Privacy Policy

Curinos Online Privacy Notice

Last Updated August 2025

1. Overview

Curinos LLC, Curinos Limited, Curinos International Limited, and Curinos, Inc. and its subsidiaries (collectively “Curinos”) prepared this Online Privacy Statement (“Privacy Notice”) to explain how Curinos collects, uses, discloses, and protects Personal Information (defined below) across our brands and in different contexts using ethical and responsible practices that respect your privacy, and as required by law.

This Online Privacy Statement (this “Privacy Statement”) applies to Personal Information collected on our websites, mobile applications, or cloud-based services and communication platforms with a link to this Privacy Statement (collectively, the “Site”).  It covers how Curinos collects, uses, shares, and otherwise processes Personal Information as of the date that this Privacy Statement is posted.  It does not apply to any other information collected by us through any other means.  “Personal Information,” means information that identifies or can identify you personally, including any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or its equivalent.

2. Collection of Information

For public areas of our Site, we generally collect and process only Personal Information you voluntarily provide to us.  For some secure areas of our Site, however, Curinos may require you to provide Personal Information, including your login credentials.  Curinos may also collect your Personal Information to perform services on our Site, enhance the services offered to you, maintain and improve the Site, to secure our Site, comply with legal obligations, and inform you about other services and products that may be available through Curinos, our affiliated companies, and our marketing partners.  If you choose not to provide us with the Personal Information that is legitimately required, Curinos may be unable to provide you with the information or services you have requested. Public areas of our Sites ask for Personal Information from you when you engage in the following activities:

1. Sign up for newsletters or general information about our products and services
2. Submit comments, reviews, or other user generated content
3. Apply for a job
4. Request customer or technical support

Personal Information may include any or all of the following:

1. Name;
2. Postal or billing address;
3. E-mail address;
4. Telephone or mobile number;
5. Location via IP address
6. Device being used (for our mobile site)
7. Previous login history with our Site; and
8. Other relevant data, including any information you provide when contacting us.

Even if you do not send us any Personal Information, Curinos may collect certain non-personal information about how you use our Site. This non-personal information cannot reasonably identify you, and is used for statistical purposes.

3. Information Collected Through Technology

Curinos may also obtain information in other ways through technology. Some of this information may be linked to you personally. Curinos processes this information to help our Sites function correctly, and better understand the needs of our customers.

Device Information. Depending on the permissions you’ve granted and other factors, Curinos may receive information about your location and your mobile device, including a unique identifier for your device. Examples of the device information Curinos collects include:

• Attributes such as the operating system, hardware version, device settings, battery and signal strength, and device identifiers.
• Certain device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals are gathered if you enabled the functionality within your product configuration.
• Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.
• Gathering of IP addresses is used for our enhanced security.

Most mobile devices allow you to turn off location services, and Curinos encourages you to contact your device manufacturer for detailed instructions on how to do that.

4. Information Collected Through Partners

As a part of its business, Curinos collects certain information (i.e., pseudonymized data) from its partners containing an identifier Curinos cannot reverse.  Partner data can be classified as follows:

1. Client Partners – Reporting and Analysis – This pseudonymized data is primarily used in analysis for Client Partners, and that data is generally aggregated to averages at consumer segments. Curinos has no way of personally identifying this data received from Client Partners, nor does it sell or share consumer information to third parties.
2. Third Party Data Providers – This pseudonymized data is provided by third parties for analysis reporting, market assessment, and developing pseudonymized marketing audiences. In some cases, Client Partner data is enhanced with Third Party Data at the direction of the Client Partner to inform marketing audience development.  Reporting and analysis is provided in aggregate, and never in a way that is personally identifiable to an individual.  Marketing audiences, at the direction of Client Partners, are provided pseudonymously by Curinos back to Third Parties at the direction of Client Partners for re-identification for marketing campaigns.  Ownership and authorization to use such pseudonymized data is based on warranties provided by Third Party Data Providers Curinos uses under contract.

