Consumer guide to direct marketing Protecting consumer privacy and promoting trust in marketing is important to Epsilon. Our business is to help companies reach consumers who are interested in their products or services. We are committed to balancing the information needs of businesses with the privacy concerns of individuals. We have created this brochure to help explain our data marketing practices and inform you about the choices you have about the use of your information for Direct Marketing purposes. Please refer to the Glossary of Marketing Terms on our website for further explanation of unfamiliar terms and concepts. What is direct marketing? Direct marketing is the practice of marketing products or services directly to consumers. This is a more personalized approach than traditional “mass” marketing where consumers receive the same message through mass media, such as broadcast television, radio and newspapers. Direct marketing allows businesses and non-profit organizations to contact you directly about products, services or causes that might interest you. For direct marketing to be effective, it is important to first identify which groups of consumers should be contacted before the mar- keter contacts the consumer directly. Marketers do not search out specific people, but rather, groups of people that share common interests and characteristics. Direct marketing occurs in a number of ways, including: Catalogs & Postal Mailings Telemarketing Online Advertising Direct Marketing Text Messaging Ads on Mobile Devices Email Direct Marketing requires an ability to contact you directly with a relevant message based on your particular interests or characteristics. What are some types of direct marketing? Direct Mail You may already be familiar with many types of Direct Marketing delivered through the mail, including catalogs, credit card offers, flyers from local businesses, local restaurant menus, pizzeria coupons, a brochure about the new dentist in town and free trial deals. Telephone Often referred to as telemarketing, companies and non-profit organizations may contact you by telephone to sell their products or services, or get support for their causes. For example, a travel company may call you to offer a vacation package. Email If you have provided a company with your email address (perhaps you signed up for email newsletters or purchased their products on the internet), the company may send you email advertisements for new products or services, or other offers of interest. Internet Banner Advertising While browsing the internet, you will see banner (or “display”) advertising. For example, if you read the news online, you may see an advertisement at the top or side of the website. This type of advertising – known as Internet Banner Advertising – can be compared to billboards along the side of a road. As you drive down the freeway, you will see billboards advertising products and services. Similarly, as you browse the internet, you will see ads marketing products and services. Technology enables companies to show you ads that you, particularly, may find interesting, so that you click on the ad, seek additional information or make a purchase. If you have been searching for hotel rooms in New York City, the next time you’re reading the news online or browsing the Internet, you may see an advertisement for a New York City hotel, and not a hotel in Los Angeles. How does direct marketing benefit you? Direct marketing is meant to speak directly to you, the consumer. In order to do so, companies need to know about your interests and characteristics. Here are just some of the benefits to consumers: Keeping costs down and developing new and better products: Companies save money and resources by sending Direct Marketing only to consumers likely to be interested in the offer. Creating, producing and distributing advertisements costs money. In fact, companies typically spend at least 5% (and in some cases up to 30%) of their annual revenue on advertising. Saving companies money on advertis- ing keeps costs down for products and services and allows companies to focus on developing new and better products for consumers. Accessing special offers and promotions: Everyone likes a great deal. Direct Mar- keting is a good way for you to receive frequent shopper benefits and other special offers and promotions, such as coupons, free trials and “early-bird” sale notices. Helping small businesses succeed: Without the affordable avenue of direct mail, small businesses wouldn’t be able to advertise and build their business. Small businesses are the heart of the US economy and provide jobs. Helping small businesses succeed increases product and service options and contributes to a growing job market. Delivering advertisements you’re interested in: Rather than wasting time, paper and money sending you ads you’re not interested in and may even ignore, you will receive ads and information about products you may actually buy. Everyone receives some form of mass marketing (such as weekly grocery specials) that are not based on, or related to, what you actually buy. Wouldn’t you rather receive mail advertising for the specific store you shop at? Similarly, while you are browsing the internet, the advertisements displayed will be more personalized, reflecting your specific interests. Reducing the amount of unwanted mail: When you only receive ads