Confidential | GGM.ver.06.06.2022
DATA SECURITY FAQS
OUR APPROACH TO PRIVACY – We are committed to protecting the privacy of personal information and the
responsible use of that information to deliver personalized, relevant content to consumers on behalf of our
clients. We have implemented policies and procedures to comply both federal and state privacy laws and
each of our brand websites to learn more about our privacy and CCPA compliance practices.
OUR CLIENT’S INFORMATION AND CONSUMER DATA – To provision our services, we require limited access
to client systems to obtain certain information about their operations, as well as certain data about their
customers. This data belongs to our clients; we cease using and promptly remove it from our systems upon client
request or conclusion of our business relationship.
OUR APPROACH TO SECURITY – We have implemented cybersecurity policies and procedures across our
organization based on industry best—practices and regulatory requirements. Our security measures including
hosting data in the Google Cloud, deploying firewall and security protocols across our network, encrypting
sensitive data in transit, limiting data access to designated groups, requiring multifactor user authentication, and
deploying physical security at our facilities and colocation sites. We regularly monitor our systems,
including through independent third party-audits, to ensure on-going compliance.
OUR INSURANCE – Despite state-of-the-art security protections, data breaches and security incidents can occur.
Therefore, we back up our commitments by carrying additional professional and cyber liability insurance.
OUR THIRD PARTY SERVICE PROVIDERS – We have partnered with, industry-leading DMS and data processing
and integration providers. We contractually require any of our service providers who have access to client data to
maintain cybersecurity insurance, meet all federal and state legal requirements, and follow industry-leading data
security practices. We remain liable to our clients for our vendors’ actions.
OUR CONTRACTUAL OBLIGATIONS – Our client agreements contain service provider data access and
safeguards protections, in accordance with industry standards, and applicable laws, including the GrammLeach-Bliley Act, FTC Safeguards Rule, and CCPA. This includes our commitment to use consumer data for
the sole purpose of providing services to our clients. We do not sell their data. Clients may review our
contractual commitments under the Data Safeguards sections in the Terms & Conditions that govern their
agreement with us.
YOUR DATA; OUR COMMITMENT – No company can guarantee information security with absolute certainty.
But at our company, protecting client information and consumer data is at the core of our business
philosophy. It informs every decision we make, from how we architect our IT systems, to the vendors we
choose. Our clients entrust us with information about their most precious assets – their customers. We hold that
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