Privacy Policy

Last updated: January 1, 2020

This Privacy Policy describes how we collect, use, share, sell, or otherwise disclose information we collect about you, and applies to our collection via this website or mobile application and to related websites, applications, services and mobile applications on or in which this Privacy Policy appears or is linked or referenced (our “Sites”). It also applies when you use or otherwise engage our Services.

As for who we are, we are Valassis Communications, Inc., and Valassis Digital Corp., (“Valassis,” “we,” “us,” or “our”). Valassis provides marketing technology and consumer engagement products and services (our “Services”), including Services that allow advertisers to more effectively target ads to end users on websites they visit and the applications they use. Valassis also maintains websites that provide information about us and our Services.

This Privacy Policy explains:

  • The information we collect on or through our Sites, in providing our Services, when you access or use our Sites, or otherwise interact with us and how that information is used, disclosed, shared, and processed;
  • How information about you is collected, used, and disclosed by Valassis when you access our Sites, mobile applications that use our Services, interact with other websites that interact with us or otherwise interact with us.
  • Your choices regarding the collection and processing of your Personal Information.

It does not cover the privacy practices of third parties that we do not own or control.

Your Personal Information (defined below) may be processed and stored in other countries (including the United States) where laws regarding processing of Personal Information may be less stringent than the laws in your country. Your Personal Information will not, however, be used or disclosed for purposes for which you have not given consent or that are not permitted under applicable law. In jurisdictions where implied consent is allowed, you consent to the terms of this Privacy Policy by using our Services and/or Sites.

It is important to note that we may provide third party content or links to third-party websites or applications, or include features that allow you to connect your account with third parties, such as financial institutions or social media platforms like Facebook.

Anytime you leave our Sites or Services or interact with third-party features or websites, you should also read the applicable third party’s privacy policies and terms of service to make sure you understand how they might collect and share information about you (approaches and philosophies can be different).

Before submitting information to or through our Sites or Services, please review this Privacy Policy carefully. (If you have not done so already, please also review our Terms of Use.)


When you use, access, or interact with us, our Sites, or our Services, you are agreeing to our Terms of Use and consent to how we collect, share, process, and otherwise use information about you as described in this Privacy Policy.

How We Collect Information About You

Information We Collect Automatically Through Our Sites and Services

As you use the Sites and/or as we employ our Services, certain information may be passively collected and stored on our or our service providers’ server logs about how you interact with the Sites and/or our Services, including your Internet protocol address, unique personal identifier (advertising or device ID), online identifier/browser fingerprint, domain name, browser type, mobile services provider, MAC address, type of device, operating system, applications installed on the device, web pages viewed, access date and time, and referring website address and website address of the web page you visit after you leave the Website and/or Services (“Usage Information”). We may also place small data files on your computer or other device. These data files may be cookies, pixel tags, Flash Cookies, Silverlight Cookies, or other local storage provided by your browser or associated applications (“Cookies”). Some information collected may be Personal Information. We use Cookies and navigational data like Uniform Resource Locators (“URL”) to gather information regarding the date and time of your visit and the information for which you searched and viewed. In order to use the Sites and/or our Services, your web browser must accept Cookies. Cookies may be used by partners, advertisers, and ad servers to promote third-party products and/or services.

We use these technologies to:

  • Recognize you as a customer;
  • Customize our content and advertising;
  • Measure promotional effectiveness;
  • Help ensure that your account security is not compromised;
  • Mitigate risk and prevent fraud;
  • To promote trust and safety across our Services;
  • To make our Services and solutions more useful to you;
  • To tailor the experience with us, and
  • To ensure our Services meet your special interests and needs.

An “Internet protocol address” or “IP Address” is a number that is automatically assigned to your computer when you use the Internet. In some cases your IP Address stays the same from browser session to browser session; but if you use a consumer internet access provider, your IP Address probably varies from session to session. We, or our service providers, may track your IP Address when you access the Sites or our Services to assist with ad targeting.