for things that interest you, you receive less unwanted mail. For example, you would receive fewer catalogs for home furnishings, children’s apparel and gardening if you are only interested in motorcycles and fishing. If it wasn’t for targeted mailings, your mailbox might look like the insert section of the Sunday newspaper. Online services: Search engine sites (such as Google and Yahoo) are free tools that anyone can use and this is made possible because they display advertisements to you online. Many internet email accounts are free services because companies allow marketers to show ads to you while you check your email. Who is Epsilon and what direct marketing does Epsilon do? Epsilon is a Texas-based marketing company with offices around the world. We have been in business for over forty years. Many companies that sell products that you may use every day have been working with us to improve their marketing efforts. We help companies and non-profit organizations build better relationships with their customers and find new customers for their products or services. Companies may come to Epsilon to get more information about their current customers, or to obtain information about potential customers who may be interested in their products or services. This information helps make the advertising more relevant and enables a company to send you offers more tailored to the things that interest you. Companies want to find the best fit for their products and Epsilon is able to help them determine their optimal target market. This benefits you as the offers you receive will be more tailored to things you might be interested in. For example, if a woman’s shoe company wants to find consumers who are most likely to purchase their shoes, the company may not want to send a catalog to a man. And, as a consumer, you do not want to receive catalogs that do not appeal to your needs and interests. Epsilon is able to help companies ensure that their marketing communications are sent to the most interested individuals. This process also helps companies control costs since they focus efforts on sending materials to people interested in their products. What does Epsilon not do with marketing data? We do not use marketing data for any purpose other than for marketing. This means that we only help companies utilize data from our databases for contacting existing and potential customers to provide them opportunities to buy their products or services, or contribute to charitable causes. We never provide our data to individuals for their personal use. For example, if a consumer were to request information about a neighbor or co-worker, we would not provide such information. Epsilon does not provide individual look-up products or services, and we do not allow clients to use our marketing data for activities such as granting credit, employment background checks, or obtaining health insurance rates. We also do not knowingly allow marketing to children under the age of 18. What types of consumer information does Epsilon have? Epsilon’s databases have consumer information related to household purchases, demographics and interests, and self-reported information about consumers and their household. We obtain information from a number of sources, as described below, and use quality control procedures to help identify inaccurate or out-of-date information. Household purchases Our household purchase database contains consumer names and addresses, along with generalized household purchase information, to help understand the types of purchases people make. Our clients (mostly catalog and retail companies, but also non-profit organizations, publishers and others) contribute information about their customers in exchange for information about prospective customers who may be interested in their products. This information helps Epsilon and our clients narrow your preferences and interests based on where your household shops, the categories of products and services bought, and the non-profit organizations you support. For example, if you buy children’s clothing, your household will likely be in the category of “children’s apparel and merchandise” and you may receive catalogs of children’s clothing in the mail. We filter household purchases into categories, based on the purchases a household has made. The categories and descriptions below are examples of the types of information Epsilon has. We do not have all of this information for every consumer or household; this is only a sample of information that Epsilon may have. Household Category Category Items Apparel & Accessories Clothing, shoes, jewelry and accessories Home & Gifts Home décor, furniture, bedding and bath, linens, lighting and kitchen accessories, jewelry, seasonal items, collectibles, art gallery and museum merchandise, wine and wine accessories, specialty foods and gift food baskets, religious merchandise and tobacco items, pet supplies Sports & Hobbies Recreational and sporting equipment, apparel, accessories, books and magazines, sport logo merchandise and collectibles, arts and crafts supplies and materials, auto parts and accessories Home Office & Electronics Electronics and accessories, telephones, computer hardware, software, games and accessories, stationery supplies, luggage, and travel apparel, packages and accessories Garden & Outdoor Patio and garden décor and furniture, BBQ grills, garden