Privacy Policy

Data Collection

V12 Group brings together data from various sources to help identify consumers who are more likely to respond favorably to the Offers of its business clients. This includes "Personally Identifying Information," such as first and last names, email addresses, and physical location addresses that V12 Group and others collect directly from consumers. V12 Group then correlates that information with other data, such as demographic information, geographic location, hobbies and purchasing preferences, obtained from other sources, which is maintained in personally identifiable form in combination with those consumer names and/or addresses. (All such categories of personally identifiable information and other information maintained in personally identifiable form are referred to below as "Categories.") V12 Group does not include in its database such sensitive information as medical records, social security numbers, credit card numbers or credit history.

V12 Group knowingly collects personally identifiable information only about consumers who have voluntarily given information about themselves by registering at a website (referred to here as "Registration Data"); and have been given clear and conspicuous notice that their electronic mail address or postal mail address or both could be transferred to third parties for the purpose of initiating commercial mail messages by electronic or postal delivery; and have chosen to accept those messages by affirmatively "opting in" or by electing not to "opt out" or by agreeing to accept those messages as a condition of participating in a website. Some of this Registration Data comes to V12 Group from its own online relationships with consumers. Much of the Registration Data comes from other businesses who collect it through their own direct consumer relationships or who accumulate Registration Data that was collected from consumers by others; in each case, they must satisfy V12 Group that the information they supply for the V12 Group database meets these three criteria.

V12 Group then double-checks in three different ways that the consumers represented in its database have chosen to accept third party Offers. The first check occurs when V12 Group receives Registration Data from other businesses relating to consumers who are not in the active V12 Group database; V12 Group sends these consumers an email giving them an opportunity to avoid receiving third party Offers by opting out of the V12 Group database. A second check occurs when V12 Group periodically sends all consumers in its active database an email giving them an opportunity to avoid third party Offers by opting out of the V12 Group database. A third check occurs each time an Offer is sent to consumers; with each Offer, consumers are given the opportunity to opt out of receiving further Offers from the same source, or to opt out of the V12 Group database, or to do both.

V12 Group does not collect information online from consumers passively without authorization such as through the use of "cookies" and does not knowingly collect information from third party sources that has been collected online by such means.

V12 Group does not knowingly collect personally identifiable information either directly or from third party sources relating to anyone under age 13 and takes reasonable steps to avoid including such information in the V12 Group database.

Direct Use of Data by V12 Group

V12 Group takes Registration Data and combines it with data from other third party sources to create enhanced profiles of the consumers represented in its databases. These profiles may include characteristics described in the Categories above such as demographic information, geographic location, hobbies and purchasing preferences.

When a V12 Group business client so requests in connection with a particular Offer, V12 Group analyzes the profiles in its database to identify consumers with characteristics that make them seem more likely to react favorably to the Offer.

V12 Group uses the results of these analyses to send Offers by email to the attention of those consumers on behalf of its business clients.

Disclosure of Data to Third Parties

V12 Group does not disclose Registration Data or any other data from its database to third parties, subject to the following exceptions.

a) For Offers to be sent by postal mail and for occasional Offers to be sent by email, V12 Group will give select business clients access to addresses of consumers with relevant characteristics. These clients will then send their Offers directly (or through a third party service). V12 Group does not itself send Offers to consumers by postal mail.
b) On occasion, for particular Offers, V12 Group will give select business clients contact information of consumers with relevant characteristics organized by select categories (such as age or geographic location). This allows the client to send a different communication to consumers in each category with respect to that Offer.
c) V12 Group will disclose information in response to a legal subpoena or other legal process; or if reasonably necessary to protect the property, rights, or safety of V12 Group, its clients, or the public.
d) V12 Group will also disclose to its business clients and prospective clients, "aggregate data" that relates to groups of consumers who are not named or otherwise personally identified. (An example of aggregate data would be the number of consumers in the V12 Group database with credit cards.) Our clients often use such data to analyze the success of their Offers.

V12 Group shares data with companies that provide consumer products and services. There is virtually no limit to the variety of these companies, which include financial services providers, retailers, restauranteurs, pharmaceutical companies, educational institutions, automotive companies, travel companies and utilities.

V12 Group only discloses personally-identifiable data to its business clients for use in connection with Offers approved by V12 Group. By contract, we limit use of the data to the Offer that was approved and forbid any other use. After the data has been used in connection with the Offer, we require that it be permanently erased from client files and databases.

Security

V12 Group takes reasonable and appropriate measures to protect against unauthorized access, alteration, destruction or disclosure of data in the V12 Group database.

Internally, we restrict employee access to personally identifiable information in our database on a "need to know" basis and strictly forbid any use of data that is inconsistent with this Privacy Policy. We will use all legal procedures at our disposal if any of these rules are violated.

Data Access and Requests to Change Information

Anyone can gain access to personally identifiable information in the V12 Group database relating to him or her for the purpose of checking its accuracy, updating the information, or for any other lawful purpose.

Deletion from the V12 Group Database

As noted above, V12 Group periodically sends an email to all consumers in its active database giving them an opportunity to avoid receiving third party Offers by opting out of the V12 Group database. This occurs approximately twice per year.

Each time an Offer is sent to consumers, they are given the opportunity to opt out of receiving further Offers from the same source, or to opt out of the V12 Group™ database, or to do both.

Once a consumer is removed from the active V12 Group database by one of these means, we will not make any further use of personally identifiable information about the consumer, and will not subsequently give such information to our business clients for their use, in connection with Offers. Also, once removed, you will not be added back to our active database without your specific permission; we will permanently note your election to opt out in a file separate from our active database and as new data comes in, we will cross-match it with the separate file. Any further information about you that comes to us through our own efforts or a third party source will be kept out of our active database.

Changes to this Privacy Policy

We may change this policy from time to time. We may do so on our own initiative, or in response to new legislation, or for other reasons such as a transfer of ownership of V12 Group, Inc. to a different company with a different privacy policy.

Should this policy be amended, the amended policy will be posted in the Privacy Policy location at the V12 Group site.

The date of each version of this privacy policy will be noted at the top of the Privacy Policy at the V12 Group site. Our prior versions, and the dates of their use, will be stored in an archive accessible through the Privacy Policy location at the V12 Group™ site.

For any questions, please contact:
V12 Group
2 Bridge Ave
Floor 3
Red Bank, NJ 07701