To help advertisers provide ads that are relevant to your interests, we automatically collect information about your browsers and devices when you (or others using your browsers or devices) access or use websites or mobile applications that incorporate our Services. We use various technologies to collect this information, including cookies, pixel tags, web beacons, server logs, browser fingerprinting, HTML5 local storage, Flash local shared objects (LSOs), statistical identifiers, mobile advertising identifiers (such as IDFA and Android Advertising ID), software development kits (SDKs), server-to-server transfers, and non-cookie technologies. The information we collect via these technologies include the following:

  • Non-Personal Information: This is information that, when used in isolation, is not able to identify a natural person.
  • Browser and Device Information: We collect information about your browsers and devices, including your browser type, device type, IP address, user agent string, operating system, mobile carrier, and identifiers assigned to your browser or device, such as the advertising identifiers assigned by platform providers or statistical identifiers that allow us to recognize your device, which we infer from the other information that we collect about your device.
  • Usage Data: We collect information about your web browsing and application usage, including the date and time your browser or device accesses websites and applications that incorporate our Services, the specific pages accessed, the names or types of mobile applications accessed, actions taken on the page, conversions or transactions, advertisements viewed, and advertisements clicked.
  • Device Location Information: If permitted by your browser or device, and with your consent, we may collect your location information for the purposes of serving ads that may be more relevant to you or helping to understand how you responded to ads served to you. For more details, please see “Your Choices” below.
Information You Provide to Us Directly or Indirectly

Because we also have a conversational ad feature on our Sites, you may provide, and we may collect chat and messaging transcripts, surveys, transcripts, and records of your communication to us, via your participation in one of our promotions, when you submit a technical support request, when you apply for employment, or when you request information, news or other content.

If you send an email to us, we will collect your email address and the full content of your email, including attached files, and other information you provide. We may use and display your full name and email address when you send an email notification to a friend through our Services, Website or the social network from which you have connected to our Services or Website (such as in an invitation, or when sharing your content). Additionally, we use your email address to contact you on behalf of your friends (such as when someone sends you a personal message). We may use this email address to contact you, for things such as notifications of limited edition shop sales and other related information. You may indicate your preference to stop receiving further promotional communications as further detailed below. Some of the emails we send to you may include a click-through link. Before you arrive at the linked website, you pass through our servers. We track these ‘click-throughs’ to help us determine your interest in particular topics and measure the effectiveness of our customer communications. In addition to ‘click through’ data, we may also collect, store and analyze other Usage Information about the products and services we offer our customers.

Prospective customers may provide contact information through our Sites to find out more about Valassis and to be contacted by a Valassis representative. Valassis (and its agents and service providers) may use this information to respond to your request, to send you marketing communications, and for business purposes such as marketing and research. We will not rent or sell this information to other companies. You may opt out of receiving promotional emails from Valassis by following the instructions in those emails. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations. Valassis will use any other information submitted on our Sites for the purpose for which it was collected, including to respond to your inquiry.

Information We Collect from Other Sources

We may also obtain information from other sources and combine that with information we collect through our Services. For example, we may collect information about you from third parties, including our business partners, data providers, other advertising companies, and publicly available sources. For example, this information may include:

  • Personal Information: This is information that can be used to identify you personally, such as your name, address, email address, and phone number. When we combine information that is not Personal Information (like Non-Personal Information or Usage Data, which we explain above) with Personal Information, we treat it like Personal Information for as long as it is combined. Personal Information does not include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person or that does not otherwise identify you as a natural person.
  • Past Purchase Information: We may collect information on past purchases from third parties.
  • Postal or Email Addresses and Related Information Provided by our Business Partners: Our business partners may provide us with their customer data (which could consist of postal or email addresses or purchasing data).
  • Publicly Available Information: We may collect publicly available information from data providers, such as census data related to cities, regions, or other geographic areas as well as related demographic, income, and education information of those areas.

You can opt out of interest-based ads by companies that participate in the Digital Advertising Alliance opt out program by clicking here . We also use Google Analytics and other similar tools, such as Pendo, to help collect and analyze certain information on the Sites. You may opt out of the use of cookies by Google Analytics here and learn more about Pendo by reviewing Pendo’s current Privacy Policy here.