and lawn care products, tools, supplies Media: Books, Music, Movies, Magazines and Newsletters Books and audiobooks, musical tapes, CD’s, movies, magazines, newsletters Health & Beauty Health aids, products, equipment, dietary supplements, décor, apparel, jewelry and gifts, cosmetics, lotions, perfumes, wigs, bath soaps Business Merchandise Computers, accessories and equipment, cleaning supplies, storage and organization merchandise, safety equipment, office supplies and accessories, fax machines, copiers, printers, shredders, gourmet food and gifts, stationery, business logos and imprints, business-to-business magazines, newsletters, trade publications Household demographic, lifestyle interests and real property information We gather household level demographic, lifestyle interest and real property informa- tion from a variety of sources, including public records (such as property deeds), publicly available sources (such as telephone directories) and proprietary sources (entities with which Epsilon has an agreement to receive certain data). These sources of information help our clients further understand your interests. For example, if you are interested in supporting charitable causes, you may receive a mailing from a local non-profit organization asking for donations to the upcoming clothing drive. Below are examples of the types of Household Categories and Category Items that we may have about a household. We do not have all of this information on every household; this is only a sample of information that Epsilon may have. Household Category Category Items Household Data Mailing address, county, telephone number, do not call indication Household Demographics Presence of adults along with date of birth, adult age ranges, presence of children, political party affiliation, occupation, credit card user Household Interests Collectibles, charitable causes, hobbies, music preferences, nutrition and diet, pets, books and reading, sports and recreation, travel Household Real Property Data Public record sources that provide home sale date and price, square footage, property lot size, year home built, assessed home value Self-reported information Epsilon’s Shoppers Voice® offers online surveys to households in the US and Canada to obtain information on consumer opinions and shopping behaviors. The survey asks questions about the products you buy or use and general household interests. When you voluntarily answer these questions, we gather information from the responses to better understand your household. You can answer as many or as few survey questions as you choose and, based on those answers, may receive marketing materials, including opportunities to receive free product samples, as a result of the responses given. We do not have all of this information for every individual; this is only an example of information that Epsilon may have, based on the responses to the survey. Category Category Items Individual Data Name, mailing address, email address, date of birth Household Purchases Grocery products, cleaning supplies, pet products, dietary supplements, body and skin care products, health and medication products, home electronics, recreational and hobby purchases, tobacco Household Demographics Health and wellness information, specific health conditions, education, internet, phone and cable information, occupation, number and ages of people in household, marital status, political affiliation, pregnancy, retirement, education level Household Hobbies and Interests Leisure activities, hobbies, sports, travel, reading, social media use, music, collectibles, pets, coupon use, shopping store preferences, mail order prefer- ences, cooking Household Economics Vehicle information, home type, income range, presence of assets and liabilities, credit card type, charitable support New mover data We gather information about consumers who have recently moved from entities such as utility companies, magazine publishers and public records (for example, property deeds). This database contains name, new address, and, possibly, the old address. The information helps companies, primarily businesses near the new address, bring information about local businesses, organizations and events to consumers who have recently moved. For example, you might receive a flyer in the mail for a local dentist or a coupon from a local book store. Email activity Epsilon delivers email messages on behalf of a number of companies to indivi- duals who have optedin to receive these email messages. We aggregate email and email activity data and use this activity to better target our client’s email campaigns. This data is not disclosed to our marketing partners, and, most importantly, we do not disclose email addresses to third parties. Gathering this type of information is common industry practice because it is very useful in telling a company if, when and how it should send you an email. For example, when a hotel company sends you an email about several vacation packages, it can then determine if it should send a different type of email message, or a follow-up message if you showed interest in that offer. How does Epsilon use information to model and create groups of consumers? What are “niches”? We also use the information described above to group consumers who have similar interests in “niches.” Niches are groups, or segments, of thousands of consumers who share