5. How Curinos Uses and Shares Your Personal Information

Whatever the purpose may be – whether to share with service providers, consultants, government authorities, or other external entities – Curinos only processes and shares your Personal Information to the extent reasonably necessary to fulfill your requests and meet our legitimate business and legal objectives.  Curinos does not share your Personal Information with unaffiliated third parties solely for their own direct marketing purposes. Curinos does not sell your Personal Information.  When Curinos discloses Personal Information to external entities to perform support services for it, Curinos will establish by contract that they may access your Personal Information only for the purposes of performing those support services. Curinos may also use what it knows about you to potentially offer you other products and services in the future. Curinos may combine your online information with information collected from offline or online sources, or information it already has. Curinos may also use and disclose certain Personal Information to our affiliated companies and others for any purpose allowed by law.

Curinos will use your information to provide certain services and to comply with regulatory or legal requirements imposed on it in each jurisdiction in which it operates. Curinos may monitor or record any communications with one of our employees, including meetings, Teams communications, and telephone calls. Curinos may use these recordings to check instructions provided to it, to assess and improve services to clients, and for training and quality purposes.  The information may also be used to invite you to events and inform you about other Curinos products that may be of interest to you or your organization, and may be shared with partner companies that provide marketing services to us at our request and under our direction. The requirements for the regulation of financial institutions could change in the future and while this notice will be regularly reviewed, Curinos may need to process your data for additional purposes not listed but necessary to give effect to the business relationship.

Business Activities. Curinos generally processes and may disclose your Personal Information to others to:

• Verify your identity or for other fraud prevention measures and reporting obligations;
• Monitor inbound calls for training and quality enhancement purposes
• Perform certain transactions initiated by you
• Respond to your questions about our products or services
• Perform Site analytics
• Engage in automated decision-making, including profiling
• Send you communications about a program or service, ads and promotions, electronic newsletters, or other marketing activities
• Comply with applicable law, obey judicial orders, cooperate with law enforcement authorities, or prevent any suspected illegal activities
• Help us run our business
• For any other everyday business purposes, such as product development and Site administration

6. Legal Grounds for the Collection, Use, Sharing, and Other Processing of Information

Certain jurisdictions require the identification of the legal grounds for the collection, use, sharing, and other processing of Personal Information. Curinos relies on the following legal grounds for the collection, use, sharing, and processing of Personal Information as described in this Privacy Notice:

• Necessary to provide information or otherwise carry out the performance of a contract with you as an individual;
• Curinos’ legitimate interests, including:
  • Performance of the contract with you or a Client Partner;
  • Customer relationship management and other forms of marketing and analytics;
  • Fraud prevention, misuse of company IT systems, or money laundering;
  • Physical, IT, and network perimeter security;
  • Internal investigations; and
  • Intended mergers and acquisitions.
• Compliance with legal obligations and/or defense against legal claims, including those in the areas of data protection, tax, and corporate compliance laws.
• Protection of the vital interests of any individual;
• Performance of a task carried out in the public interest or in the exercise of official authority vested in us; and
• Consent, as permitted by applicable law.

Authorized Service Providers. Curinos uses other companies and individuals to perform certain functions on its behalf. Curinos may disclose certain Personal Information to these companies and other individuals performing services in the United States or other locations where it conducts business.

Sale of the Businesses. If Curinos sells all or part of its business, Personal Information may be transferred to the purchaser in connection with that transaction. Curinos will use reasonable efforts to include contractual provisions that require the purchaser to treat your Personal Information consistently with the terms of this Privacy Notice.

Other Disclosures. Curinos may otherwise disclose Personal Information as permitted or required by law, when Curinos believes in good faith it is necessary for safety purposes, required for legal reporting, or to protect its legal rights or enforce this Site’s terms and conditions or any applicable rules, or to protect the rights of others. Curinos may disclose Personal Information to its auditors, legal advisors, or to respond to a subpoena. Curinos may also aggregate information that we gather about you (e.g., traffic patterns) and provide these statistics to others in aggregate form.

You should expect that the recipients identified above are located inside or outside the European Economic Area (“EEA”), or the United Kingdom. Recipients outside the EEA might be located in countries that do not offer an adequate level of protection from an EEA data protection law perspective.  Curinos will take all necessary measures to ensure that transfers out of the EEA or UK are adequately protected as required by applicable data protection law. With respect to transfers to countries not providing an adequate level of data protection, Curinos may base the transfer on appropriate safeguards, such as the EU’s or the UK’s standard contractual clauses, Data Privacy Framework, approved codes of conduct together with binding and enforceable commitments on the recipient, or approved certification mechanisms together with binding and enforceable commitments on the recipient. You can request a copy of the appropriate safeguards by contacting Curinos as set out below.