How We Use Your Information

We use the information we collect through our Services to provide, maintain, and improve our Services, including:

  • Serving targeted advertisements: We use the information we collect to select and serve advertisements that we or our business partners think may be of interest to you. These advertisements may be served on the browser or device from which the information was collected, or on a different browser or device that we have linked to the browser or device from which the information was collected. We also use this information to manage the frequency and type of advertisements you see across your devices.
  • Measuring the effectiveness of advertisements: We use the information we collect to measure and analyze trends, usage, and the effectiveness of our Services and the advertisements we and our business partners serve, including clicks and views of advertisements and any resulting purchases, as well as physical visits to retailers or other businesses.
  • Creation of audience segments: We develop audience segments which consist of combinations of various data, including consumer location activity, purchase intent, and online and offline interests based in part on your online activity. We may offer these audience segments for licensing by third party data providers and cloud marketing providers.
  • Cross-device linking: We use the information we collect to establish connections among related web browsers and devices (such as smartphones, tablets, and computers) for targeted advertising, analytics, and reporting purposes. For example, we may match a user’s browsers or devices if they share similar attributes that support an inference that they are used by the same person or household. This means that information about website activities or application usage history on your current browser or device may be combined and used with information collected from your other browsers or devices. So, for example, if you browse for new cars on your tablet, you may see an advertisement for new cars on your smartphone.
  • Building Customer Profiles: Our business partners may provide us with their customer data (which could consist of postal or email addresses or purchasing data), and we may match that customer data with the applicable digital households and then enrich each digital household profile with real-time interest and location activity.
  • Other Uses: We also use the information you provide to use to operate the Services, including:
    • personalizing the types of information that you receive from us;
    • assessing trends in your use of the Services or purchases of products or services;
    • customizing, improving and developing content and functionality that helps us better serve your needs;
    • facilitating communication between us and you;
    • effectuating your opt-out of our direct mail campaigns and/or our other Services;
    • providing you with information that we think may interest you, such as company news and certain products, services, special deals and promotions;
    • displaying third-party advertisements that may interest you based on your activity on the Website and/or Services;
    • developing aggregate, non-identifiable data that may be used for our business purposes;
    • for promotions you may enter into;
    • when you submit a resume, CV, or other information for consideration for employment;
    • engage in conversational advertising with you via Google AdLingo; and
    • preventing fraud and other prohibited or illegal activities.

We and our business partners also may combine different types of information collected from or about you through various sources, including Personal Information, and use the combined information for the purposes described in this Privacy Policy.

We may collect and use certain non-sensitive health-related information in delivering advertisements. This includes utilization of similar to and including the following non-sensitive health-related data segments: Men’s Health and Wellness, Women’s Health and Wellness, General Health, Seniors’ Health and Wellness, and Common Ailments and Illnesses such as flu, allergies, and seasonal ailments.

Advertising Data Retention
Information collected through our Services that is linked to a browser or device is kept for a period of one year after it is collected. After that period has expired, this information is de-linked from any browser or device identifier but may be kept for research and used as set forth in this Privacy Policy.

Sharing of Information
We may share the information we collect as follows or as otherwise described in this Privacy Policy:

  • With vendors, consultants and other service providers who need access to such information to carry out work or perform services on our behalf;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, rule, regulation, or legal process;
  • If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, or safety of Valassis or others;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
  • Between and among Valassis and any current or future parent, subsidiary, and/or affiliated company;
  • With our business partners for the purposes described in this Privacy Policy;
  • With your consent or at your direction;
  • As required to do so by law or in the good-faith belief that such action is necessary to investigate, protect or defend the rights, safety or property of us, our customers, or the public; to investigate or enforce perceived violations of our Terms of Use or this Privacy Policy; as evidence in litigation in which we are involved; and for fraud protection and credit risk reduction purposes.

For more information about Google’s use of data via our partnership with Google, please review How Google Uses Data when you use our partners’ sites or apps.

For more information about our Terms and Conditions for partnership with Google for use of its AdLingo functionality, please see Google’s Platforms Policies Help.