similar buying patterns or interests. The information is then modeled with sophisticated mathematical algorithms, based on informed “guesses” on what the segment of consumers might be interested in buying next. Niches help companies save money and resources by only marketing to groups of people likely to be interested in their products. An example description of one of Epsilon’s segmentation groups is provided below. GROUP H Average household income: $111,032 Homeowner: High number of renters Average age of head of household: 50 Average length of residence: 8 years Percentage with kids: 10% (below average) Likely education level: At least some college Favored shopping methods: Mail, online, retail Likely occupations: Professional and managerial Credit card user: Yes Likely auto type: Luxury crossover utility Makes discretionary purchases on: Kitchen, home décor, female apparel, and magazines Interests: Investing, insurance, health, leisure travel, wine, cooking, gourmet food, self-improvement, cycling, golf, running/jogging, reading, online shopping, domestic and foreign travel for vacations and business Because the groups and models described above constantly change as the information Epsilon has changes, these informed “guesses” about what niche you or your household belong to may be less accurate than data we have collected directly from you. When you request a copy of our marketing data summary, we will provide you with the Niche information for you or your household under the heading “segmentation.” What kinds of information are not part of these databases? Epsilon does not have social security numbers, driver’s license numbers, bank account numbers or other financial accounts, credit card numbers, or password information. We also do not have health-related information, unless you voluntarily provided health-related information through the customer surveys mentioned earlier in this brochure. How to opt-out of information sharing? If you decide you are not interested in the benefits of direct marketing, you can opt-out of receiving marketing offers and from having your information shared with companies. There are a number of ways to opt-out. Unfortunately, there is no universal way to opt-out of all of these methods. Telephone The US maintains a national do not call registry. You can register your personal telephone number(s) so that you do not receive telemarketing calls from for-profit companies. By law, marketers must refrain from contacting you if you have submitted your number to the “do not call” list. The website is: https://www.donotcall. gov/. Canadian residents can register for the national do not call list at https:// www.lnnte-dncl.gc.ca/index-eng. These National Lists do not apply to certain organizations, such as non-profit, political or polling organizations. If you already have a business relationship with a company because you purchased from the company or asked for information, you will need to contact the company directly and ask that they no longer contact you by telephone for marketing purposes. If you receive an unwanted telemarketing call, you should also tell the caller to place you on the company’s internal do-not-call list. Email The easiest way to stop unwanted emails is to unsubscribe directly from the unwanted email received. There is usually an unsubscribe link at the bottom of every commercial email, and clicking the “unsubscribe” will remove you from that advertiser’s email list. You can also visit the company website or send an email requesting removal from the email list. If you do not want a company to share your email address with other marketers, you can also tell that company not to share your email address. Internet banner advertising You can visit the digital advertising alliance at www.aboutads.info or the network advertising initiative at www.networkadvertising.org. Both sites explain how you can prevent gathering information about you when browsing the web. You also have the option of setting your browser to notify you when internet technologies gather information about you, and can then decide whether or not to allow the gathering. Or, you can always change your browser settings to prevent information gathering. Below are links to information on managing preferences with common browsers: • Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647 • Mozilla Firefox: http://support.mozilla.org/en-US/kb/Enabling%20and%20disabling%20cookies • Microsoft Internet Explorer: http://support.microsoft.com/kb/196955 • Safari: http://support.apple.com/kb/PH11920 Postal mail Direct marketing association: The easiest way to opt-out of data sharing in the US is to register with the direct marketing association’s (DMA) mail preference service at www.dmachoice.org. All you have to do is enter your name and address on this site (which you must update every five years, or when you move or change your name) and companies that are members of the DMA and non-member companies that use this service remove the matching names and address from their databases that are used to send marketing materials to prospect consumers. Not all marketing companies utilize the DMA list, so registering with this site will not eliminate all unwanted mail, but it will likely reduce the amount. Epsilon is a member of the DMA and we utilize the mail preference service. The DMA also allows you to register deceased family