NextAction Corporation takes your privacy seriously. Our privacy policy describes the types of information NextAction collects, how the company uses it and to whom we disclose such information, as well as the ways in which you can control this use and disclosure.

NextAction Online Privacy and Security Pledge

NextAction® uses this Web page to communicate to all our stakeholders about the systems and procedures we have in place to safeguard the privacy and security of data.

We adhere to these policies because understanding and honoring the preferences of consumers:

• Is at the heart of our business,
• Is best practice, and
• Part of our ongoing commitment to adhere to a self-regulatory code of conduct.

Please refer back to this page for updates to this policy, as we always seek to improve our management of this important issue.

To make the important information on this page more user friendly, we have used a Question and Answer format including a Frequently Asked Question (FAQ) section.

Consumer Notices and Choices

1. How does NextAction provide notice & choice to consumers?
   

   • Consumers who no longer wish to receive tailored advertisements can send an opt-out request to NextAction directl via email. Please send your request, including name, address, and email address, and phone number to opt-out@nextaction.net.
   • Within 30 days of receiving your request, NextAction will reply with an acknowledgement of your request and confirming a modification of our records.
   • Your preference will be noted immediately in our records, but may not impact information that has already been provided to NextAction’s Members or partners.

   
   
2. How does NextAction limit data collection?
   

   In all instances, NextAction does not collect or maintain sensitive financial or health information. For example, NextAction does not collect:

   • Social Security Numbers;
   • Drivers License Numbers;
   • Credit card numbers or banking information; or
   • Medical records

   NextAction recommends that you examine the privacy statements of companies with whom you share your sensitive personal information to understand their procedures for collecting, using, securing and disclosing sensitive personal information.

   
   
3. What data does the company collect?
   

   The NextAction Network of retailers contribute data to a co-op database with the purpose of better understanding which ads, products or services consumers might find most relevant. Based on this, our retailers can, for example, make decisions about whether to send a particular advertisement to those consumers who might find it most relevant.

   To ensure the highest level of relevance for consumers and the most efficient segmentation for retailers, NextAction Network member companies may contribute name, address, phone, email, purchase information, customer ID, demographic and other appropriate data.

   As always, NextAction provides consumers with the notice and choice they need to make informed decisions about whether and how they choose to receive the most relevant ads from retailers. In addition, NextAction recommends that its members abide by the DMA’s Privacy Promise to the American Consumer, as a demonstration of their own commitment to privacy. Consumers can opt-out of these benefits in a number of ways detailed below.

   
   
4. What does your company do with this data?
   

   NextAction Network companies work with NextAction to inform their marketing programs. Retailers may, for example, work with NextAction to develop products and services that are tailor-made to specific consumer or market segments, and then deliver advertisements with messages that consumers find relevant. The efficiency of this process ensures that consumers continue to have access to the widest possible array of products and services. This breadth of consumer choice creates competition, lowering the cost of daily living for all consumers.

   NextAction maintains information at the individual and household level, including, for example: updated delivery and address information, including legitimately obtained email address(es) and demographic information. This is used to correct our records and facilitate proper delivery of NextAction Network members' services and communications. NextAction may combine this information with information we have obtained from business partners or other companies.

   We also may disclose information about individuals’ purchasing preferences to third parties that have partnered with or been hired by NextAction or NextAction Network members to provide designated services. For example, NextAction may partner with a company that wants to know more about the types of products or services in which its subscribers are interested to deliver tailored advertising. In such a scenario, NextAction may share information about the purchasing preferences of this company’s subscribers.

   
   
5. How do you limit the use of data by the government?
   

   NextAction is bound by agreements with its more than 1200 NextAction Network members and partners in protecting the privacy and security of the data it holds. As part of those covenants and our own commitment to create consumer confidence, we only share data with government agencies or law enforcement for limited purposes, such as:
   

   • To prevent and investigate:
     • actual or suspected identity theft,
     • fraud, and
     • defend/protect the rights of NextAction or
     • other illegal activities we may also provide limited data to law enforcement.
   • NextAction takes reasonable measures, as detailed by the DMA and FTC, to protect the data we compile. To deter cyber criminals, we may work collaboratively, however, with law enforcement, including the possible sharing of the most limited amount of data possible, if NextAction becomes the target of a cyber attack – regardless of whether the attack is successful or not.
   • We will provide data to law enforcement when required to do so by a court order or legal process obtained by the requesting law enforcement agency. As part of its due process and its commitment to privacy, NextAction reserves the right to challenge and/or limit subpoenas and court orders.