We may also share aggregated information, which cannot reasonably be used to identify you, with third parties. For example, we may share aggregated information with our business partners to help them optimize their services.

Additional Mobile Considerations
In addition to the other terms in this Privacy Policy, if you use our mobile applications, access our mobile-optimized websites or have a conversation with a customer that uses our Services in its mobile application, we may receive information about your mobile device, including a unique identifier for your device.

If you receive SMS messages from us, you may opt out by following the opt-out instructions that we provide.

If you receive SMS messages from one of our customers, you may opt out by following the opt-out instructions provided by the brand you are communicating with or by contacting the brand. You may also contact us at privacyrequests@valassis.com, and we can help put you in touch with the brand regarding your request.

Social Media Plug-Ins
On certain pages of the Website we may implement so-called “social media” plug-ins, in particular Facebook’s “like” button, LinkedIn “comment” / “thumbs up”, and Twitter’s “comment” / “retweet” / “♡” buttons. When you visit a page that displays one or more of such buttons, your browser will establish a direct connection to the relevant social media server and load the button from there. At the same time the provider of the social media service will know that the relevant page on the Website has been visited.

We have no influence on the data that any such social media provider collects on the basis of the buttons. According to the available information, however, if you do not click on the respective buttons, none of your personal data will be collected and stored unless you have logged onto to your social media account. In that case, certain user data (including your IP address at the time) may be collected and linked to the account information already present at the social media service. If you wish to prevent this, please log out of your social media accounts before visiting our Website.

In addition, clicking a button may also lead to a collection of certain data, such as your IP address. Social media providers such as Facebook, Instagram, YouTube, or Twitter may set cookies as well, unless you have disabled the acceptance and storage of cookies in your browser settings (see above).

We receive no information from social media providers about which social media buttons you may personally have clicked or seen on our Website. If at all, we may receive a summarized, non-personalized statistical report on the use of the buttons.

Your Choices

You may opt out of our use of information about your web browsing or mobile application usage for interest-based advertising purposes (including through the use of non-cookie technologies such as statistical IDs). Because we use different technologies to collect information across web browsers and mobile applications, we provide different choices for each environment. You can follow the instructions below to opt out in web browsers or in mobile applications, or to change your location settings. Please note that the opt-out will apply to the specific browser or device from which you opt out, and therefore you will need to opt out separately for each device and each web browser that you use and wish to be opted out on.

When you opt out of interest-based advertising in web browsers and mobile applications, as described below, we will no longer serve ads that are targeted based on your web browsing activity or application usage history to the browser or mobile device from which you have opted out (including through the use of non-cookie technologies such as statistical IDs). In addition, we will not use information collected from the browser or device from which you have opted out to serve you targeted ads on other browsers or devices that we have linked to that browser or device. Similarly, we will not use information collected from other, linked browsers or devices to serve you ads on the browser or device from which you have opted out. Please note, however, that we may continue to serve you ads that are not based on your web browsing or mobile application usage.

Opting Out in Web Browsers
Valassis adheres to the Digital Advertising Alliance’s (DAA) Self-Regulatory Principles. You can visit the DAA’s website to learn more about online advertising, and to opt out of having certain information used for interest-based advertising purposes on web browsers. To opt out solely from Valassis’s use of information about your web browsing activity for interest-based advertising purposes (including through the use of non-cookie technologies such as statistical IDs), please click here: Ad Cookie Opt Out.

When you opt out using any of these methods, we will place an opt-out cookie on your browser. This cookie is only effective as to the device and browser where the opt out is made. If you want to opt out for multiple browsers or devices, you must opt out on each browser and device individually. You may need to enable cookies in order to opt out using any of these methods, and if you delete your cookies, you may need to renew your opt-out choice. You can download the DAA’s Protect My Choices browser extension to help preserve your opt-out preferences.

Please note that when you delete or clear cookies from your browser, you will not necessarily delete the Flash Local Shared Objects stored on your computer. You can review Adobe’s Website Storage Settings panel to view, delete, and control Flash Local Shared Objects.