members who may still be receiving mail. To receive less direct marketing mail in Canada, you can register through the Canadian marketing association’s do not contact service at: http://www.the-cma.org/?WCE=C=47|K=224217. Individual companies: If you are a customer of a certain company and you would rather opt-out of specific company marketing mailings, you can contact any company from whom you receive catalogs or other mail pieces, and ask to be added to the company’s do not mail list. The DMA list described above does not apply to companies where you are already a customer, therefore you must contact the company directly. You may also ask a company not to share your contact information with third parties for marketing purposes. This means that if you like receiving a catalog from a gardening company but do not want that company to share your name and address with other companies (such as auto supply companies or children’s apparel companies) because you do not want mail from them, you can contact the gardening company directly and ask to be placed on their do not share list. Epsilon: You can contact Epsilon directly and request not to receive marketing mailings that result from Epsilon data. By opting-out with us, you are opting-out of Epsilon’s marketing databases only, not databases belonging to other companies. There are other companies similar to Epsilon that provide consumer information to marketers for marketing purposes and you should also opt-out with them if you do not want your information shared for marketing purposes. It is important to understand that when you opt-out with Epsilon, we do not delete your information. We mark it on our databases as “do not share.” We do this because if your information is deleted, in the future, we would have no way to know that you requested that your information not be shared. When you are marked as “do not share,” we will know that you did not want your information shared in case your information is later resubmitted. We want to be sure that consumers’ requests are honored until we are told of a change. By opting-out of information sharing, will all unwanted marketing offers stop? No. By following the steps above, you will see a reduction in unwanted marketing offers, but it won’t stop all of them. It may take several weeks or months for an opt-out to go into effect, depending on the planning cycle for the marketing offer. Advertisers begin their process several months in advance of actually sending a mail piece, so your name and address may have been provided before you opted-out. There are many companies similar to Epsilon that gather information about consumers and your information may be gathered and shared by a number of different companies for similar marketing purposes. List renting and exchanging is legal and has been a common marketing practice for many years. How can you see what information Epsilon has about you? We are happy to provide you with information Epsilon has about your household in our databases. If you have questions about the information we have about your household, you can contact our privacy department at 1-888-780-3869 or complete the Epsilon marketing data summary request form. For your protection, we will need to first verify your identity, as we want to make sure information is not shared with someone else. Similarly, we cannot provide unverified access to another household’s information. If you are receiving mail for someone who does not live at your address, please contact Epsilon and we will opt that person out of our databases. Or, you can always register them on the DMA “do not mail” list discussed above. Other valuable resources The Federal Trade Commission (FTC) offers a variety of educational and reporting resources for consumers, including a Consumer Response Center, the Do Not Call Registry, Facts for Consumers, Report Violations Registry, Identity Theft Registry, and the Spam and Phishing Registry. Federal Trade Commission 600 Pennsylvania Avenue, NW Washington, DC 20580 Telephone: 202-326-2222 Toll-Free Helpline: 1-877-FTC-HELP (1-877-382-4357) Online: www.ftc.gov FTC Bureau of Consumer Protection Online: http://business.ftc.gov/ The Direct Marketing Association (DMA) offers information and tools to assist consumers in opting-out of various forms of Direct Marketing. Direct Marketing Association 1120 Avenue of the Americas New York, NY 10036-6700 Telephone: 212-768-7277 Fax: 212-302-6714 Online: www.the-dma.org DMA Mail Preference Service Direct Marketing Association 1615 L Street Washington, DC 20036 Telephone: 212-768-7277 Online: www.dmachoice.org DMA Email Preference Service www.ims-dm.com/cgi/optoutemps.php The Better Business Bureau also offers consumer privacy guidance on their website at: http://www.bbb.org/us/. The Network Advertising Initiative (NAI) provides a centralized location for consumers to opt-out of online targeted advertising at: www.networkadvertising.org. The Digital Advertising Alliance (DAA) provides another centralized location for consumers to opt-out of online targeted advertising at: www.aboutads.info. For additional information about Epsilon’s privacy and information practices, please contact us. Epsilon Attn: Privacy 2550 Crescent Drive Lafayette, CO 80026 Telephone: 1-888-780-3869 Email: privacy@epsilon.com Online: www.epsilon.com/consumer-preference-cente epsilon.com 888 309 0505 privacy@epsilon.com