   
   
6. How does NextAction secure data?
   

   NextAction invests every year in the security of the data entrusted to us. Security receives a high level of attention, because we know that understanding consumer preferences, including their demands for strong security measures, is at the heart of preference-based marketing.

   NextAction is a member of the Direct Marketing Association and abides by its self-regulatory guidelines, which include the Security Checklist co-developed by the DMA and the U.S. Federal Trade Commission. As part of this program, NextAction uses available technology, training, and other techniques to implement systems like firewalls, and offering encryption to secure data transfers. Our continued membership in DMA demonstrates our commitment to go above and beyond any laws in our quest to secure the trust of consumers and our members/partners.

   In addition to securing our data, we also voluntarily commit ourselves to Email Authentication protocols. This step reduces the ability of hackers to abuse our email system, creating an additional level of security. To learn more about Email Authentication please Click Here.

   As a condition of employment, each and every employee has to abide by the NextAction Corporate Information Security Policy to ensure the safe and secure management of data.

   
   
7. How does NextAction handle data retention issues?
   

   The retention of data in a secure, responsible manner receives a high level of attention because consumers demand strong security measures and because of our contractual obligations. For example, we delete data from our database upon request from NextAction Network companies and suppress records as requested by consumers. In all other cases, we retain data in accordance with established security and retention procedures.

8. Your California Privacy Rights
   

   As of January 1, 2005, organizations must provide residents of the State of California access to a privacy policy that gives consumers a choice in the use of Personal Information by third parties for marketing purposes.

   NextAction has a comprehensive privacy policy and provides consumers with details on how you may express your choice regarding the use of Personal Information by third parties for direct marketing purposes.

   If you are a California resident interested in exercising your third party disclosure choices please send a request to the following address with a preference on how our response should be sent (email or postal mail). Send an email to privacy@nextaction.net. (please use subject line: California Privacy) or you may contact us via postal mail at:

   NextAction
   382 Springfield Avenue
   Summit, NJ 07901
   Attention: California Privacy

   All requests must be labeled "California Privacy" on the envelope, post card or subject line. For all requests, please include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent improperly, or do not have complete information.

   
   
9. Who does this pledge apply to?
   

   NextAction’s Online Privacy & Security Pledge applies only to NextAction’s Web site. It does not apply to 3rd party or member/partner Web sites. For information on those sites, please review their privacy policies.

   
   
10. What if I believe your systems have been compromised or are not in compliance?
    

    At NextAction we take our commitment to our Online Privacy & Security Pledge extremely seriously. If you have reason to believe that our systems have been compromised in any way please send an email to abuse@nextaction.net.
    This includes any concerns you might have about a cyber criminal abusing NextAction to perpetrate phishing or other illegal/unethical behavior.

    If you have concerns about NextAction’s compliance with this policy, please send an email to privacy@nextaction.net.
    

    Alternately, you can contact the DMA if you believe we are not complying with this policy by clicking here.

    
    
11. What if the company is acquired or merges?
    

    We may provide data to acquiring third parties if NextAction is acquired or merged with another organization.

    
    
12. Who can I contact for more information?
    

    For additional information related to this privacy pledge, please send an email to privacy@nextaction.net.
    

    
    

Privacy & Security FAQ’s

1. What does NextAction’s Privacy & Security Pledge mean to me?
   

   Understanding and honoring the preferences of consumers is the heart of NextAction’s business. To ensure confidence from consumers and retailers in our practices, we commit to provide notice and choice to consumers so that they can express their preferences to us and that we can honor them.

   
   
2. Why Is Privacy and Security Important to NextAction’s Business Model?
   

   The respectful, ethical use of data and the security with which we protect it are critical components of NextAction’s business model to:

   • Present the most relevant offers to consumers in the most convenient ways and channels possible,
   • Increase the success of NextAction Network organizations in identifying new and emerging markets,
   • And, to enable increased competition that lowers the cost of daily living for all consumers.

   NextAction takes the delivery of these three goals extremely seriously and invests significantly each and every year to ensure that the trust placed in our processes, by consumers and retailers alike, is justified.

   
   
3. How does NextAction set an example in its industry?
   

   Through its work with trade associations, the media, and in thought-leadership venues, NextAction has demonstrated its ongoing commitment to proactively advocating policies that provide notice and choice to consumers.

   In addition, NextAction’s management has worked to build the confidence of consumers by supporting laws that limit the collection of sensitive personally identifiable information, like The Children’s Online Privacy Protection Act (COPPA), as well as laws that protect American consumers from international fraudsters, like US Safe Web Act.

