The Data Center recognizes that consumers have rights regarding the use and dissemination of information about themselves. Notices should be provided that explain the collection, use and distribution of personally identifiable information. The Data Center conforms to all legal and self-regulatory guidelines for providing a consumer notice, access and choice. To understand what information The Data Center compiles, how it Is used and to learn how to exercise choice and access, please read the information on Notice, Access and Choice.

Compliance

The Data Center is registered with the Information Commissioner and has implemented internal controls and procedures designed to ensure compliance with the Data Protection Act of 1998.

The Data Center works with recognized trade associations and organizations that support consumer privacy. The Data Center actively participates in the Direct Marketing Association's efforts to maintain and develop appropriate industry guidelines and regulations to safeguard the consumer's rights to privacy.

The Data Center supports industry self-regulation and believes such actions are the best way to protect privacy. The Data Center also supports legislation and regulatory efforts to introduce fair and workable guidelines that protect the privacy of the consumer and also allow the consumer to continue receiving the benefits that sophisticated marketing techniques and services provide.

We recognize and actively support industry sector codes of practice and relevant legislation that covers other industry-specific guidelines on privacy, such as the Banking Code and the recommendations of the Office of Communications.

The Data Center US is also registered with the Department of Commerce for EU Safe Harbor.

More information can be found under The Data Center's EU Safe Harbor Policy.

Ethical Relationships

The Data Center pledges to conduct our relationships with both clients and other information providers in an ethical and professional manner. The Data Center includes in our client and supplier contracts a commitment that any data sent to us has been legally obtained and that the client's subsequent use of any data received from us will be in compliance with all data protection laws, as well as with applicable Industry information practices.

The Data Center includes in our information provider contracts a commitment that the data we receive has been legally obtained for the uses to which it will be put. Furthermore, we agree to comply with any restrictions that these information providers place upon the data.

If The Data Center has reason to believe that a client or an information provider is not in compliance with these commitments, we will terminate our relationship with them.

Awareness

The Data Center educates all our employees about the issues, guidelines and laws surrounding individual consumer rights to privacy and about The Data Center's privacy policies.

We provide information to all employees beginning with information during Induction Training, on the importance of consumer privacy. We provide ongoing education on the laws and accepted practices under which The Data Center conducts its business.

All new employees sign confidentiality agreements as a condition of employment with The Data Center.

We discipline associates who violate or fail to report violations of our privacy policies and practices.

Accuracy

The Data Center maintains strict quality control procedures to ensure our information is as accurate as possible. Our quality-control procedures are designed to assure that the information we compile and process is both accurate and complete. The Data Center responds promptly to any question about the accuracy of information from our clients and the consumer.

Security

The Data Center maintains strict security procedures that ensure information will not be made available to any unauthorized person or business.

The Data Center uses 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 The Data Center associates, must have the appropriate access codes and be qualified to access that specific data and application.

The Data Center conducts risk assessments and audits on all internal and external information systems to maintain the integrity of customer data. The Data Center has rigorous physical security for our facilities and limited access to certain critical areas of the business.

Online Practices

The Data Center's online privacy practices apply to the collection and use of information collected online from individuals, prospects and customers who visit our website. These policies describe The Data Center's use of cookies and what choices individuals have over the use of information collected by such technologies and can be found in our Online Privacy Policy.

Consumer Benefits

The Data Center offers services and information products that provide benefits to both consumers and businesses. Consumers benefit from The Data Center's services through the realization of the lower prices that result from our clients' more efficient marketing approach and transaction processing. In addition, consumers realize savings in time and expense and benefit from loyalty programs that are facilitated by our systems.

The Data Center enables marketers to tailor products and services to meet the needs of customers. Furthermore, they can refine their promotion efforts to target only those customers who would benefit from a particular product.