Opting Out in Mobile Applications

Your mobile device may provide you with a setting that allows you to opt out of having your data used for certain advertising activities (Limit Ad Tracking on iOS, and Opt out of Interest-Based Ads on Android). Valassis treats these signals as an opt-out for that particular device and will not use information collected in mobile applications on that device for interest-based advertising purposes (including through the use of non-cookie technologies such as statistical IDs). To adjust settings on your mobile device, please visit:

  • iOS: Settings > Privacy > Advertising > Limit Ad Tracking
  • Android: Settings > Google > Ads > Opt out of interest-based ads

We also participate in the DAA’s Appchoices opt-out program, which you can learn more about at http://youradchoices.com/appchoices.

Effect of Opting Out
When you opt out using any of these methods, we will no longer serve ads that are targeted based on your web browsing activity or application usage to the browser or mobile device that has opted out, regardless of where such information was initially collected, and we will not use information collected from the device that has opted out to serve you targeted ads on other browsers or mobile devices. We may continue to serve you non-targeted ads.

Opting Out for Device Location Data
When you first download or open any applications that incorporate our Services, you may be asked to consent to the collection of location information from your device. If you consent to the collection of this information but later wish to withdraw your consent, you may do so at any time by either changing the settings on your mobile device or deleting the mobile application.

Mobile Location Analytics Opt Out
Valassis complies with the Mobile Location Analytics Code of Conduct. As provided for in the code, you may elect to opt out of associating information about your presence at a location with a device’s MAC Address at: https://smart-places.org/. If you opt out, we will use your device’s MAC Address only to maintain the device’s opt-out status.

Do Not Track Requests
Valassis does not honor Do Not Track (DNT) requests at this time.

Opting Out of Valassis Mailings
Consumers have the option to unsubscribe and stop receiving Valassis mailings by simply providing their address on our Unsubscribe page or calling the Valassis consumer line at (800) 437-0479.

Minors
The Sites are not intended for use by children under the age of 18. Valassis does not knowingly collect or use any personally identifiable information from children under the age of 18 and does not use any information collected from websites or mobile applications directed to children for interest-based advertising purposes. If we learn that we have collected the personally identifiable information from any such children, we will take steps to delete the information as soon as possible.

Links
The Sites may contain links to third-party websites. We are not responsible for the privacy practices or the contents of such other websites. Please read the privacy statements of each website you visit. This Privacy Policy applies solely to information collected by us through the Sites. Any links to other websites are for your convenience and do not signify our endorsement of such websites or their contents.

Notice to Residents of Countries Outside the United States
Valassis is headquartered in the United States. Personal information may be accessed by us or transferred to us in the United States or to our business partners, service providers, vendors or consultants elsewhere in the world. If you are located outside of the United States, be advised that any information you provide to us will be transferred to and stored in the United States and that, by submitting information to us, you explicitly authorize its transfer and storage within the United States. We will treat personal information according to this Privacy Policy regardless of where it is processed or stored.

California Privacy Rights Notice (the “Notice”)

This portion of the Privacy Policy applies solely to California Consumers (“consumers” or “you”). We have adopted this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. The purpose of this Notice is to provide you with a description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights you have regarding your personal information. As used in this Notice, any terms defined in the CCPA have the same meaning when used in this Notice.

Shine the Light
Pursuant to Section 1798.83-.84 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, what types of personal information, if any, the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information in the immediately preceding calendar year. To access this information, please contact us by emailing privacyrequests@valassis.com with “CA Shine the Light Request” in the subject line. Please note that, under the law, we are not required to respond to your request more than once in a calendar year, nor are we required to respond to any requests that are not sent to the above-designated email.

California Consumer Privacy Act (“CCPA”)

Your Right to Know About the Personal Information We Collect About You

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

In particular, we may have collected the following categories of personal information from consumers within the last twelve (12) months as follows:

Category

Specific Pieces of Information

Identifiers

A name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.

We collect this information from you directly and indirectly, automatically through our Services, and from other sources.

