Nexus Direct Privacy Policy
Updated November 4, 2019

 

Source and Usage of Data

Nexus Direct obtains marketing data for both businesses and consumers through our clients. Nexus Direct also acquires data from third parties to be used by our clients. Many of our client solutions involve various uses of data, including the storage, exchange, transfer, management, and analysis and/or reporting of such data. Nexus Direct does not collect data directly from consumers except for information collected as part of our clients’ marketing programs.

Privacy Viewpoint

Nexus Direct remains dedicated to the safeguarding of data provided by clients and third-party sources and has taken the necessary steps to secure the data in our possession. We fully understand the paramount importance of protecting consumer privacy within our business and within our industry; therefore, we continually seek robust ways to protect, guard, and ensure the appropriate use and storage of data related to our constituents and continually promote and condone direct and indirect policies that share the same best practices of data security in our industry.

Opting Out of Direct Mail and Telemarketing

Nexus Direct respects a consumer’s choice not to receive direct mail advertising. Please send any opt-out requests and/or any marketing preferences to the attention of Nexus Direct Opt-Out DM, 101 West Main Street, Suite 400, Norfolk, VA 23510.

To inquire about or to make additional opt-out direct mail advertising requests beyond that of Nexus Direct, visit the national trade organization, U.S. Association of National Advertisers , at their website — https://www.dmachoice.org/— for further options to decrease direct mail receivables. While Nexus Direct cannot make any expressed guarantee of the elimination of all promotional mail offers, one should observe an overall reduction in the amount of promotional material received through the mail.

Nexus Direct also respects the consumer’s option not to receive telemarketing correspondence. Forward those requests to the attention of Nexus Direct Opt-Out TM, 101 West Main Street, Suite 400, Norfolk, VA 23510. To opt out of telemarketing calls beyond those of Nexus Direct clients, we recommend registering applicable information with the Federal Trade Commission’s National Do Not Call Registry located at https://www.donotcall.gov/.

Access to Personal Information

At Nexus Direct, we believe in the importance of providing consumers with clear, accurate information about the data within our marketing databases. To request access to amend, correct, or delete any information from Nexus Direct’s database about a household, simply email dataprivacy@nexusdirect.com with any preferences or requests.

Information Management

Nexus Direct provides information management and marketing services designed to help companies and organizations improve their marketing strategies and programs. These services involve third parties and utilize cookies, web beacons, and other tracking and retargeting mechanisms. When providing marketing services to our clients, we process information according to the terms and conditions of the contract set forth by our clients. Accordingly, Nexus Direct relies upon the instructions of its clients with respect to the use of marketing information. Ultimately, our clients advise us of any consumer preference or opt-in/opt-out choices.

Third-Party Data Sources

Nexus Direct hosts and maintains various third-party data on behalf of our clients. When Nexus Direct provides data products to clients, we strictly adhere to the terms and conditions defined by third-party data suppliers.

Information Security

Nexus Direct has implemented responsible, industry-standard security policies, standards, and practices designed to protect information from internal and external threats. The degree of protection for each piece of information is based on the risk and consequences associated with having that information compromised. While no security measures will provide absolute security, all Nexus Direct employees responsible for the management of information have the responsibility to adhere to Nexus Direct’s documented security controls that are commensurate with the understood risk.

Website Privacy

Please go to https://nexusdirect.com/website-policy.

 

Privacy Shield

Nexus Direct complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom to the United States in reliance on Privacy Shield. Nexus Direct has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

 

Onward Transfers

Nexus Direct acts as a processor on behalf of its clients, providing customized services that enable organizations to manage their customer information efficiently by reducing data processing timeframes, increasing marketing efficiency, and applying database marketing strategies. Nexus Direct processes marketing information of its clients and on behalf of its clients. In this capacity as a processor on behalf, Nexus Direct acts on the instructions of its clients and does not control or share such data without direction from the client.

 

For such data processing, Nexus Direct enters into contracts with its clients in the European Union (EU) and the United Kingdom (UK) specifying that the EU/UK client recognize that it is a data controller for the purpose of the European Union Data Protection Directive and is in compliance with the corresponding Member State national data protection laws. These contracts ensure the processor acts only on instructions from the controller, provided adequate measures of data protection, and assists the controller in responding to individual requests exercising their rights under the Principles.

 

In cases of onward transfer to third parties of data of EU and UK individuals received pursuant to the EU-US Privacy Shield, Nexus Direct is potentially liable.

 

 

 

Data Security

Nexus Direct will not disclose to third party’s personal data processed in this capacity, except as permitted or required by the processing agreement, Privacy Shield Principles, applicable Member State data protection law, or as otherwise required by law. Nexus Direct has reasonable security measures in place to help protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

 

Please see the U.S. Department of Commerce’s website — https://www.privacyshield.gov/— for details regarding our compliance.

