Brazil Data Products Privacy Policy

Scope

This policy applies to Acxiom’s information management services and information products involving Brazilian data. When we provide information management services, we process our clients’ information according to the terms and conditions of the contract. When Acxiom licenses our information products to our clients, we adhere to the practices described in this policy.

Personal Information Collection and Use

Marketing Products: Acxiom acquires various information about consumers to be used by our clients for marketing purposes. This includes contact information, general demographic information, lifestyle information and interest information. This information comes from many sources, including:

  • Public record and publicly available information: Telephone directories, website directories and listings, government agencies;
  • Data from other information providers: Demographic socio-economical and behavioral information, surveys and questionnaires and summarized or aggregated purchase information.

Acxiom uses the PROCON Do-Not-Call registry in addition to suppression data we obtain from Brasilia City Government sites in the development of our marketing products.

These products contain only general information about an individual or the household. They do not include specific details about a purchase, detailed financial information, credit information or medical information.. We will not knowingly collect, use or disclose data for marketing purposes on anyone under the age of 18. We do use information related to children to identify and remove minor records from ours and our client’s marketing files.

These products are used by qualified organizations in their marketing, fundraising, customer service and outreach programs. The information can be used to enhance our client’s customer files and provide our clients with lists for prospecting purposes.

Directory Products: These products contain contact information such as name, address and telephone number. These products are developed from the white and yellow pages of published Brazilian telephone directories and information available through directory assistance.

Acxiom’s directory products are used by organizations and consumers through Internet search sites to locate names, addresses and telephone numbers. For example, we may license some of our directory products to companies as an automated and inexpensive form of directory assistance. We also may license the directories to Internet search engines that provide nationwide directory searches to consumers.

Your Choices and How to Contact Us

Opt-Out: Consumers may opt-out of our marketing and directory products by contacting us to request our opt-out form, then submitting that completed form to us. Consumers may contact us by emailing us atprivacybrazil@acxiom.com, by calling our consumer line at 55 11 3050-7039, or by writing to us at Acxiom Brazil Consumer Advocate, Al Lorena 638 11th floor, São Paulo, Brazil 01424-00.

Questions and Concerns: Individuals with questions or concerns should e-mail us at privacybrazil@acxiom.com, call our consumer line at 55 11 3050-7039, or write to us at Acxiom Brazil Consumer Advocate, Al Lorena 638 11th floor, São Paulo, Brazil 01424-000.

Other Important Information

Additional Terms and Conditions: For a company to use Acxiom’s products and services, they are required to enter into a contract with Acxiom. The terms of these contracts may further govern the use of personal information collected and maintained by Acxiom.

Accuracy: Acxiom maintains quality control procedures to ensure the information we compile and process is as accurate and complete as possible. Acxiom responds promptly to questions from clients and consumers about the accuracy of information.

Contracted Services: Where permitted by law, third parties service providers under contract to Acxiom may have access to the information in Acxiom’s information products. Some of these service providers may reside outside of Brazil.

Security: Acxiom maintains security procedures designed to keep information we own, license and process from being accessed by any unauthorized person or business. We use a variety of multi-level security systems to control access to our services and information products. All users at client locations, as well as all Acxiom associates, must have the appropriate access codes and be authorized to access certain data and applications.

Acxiom conducts risk assessments and regular audits on our internal and external information systems to assess our ability to maintain the integrity of client and Acxiom data. Our enterprise security operations center maintains real-time monitoring for information system vulnerabilities and unauthorized access attempts into our internal systems. We also maintain physical security for our facilities and limit access to certain critical areas of our business. We take reasonable precautions to ensure that our security procedures are adequate for the protection of our computer systems and data, but this does not eliminate the possibility that our security will be breached.

Awareness: Privacy awareness and education is part of the culture at Acxiom. At the time of initial employment and annually thereafter, we require all Acxiom associates to complete privacy education and pass a certification test. When appropriate, Acxiom disciplines associates who violate our privacy policies.

Privacy Policy Changes: From time to time Acxiom may update and revise our privacy policy based on changes in our business environment and changes to applicable law. We urge consumers and clients to periodically visit our website to understand any changes that may have occurred.

Effective Date: November 27, 2012