We collect this information to serve and deliver relevant advertisements to you; to enhance our Valassis National Enhanced File; internally to support direct mail; to supplement, enhance, target, and/or suppress existing customers from client campaigns; to provide specialty lists to our clients; to respond to your requests; to match a device exposed to an advertisement; to better understand and study purchase behavior or advertisement targeting; for targeting based on geolocation; to learn about a client’s campaign; and to understand purchase behavior.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, address, and telephone number.

We collect this information from you directly and indirectly, automatically through our Services, and from other sources.

We collect this information to provide the Services to our customers; to allow consumers to enter promotions; to enhance our Valassis National Enhanced File; to supplement, enhance, target, and/or suppress existing customers from client campaigns; to provide specialty lists to our clients; to respond to your requests; and to improve our products and Services.

Protected classification characteristics under California or federal law.

Age (40 years or older), marital status, sex (including gender, gender identity)

We collect this information automatically through Services, and from other sources.

We collect this information to enhance our Valassis National Enhanced File; to append to our household data; and to understand and study purchase behavior.

Commercial information.

Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, and property records.

We collect this information automatically through our Services, and from other sources.

We collect this information to enhance our Valassis National Enhanced File; to match an exposed device to an advertisement; internally to support advertising campaigns; to supplement, target, and/or suppress existing customers from client campaigns; to provide specialty list to clients; and to understand purchase behavior.

Internet or other similar network activity.

Browsing history; search history; information on a consumer’s interaction with a website, application, or advertisement.

We collect this information automatically through our Services, and from other sources.

We collect this information to support advertising campaigns; to learn about a client’s campaign; and to provide our products and Services.

Geolocation data.

Physical location.

We collect this information through our Services and from other sources.

We collect this information to target advertisements to individuals based on geolocation; to support advertising campaigns; to learn about a client’s campaign; and to provide our products and Services.

Inferences drawn from other personal information.

Profile reflecting a person’s interest and purchase preferences, characteristics, consumer predispositions and behavior.

We collect this information automatically through our Services, and from other sources.

We collect this information to target advertisements to individuals based on interests and in-market data; to support advertising campaigns; and to provide our products and Services.

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
  • Auditing related to a current interaction with you and concurrent transactions, including, counting ad impression to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with the CCPA;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for the activity; debugging to identify and repair errors that impair existing intended functionality;
  • Short-term, transient use (of which the personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction, including the contextual customization of ads shown as part of the same interaction);
  • Performing services on behalf of the business or service provider, including providing advertising or marketing services, providing analytic services, or providing similar services on our behalf or on behalf of a service provider;
  • Understanding internal research for technological development and demonstration; undertaking activities to verify or maintain the quality or safety of a service owned or controlled by us, and to improve, upgrade, or enhance the service that is owned or controlled by us.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information
We may disclose your personal information to a third party or a service provider for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

  • Identifiers.
  • California Customer Records personal information categories.
  • Protected classification characteristics under California or federal law.
  • Commercial information.
  • Internet or other similar network activity.
  • Geolocation data.
  • Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Advertisers and advertising agencies who desire to market to you;
  • Marketing services companies; and
  • Direct marketing partners.

In the preceding twelve (12) months, we have sold the following categories of personal information:

  • Identifiers.
  • California Customer Records personal information categories.
  • Protected classification characteristics under California or federal law information.
  • Commercial information.
  • Internet or other similar network activity.
  • Inferences drawn from other personal information.

We sell your personal information to the following categories of third parties:

  • Advertisers and advertising agencies who desire to market to you;
  • Marketing services companies; and
  • Direct marketing partners.

Your Rights and Choices
Under California Laws, California residents can exercise three privacy rights (Disclosure and Access; Deletion; and “Do Not Sell My Personal Information”), which are described in more detail below (collectively, “Rights”). These Rights are not absolute and are subject to certain exceptions. For instance, we cannot disclose or permit access to specific pieces of personal information if the disclosure or access would present a certain level of risk to the security of the personal information, your account with us, or the security of the business’s systems of networks. If you are a California consumer, we will process your request to exercise your Rights in accordance with California Laws.

A record concerning the requests may be maintained pursuant to our legal obligations. Further, we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded.