 

Inquiries and Dispute Handling

Nexus Direct has designated a team responsible for the internal supervision of Nexus Direct’s privacy policies. Nexus Direct educates relevant employees about compliance with the Privacy Shield Principles and has self-assessment procedures in place to ensure compliance.

 

For any complaints regarding Nexus Direct’s compliance with the Privacy Shield Principles, including access to data where one can amend, correct, or delete information, please contact us at:

 

Email:   dataprivacy@nexusdirect.com

 

Mail:     Nexus Direct

101 West Main Street, Suite 400

Norfolk, VA 23510

http://www.nexusdirect.com/privacy-policy/

 

Phone:  +1-757-961-3219

 

The U.S. Association of National Advertisers (ANA) serves as Nexus Direct’s third-party dispute resolution provider, as required under the Privacy Shield Principles. If by contacting Nexus Direct without satisfactory resolution, complaint(s) may be filed with the U.S. Association of National Advertisers using the following contacts:

 

To file a complaint/inquiry with ANA: https://thedma.org/resources/consumer-resources/privacyshield-consumers/dma-eu-privacyshield-complaint-form/

 

Or go to:

 

Web:     https://thedma.org/resources/consumer-resources/privacyshield-consumers/

 

Mail:

ANA
Attn: Privacy Shield
225 Reinekers Lane, Suite 325
Alexandria, VA 22314

 

Fax:      +1-202-955-0085

 

In the event complaints to Nexus Direct and the U. S. Association of National Advertisers do not result in a satisfactory resolution, a consumer may seek binding arbitration. Additionally, if the consumer has a national security concern, you can contact the Ombudsperson at the Department of State at http://www.state.gov/s/ombudsman/.

 

Enforcement

Nexus Direct is subject to the investigatory and enforcement power of the Federal Trade Commission, the Department of Transportation, or any other U.S. authorized statutory body. We are required to disclose personal information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

 

 

Contact Information

For questions or comments related to Nexus Direct’s privacy policy, please contact:

Nexus Direct
Privacy Committee
101 West Main Street, Suite 400
Norfolk, VA 23510
dataprivacy@nexusdirect.com

General Data Protection Regulation Compliance: as it pertains to work performed by Nexus Direct for our clients.

 

Definitions

Service

Service is the data processing and analysis performed by Nexus Direct for our clients

 

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

 

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

 

For the purpose of this Privacy Policy, our Clients are a Data Controller of Personal Data.

 

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller

 

For the purpose of this Privacy Policy, Nexus Direct or Service Providers are Data Processors of Personal Data.

 

We may use the services of various Service Providers in order to process your data more effectively.

 

Information Collection and Use

We collect Personal Data, through our clients, for various purposes to provide and improve our Service.

 

This includes certain personally identifiable information that can be used to contact or identify individuals (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address

 

Use of Data

Nexus Direct uses the collected data for various purposes:

  • To provide marketing Service to our Clients
  • To gather analysis or valuable information so that we can improve our Service

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Nexus Direct legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

 

Nexus Direct may process Personal Data because:

  • We need to perform a contract with our Clients
  • Our Clients have given us permission to do so
  • The processing is in our Clients legitimate interests and it’s not overridden by individual rights
  • To comply with the law

Retention of Data

Nexus Direct will retain our Clients Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use our Clients Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

 

Transfer of Data

Our Clients Data, may be transferred to — and maintained on — computers located outside of our state, province, country or other governmental jurisdiction where the data protection laws may differ than those from our Clients jurisdiction.

 

If our Clients are located outside United States and choose to provide information to us, please note that we transfer the data, to United States and process it there.

 

Our Clients consent to this Privacy Policy followed by their submission of such information represents our agreement to that transfer.

 

Nexus Direct will take all steps reasonably necessary to ensure that our Clients data is treated securely and in accordance with this Privacy Policy and no transfer of our Clients Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

Disclosure of Data

 

Business Transaction

If Nexus Direct is involved in a merger, acquisition or asset sale, our Clients Data may be transferred. We will provide notice before Data is transferred and becomes subject to a different Privacy Policy.

 

Disclosure for Law Enforcement

Under certain circumstances, Nexus Direct may be required to disclose our Clients Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

 

Legal Requirements

Nexus Direct may disclose our Clients Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Nexus Direct
  • To prevent or investigate possible wrongdoing in connection with our Service
  • To protect the personal safety of users or the public
  • To protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

 

Individual’s Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Nexus Direct aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

 

In certain circumstances, you have the following data protection rights:

 

The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where Nexus Direct relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

 

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

 

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Please go to https://nexusdirect.com/privacy-policy

to see changes.

 

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on our website.

 

Contact Us

If you have any questions about this Privacy Policy, please contact us:

  • By email: dataprivacy@nexusdirect.com
  • By phone number: +1.757.340.5960