:

Andrews Wharton Inc. is considered to be a ‘third party’ Business, but may contract as a ‘service provider’ with select customers.

Categories of Personal Information Collected:

● Identifiers. We may collect name, postal address, email address, phone number, unique personal identifiers, and online identifiers like cookie IDs, MAIDs, CTV IDs, and IP address.

● Demographic information. We may collect or infer your age, gender, income, and level/type of education.

● Personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Our business customer’s employee names, job title, the business name, business address, telephone number, and email address.

● Protected classification characteristics under California or federal law. We may collect or infer information about a consumer’s age, gender, ethnicity, national origin, race, pregnancy, and religion. This information is often self-reported by the consumer.

● Commercial information. We may collect records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.

● Internet or other similar network activity. We may collect browsing history, search history, information on a consumer's interaction with a website, application, or advertisement for example, which pages you visited and when, what items were clicked on a page, and how much time was spent on a page.

● Geolocation data. We may collect imprecise geolocation derived from your IP address. We may also collect precise geolocation.

● Inferences. We may also make inferences about you such as your interests that we believe are relevant to you and your household based on the information we have collected.

● Sensitive personal information. We may collect information about a consumer’s mental and physical health - this information is self-reported by the consumer. In addition, we may collect precise geolocation, and infer a consumer’s ethnic origin and religious and political beliefs.

Purposes for Collection and Use of Personal Information:

We collect personal information to provide marketing services to corporate customers, including direct marketing, data hygiene, modeling and analytics, data licensing, lead generation, and market research.

Categories of Sources from which Personal Information is Collected:

● Directly from consumers namely, self-reported information.

● Public record and publicly available information.

● Website directories.

● Data resellers.

● Surveys.

● Inferences.

Categories of Personal Information We Sell or Share:

● Identifiers. We may collect name, postal address, email address, phone number, unique personal identifiers, and online identifiers like cookie IDs, CTV IDs, and IP address.

● Demographic information. We may collect or infer your age, gender, income, and level/type of education.

● Commercial information. We may collect records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.

● Geolocation data. We may collect imprecise geolocation derived from your IP address. We may also collect precise geolocation.

● Inferences. We may also make inferences about you such as your interests that we believe are relevant to you and your household based on the information we have collected.

Purposes for Selling and Sharing Personal Information:

We sell personal information to provide our marketing services to corporate customers, including for the purposes of direct marketing, data hygiene, modeling and analytics, data licensing, lead generation, and market research. Generally, our corporate customers use our Services for marketing and advertising.

Categories of Third Parties to whom Personal Information is Sold and/or Shared:

● Advertising Networks

● Advertising/Marketing Companies

● Apparel & Accessory Companies

● Automotive Companies

● Business Service/Agencies

● Business to Business Companies

● Communication Services Companies

● Consumer Data Resellers

● Consumer Packaged Goods Companies

● Consumer Services Companies

● Data Analytics Providers

● Educational Institutions & Companies

● Electronics Companies

● Energy & Utility Companies

● Financial Services Companies

● Food & Beverage Companies

● Gift Product Companies

● Health & Wellness Product & Service Companies

● Lifestyle & Interest Product Companies

● Manufacturing Companies

● Marketing Data Companies

● Not for Profit Organizations

● Operating Systems & Platforms

● Parenting Product Companies

● Public or Government Entities

● Publishing Product Companies

● Social Networks

● Technology/Computer Software Companies

● Telecommunications Companies

● Travel, Leisure, & Entertainment Companies

California Consumer Rights & Options:

You can exercise your privacy rights as detailed in the U.S. State-Specific Disclosure (above).

2023 CCPA Request Metrics:

● Number of CCPA requests received: 1733

● Median number of days to respond to CCPA requests: 4

● Mean number of days to respond to CCPA requests: 3.9

● Number of denied CCPA requests: 0

● Number of unfulfilled requests because AWI does not maintain the individual’s data: 1733

CHILDREN’S PRIVACY

We do not intentionally collect any personal information from children under the age of 13 (or 16 in California). If you are under the age of 13 (or 16 in California), please ask a parent or guardian for help in using our website or purchasing any products. If you believe we have obtained personal information associated with children under the age of 13 (or 16 in California), please contact us at privacy@andrewswharton.com and we will delete it.

THIRD-PARTY LINKS ON OUR WEBSITE

Our Website and Services may contain links to other websites or services. We do not exercise control over the information you provide, or is collected by these third party websites. We encourage you to read the privacy policies or statements of the other websites you visit.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. If we make material changes, we will post the updated Privacy Policy on this page with a “Last Updated” effective date of the revisions. We encourage you to look for updates and changes to this Privacy Policy by checking this page when you access our Services.

If you have any questions about our privacy or security practices, or if you would like to request access to or correction of your personal information, you can contact us by email at privacy@andrewswharton.com or at:

Andrews Wharton Inc.
700 Veterans Highway, #115
Hauppauge, NY
11788