Disclosure and Access Requests
You have the right to request that we disclose to you, for the 12-month period immediately preceding the date of your request to know the following:

Categories of Personal Information Request

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Specific Pieces of Information Request

  • The specific pieces of personal information we collected about you (also called a data portability request).

When a request for disclosure is made, we will first take steps to verify your identity to protect your privacy and security. For requests to disclose categories of personal information collected, we will have the requestor provide at least two pieces of information so that we may verify the requestor’s identity to a reasonable degree of certainty. For requests to disclose specific pieces of personal information collected, we will have the requestor provider at least three pieces of information so that we may verify the requestor’s identity to a reasonably high degree of certainty and additionally provide a signed declaration under penalty of perjury that the requestor is the consumer whose personal information is the subject of the request. We are required to retain the signed declarations as part of our record-keeping obligations for 24 months.

Please note that we will never disclose a consumer’s social security number, driver’s license number, or other government-issued identification number, financial account number, any health information or medical identification number, an account password, or security questions and answers in response to a disclosure request.

Please note additionally that we are only required to fulfill a Disclosure request from a consumer twice per every 12-month period. If you submit a request in excess, it may be denied or you may be charged for fulfilling your request.

Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Given the type of personal information we collect, for requests to delete personal information collected, we will have the requestor provide at least two pieces of information so that we may verify the requestor’s identity to a reasonable degree of certainty. We are required to retain the requests to delete for a period of 12 months as part of our record-keeping obligations.

If we are unable to verify a request, to the extent possible, that request will be treated as a request to opt-out and afforded rights associated with that request right as described in more detail below.

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. A deletion request may be denied, in full or in part, if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Disclosure and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request and, to the extent necessary, to identify the browser/device that is subject to the request.

Do Not Sell My Personal Information Requests
You have the right to direct us not to sell your personal information to a third party. To request that we not sell your personal information, click the button “Do Not Sell My Personal Information.”

Further, you may designate an authorized agent to make a Do Not Sell My Personal Information request, but that agent will have to provide proof of the authorized agent’s written permission to do so. We will also require the authorized agent verify their identity corresponding to the written permission. (The verification requirement does not apply if the consumer has provided the authorized agent with legal power of attorney under California Probate Code Sections 400 to 4465.)

In addition, you may use the Opt-Out Tool provided by the Digital Advertising Alliance to send requests under the CCPA for your browser to opt out of the sale of personal information by some or all of the participating companies. To learn more about sending an opt-out request, click this green icon whenever you see it.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data disclosure requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Requests to Opt-In for Minors
If you are 16 years of age or older, you have the right to direct us not to sell your personal information at any time. We do not and will not sell personal information of consumers we actually know are less than 16 years of age unless we received affirmative authorization from the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age, to opt-in to the sale of their personal information. Upon the receipt of this request to opt-in, we will inform the minor of the right to opt-out later and of the process for doing so.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Security
Valassis uses commercially reasonable technical, administrative, and physical safeguards to protect your information against loss or unauthorized access, use, modification, or deletion. However, no security program is 100% secure, and thus we cannot guarantee the absolute security of your information.

Feedback
If you provide feedback to us, we may use and disclose such feedback for any purpose, provided we do not associate feedback with your Personal Information. We will collect any information contained in such feedback and will treat the Personal Information in it in accordance with this Privacy Policy. You agree that any such comments and any email we receive becomes our property. We may use feedback for marketing purposes or to add to or modify our Services without paying any royalties or other compensation to you.

Data Retention
We will retain your Personal Information only for as long as reasonably necessary for the purposes described in this Privacy Policy. Please be aware that we may also be required to retain your Personal Information for legal and accounting reasons.

Changes to This Privacy Policy
We may change this Privacy Policy from time to time. If we make changes, we will revise the Effective Date above and attempt to provide additional notice on our Sites. We reserve the right to modify this Privacy Policy at any time, so please review it frequently.

How to Contact Us
If you have any questions about this Privacy Policy, please contact us via email at: privacyrequests@valassis.com.

Effective: March 18, 2017

Prior Update: March 8, 2019