Innovairre Communications along with our subsidiaries and affiliates (Innovairre) respects the privacy of information that identifies you or is identifiable to you (Personal Information). We want you to understand how Innovairre processes Personal Information, and how you can submit privacy rights requests to us concerning your Personal Information, in compliance with the various laws in the United States, Canada, European Union, and other countries that govern our processing of your Personal Information (Data Privacy Laws). Innovairre’s processing of Personal Information is governed by those Data Privacy Laws as well as this Privacy Policy (Policy).
We do not intend to, and do not knowingly, process Personal Information about individuals who are minors in the jurisdictions where they reside (Children). Individuals who are Children should not provide any Personal Information to us, and individuals should not provide Personal Information to us about Children.
Data Privacy Officer
For questions about Innovairre’s processing of your Personal Information or this Policy, please contact our Data Privacy Officer as follows:
Colin Scheule, Director of Corporate Information Technology
Innovairre Communications
3200 West Market Street, Suite 302, Akron, OH 44333
(330) 869-8500
Innovairre provides a variety of different types of direct mail services (Services), including agency, strategy, creative, artwork, literary, premium sourcing, publishing, printing, mailing, other distribution, mail collection, donation processing, and data gathering and analytics. We provide Services to many different clients (Clients), who are predominately (though not exclusively) charitable organizations. Depending on the Client, Innovairre may provide all of the Services listed above, or only some of them.
In the course of providing Services, Innovairre receives from Clients, receives from individuals, itself collects, and processes Personal Information, which may include the following: name; physical address; email address; phone number; donation history, amount, and preferences; premium history and preferences; memberships in, affiliations with, and support for various organizations; employment history and information; and various aspects of an individual’s public, professional, and personal life.
In addition, depending on the nature of the Client for whom Innovairre is providing Services, and depending on the type of information collected by the Client or provided by individuals to the Client or Innovairre, in the course of providing Services to certain Clients, Innovairre may receive from Clients or individuals, itself collect, and process certain types of Personal Information that is of a sensitive nature (Sensitive Personal Information), including information about the following: race; ethnic origin; national origin; gender; sexual orientation or identity; sex life or activity; religion or religious affiliation; political opinions or affiliation; philosophical beliefs; trade union membership or affiliation; physical or mental health; governmental identification numbers; and numbers for bank, debit, credit, and other financial accounts. For purposes of this Policy, Sensitive Personal Information is a sub-category of Personal Information.
Innovairre processes Personal Information only for Clients. A Client directs Innovairre with respect to the processing of Personal Information for that Client, and Innovairre does not process Personal Information for the Client without such direction. As such, our Clients are controllers of Personal Information, and Innovairre is a processor, as those terms are defined and used in Data Privacy Laws.
Innovairre does not process Personal Information that we receive from or collect for one Client for any other Client or unaffiliated third party. If and to the extent any Client of Innovairre obtains Personal Information from any other Client or unaffiliated third party – including any other Client or unaffiliated third party that sell, shares, trades, exchanges, or brokers Personal Information – Innovairre relies solely on the Client who provides such Personal Information to us to ensure that Client, the other Client, and the third parties involved have complied with Data Privacy Laws and all other policies and rules applicable to Innovairre’s processing of that Personal Information.
If and to the extent you have received, or had a right to receive under Data Privacy Laws or otherwise, notice about the processing of your Personal Information, Innovairre relies solely on the Client for whom we process your Personal Information to ensure that such notice has been provided to you. Similarly, if and to the extent you consented, or had the right to consent under Data Privacy Laws or otherwise, to the processing of your Personal Information, Innovairre relies solely on the Client for whom we process your Personal Information to ensure such consent has been obtained from you.
Innovairre has contractual and other commercial, business, and legal relationships with and obligations to provide Services to Clients. Client and individuals provide Personal Information to Innovairre and Innovairre collects and processes Personal Information for Clients in order to provide Services to Clients. That is the legal basis for Innovairre to process Personal Information. Depending on the Services that Innovairre is providing to a certain Client at any point in time, we may use Personal Information to provide some or all of the Services listed above to the Client.
Disclosure of Personal Information
Except as necessary or appropriate to provide Services to a particular Client, Innovairre does not disclose Personal Information that we received from or collected for that Client to any other Client or unaffiliated third party, provided that we may disclose Personal Information for the following purposes and in the following circumstances.
Privacy Rights
Depending on the Personal Information that Innovairre has about you, and depending on the manner in which we process your Personal Information, you may have the following privacy rights related to our processing of your Personal Information.
Since Innovairre processes Personal Information for many different Clients, any request that you make to us concerning these rights must necessarily be made with respect to the particular Client for whom we process your Personal Information.
To make a request concerning these rights, please send an email to privacy@innovairre.com. We will confirm receipt of all such complete Privacy Rights Request Forms within 10 days of receipt. Upon receipt of a complete Privacy Rights Request Form, Innovairre will forward your request to the Client(s) specified on your form from who we received or for whom we collected your Personal Information. We will then comply with the direction provided by the Client(s), including by responding substantively to your request within 30 days, subject to any lawful extension of that period. Additionally, there may be a delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized person.
Please aware there may be valid reasons to refuse a request. In such a situation, we will notify you in writing of the reason within 30 days. You may also contact our Data Privacy Officer for help with that situation.
Innovairre will not discriminate against you if exercise any of the foregoing rights or any other rights under Data Privacy Laws, including, by not denying goods or services to you, not providing a different level or quality of goods or services to you, and not suggesting that you will receive a different level or quality of goods or services.
Selling, Share, Trading, Exchanging and Brokering Personal Information
Innovairre does not sell, share, trade, exchange, or broker Personal Information (including as those terms are defined and used in Data Privacy Laws) in any way, including for itself, any Client, or any unaffiliated third party. If and to the extent any Client or unaffiliated third party sells, shares, trades, exchanges, or brokers your Personal Information, that Client or unaffiliated third party is solely responsible, to the extent required by Data Privacy Law or otherwise, to notify you and obtain your consent for such sale, sharing, trading, exchanging or brokering of your Personal Information.
If and to the extent you want to opt-out of the sale, sharing, trading, exchanging, or brokering of your Personal Information by one of our Clients, please send an email to privacy@innovairre.com, and we will address such requests as described in the foregoing section of this Policy.
Innovairre does use automated decision making or profiling in the processing of your Personal Information, and does not make decisions that affect you based on automated decision making or profiling using your Personal Information.
Because the Services that Innovairre provides vary significantly from Client to Client, the duration we retain Personal Information varies significantly, depending on the types of Services that Innovairre provides to a particular Client and the duration and depth of Innovairre’s relationship with a particular Client. Innovairre endeavors to retain Personal Information that it receives from or collects for a Client for only as long as is necessary or appropriate to provide Services to that Client.
When you visit the Site, Innovairre may place a cookie (a text file containing a randomly assigned number) on your device so that we have the ability to customize the look and feel of the Site for you. Cookies remember information about you, your preferences, and your device for a better user experience when visiting the Site. Using cookies, we may also collect a variety of other information regarding your usage of the Site, including your Internet protocol address, username, session identification, browser you are using, web pages you view and referring web pages, when you access the Site, and general online behavior for performance and marketing purposes.
Innovairre reserves the right to change or amend this Policy at any time and for any reasons, including to remain in compliance with Data Privacy Laws.
Questions or Concerns
For questions or concerns, please contact our Data Privacy Officer as follows:
Colin Scheule, Director of Corporate Information Technology
Innovairre Communications
3200 West Market Street, Suite 302, Akron, OH 44333
(330) 869-8500
Last Updated: February 24, 2023