   Notice and choice create a win-win for consumers and retailers alike. Notice and choice create balance between helping retailers identify the most relevant offers, as well as new and emerging markets. This efficiency leads directly to lower prices for consumers, while respecting their privacy preferences. Win-win.

   
   
4. What laws apply to the use of data?
   

   Congress has enacted numerous laws that deal with or touch upon the use of personal information, including to name just a few:

   • The Electronic Communications Privacy Act (ECPA),
   • The Fair Credit Reporting Act,
   • The Children's Online Privacy Protection Act,
   • CAN-SPAM Act
   • Drivers’ License Privacy Protection Act,
   • Telephone Sale Rule (National Do-Not-Call),
   • The Electronic Funds Transfer Act,
   • The Video Privacy Protection Act,
   • The Telephone Consumer Protection Act of 1991,
   • The Cable Communications Policy Act of 1984,
   • The Communications Act itself,
   • The Federal Aviation Act,
   • The Health Insurance Portability and Accountability Act (HIPPA),
   • The Right to Financial Privacy Act of 1978,
   • A myriad state law protections have also been enacted.

   The collective effect of these laws layered on top of a time-tested industry self-regulatory system administered by the Direct Marketing Association provides a robust level of privacy protection to US consumers.

   
   
5. How do I protect myself against identity theft?
   

   Identity theft is a concern for many consumers. At NextAction we do not collect or maintain sensitive personally identifiable information. This type of information is of greatest value to an identity thief.

   The direct marketing industry takes identity theft very seriously. There are a number of resources provided by the Direct Marketing Association and the Federal Trade Commission to help consumers protect themselves from identity theft and other frequently asked questions. You can find these resources at:
   How to protect your identity from being stolen

   • http://dmaconsumers.org/consumers/idstolen.html,
   • http://www.consumer.gov/idtheft

   What to do if you think your identity has been stolen.

   • http://dmaconsumers.org/consumers/whattodowhenidstolen.html.
   • http://www.consumer.gov/idtheft

   
   
6. How can you be sure that no one is abusing your systems?
   

   We cannot divulge many of the systems and practices we employ for security reasons. But NextAction is committed to continuously improving its systems and technologies to verify that our data is not used illegally, unethically or irresponsibly.

   NextAction is also a leader in being proactive by enlisting the help of its loyal NextAction Network organizations and the consumer in the fight against cyber crime. We have established and monitor an email box specifically for the reporting of suspicious activity. If you believe that one of our systems has been targeted or used illegally by cyber criminals, please email us at: abuse@nextaction.net.
   

   
   
7. What if I wanted to learn more about privacy?
   

   Over the last 10 years, the direct marketing industry has led the way on developing resources for consumers who want to understand privacy choices in the still-evolving online space. You can visit any of the following sites for further information:

   • Understandingprivacy.org
   • DMAconsumer.org
   • U.S. Federal Trade Commission Onguard Online

   
   
8. What are the benefits of data sharing to consumers and society?
   

   The ability for retailers to identify audiences based on common characteristics has greatly benefited consumers by creating tailored offers and saving consumers time, money and energy.

   The respectful and ethical use of data to make marketing decisions has been a windfall to consumers and the economy. It has saved consumers time and money through additional competition

   In 2005, the DMA reported that direct marketing increased US GDP by 10%.

   • Based on a conservative assumption that a single shopping trip would replace three direct orders, 111.3 million shopping trips were replaced by catalog purchases in 2004.
   • By that same assumption, at an average round-trip distance of 14.9 miles per shipping trip, catalog mail reduced the number of miles driven in 2004 by 1.7 billion miles.
   • This amounts to a reduction in carbon dioxide emissions of more than 35,000 tons, and a reduction in gasoline use of 75.9 million gallons.
   • Even at a 2004 average price of $1.90 per gallon, this represents an annual savings of $144 million.

   It used to be that consumers with common characteristics would be geographically concentrated, allowing retailers to make critical decisions about location, inventory and marketing based primarily on geography. Think of the local department store.

   As the American consumer became more mobile and sophisticated, audiences with common characteristics became more dispersed, but still needed the ability to shop for the products and services they needed in a convenient and efficient manner. Direct marketing allows this to happen with great benefits for consumers in terms of saving time, money and energy to name a few.

   
   

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Contact Information

If you have questions about our Privacy Policy or about any of the services we provide, please send an email to privacy@nextaction.net.

Privacy Policy is effective as of October 2006.