Any access to your Personal Information is restricted to those individuals who have a need to receive or access this data in order to fulfill their job responsibilities. Curinos may also disclose your Personal Information as required or permitted by applicable law to governmental authorities, courts, external advisors, and similar third parties.

7. Your Rights Concerning Your Personal Information

Certain jurisdictions maintain local data protection regulations that confer specific data protection rights on individuals. Curinos will address those rights as required by applicable laws. If you wish to exercise any of these rights, please contact Curinos as specified below. If you have declared your consent regarding certain types of processing activities, you can withdraw this consent at any time with future effect. This withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.  To the extent you’ve provided your consent and wish to withdraw it, you can contact Curinos as stated below.

Pursuant to applicable data protection law you may also have the right to: (1) request access to Personal Information; (2) request rectification of your Personal Information; (3) request erasure of your Personal Information; (4) request restriction of processing of your Personal Information; (5) request data portability of your Personal Information; and/or (6) object to the processing of your Personal Information. Please note that these rights might be limited under the applicable national or local data protection law.

1. Right of access: You may have the right to obtain from Curinos confirmation as to whether Personal Information concerning you is processed, and, to request access to the Personal Information. The access to information includes, among other things, the purposes of the processing of Personal Information, the categories of Personal Information concerned, and the recipients or categories of recipients to whom the Personal Information have been or will be disclosed. This is not, however, an absolute right, and the interests of other individuals may restrict your right of access.
2. Right to rectification: You may have the right to obtain from Curinos the rectification of inaccurate Personal Information about you. Depending on the purposes of the processing, you may have the right to have incomplete Personal Information completed, including by means of providing a supplementary statement.
3. Right to erasure: Under certain circumstances, you may have the right to obtain from Curinos the erasure of Personal Information concerning you, and Curinos may be obligated to erase that Personal Information, as long as it is not required for legal or regulatory purposes.
4. Right to restriction of processing: Under certain circumstances, you may have the right to obtain from Curinos restrictions on processing of your Personal Information. In that case, your data will be marked and may only be processed for certain limited purposes. As Curinos processes and uses your Personal Information primarily for purposes of carrying out the contract for services and in furtherance of our business relationship, Curinos has a legitimate interest for the processing which may override your restriction request, unless the restriction request relates to marketing activities.
5. Right to data portability: Under certain circumstances, you may have the right to receive the Personal Information about you, which you have provided to Curinos, in a structured, commonly used and machine-readable format, and you may have the right to transmit that data to another entity without hindrance from Curinos.
6. Right to object: Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Information by Curinos, and Curinos can be required to cease future processing of your Personal Information.

You also have the right to lodge a complaint with a competent data protection supervisory authority. To exercise your rights, please contact us as set out below.

8. Cookies and Other Tracking Technologies

In accordance with applicable law, Curinos uses and allows third parties to use essential and non-essential cookies, online tracking tools, web beacons, and similar technologies (collectively, “cookies”) on our Site. Curinos processes this information to help its Site function correctly, and better understand the needs of its customers.

Cookies on this Site generally fall into the following categories:

• Strictly Necessary Cookies: These are required for the operation of the Site. They include, for example, cookies that enable you to log into secure areas. These cookies are session cookies which are erased when you close your browser.
• Analytical/Performance Cookies: These allow Curinos to recognize and count the number of users of its Site and see how those users navigate through the Site. This helps to improve how the Site works, for example, by ensuring that users can find what they are looking for easily. These cookies are session cookies which are erased when you close your browser.
• Functional Cookies: These improve the functional performance of the Site and make it easier for you to use. For example, cookies are used to remember that you have previously visited the Site and asked to remain logged into it. These cookies are session cookies which are erased when you close your browser.

Controlling Tracking Tools. Your browser may give you the ability to control cookies. How you do so, however, depends on your browser and the type of cookie. Certain browsers or browser plugins can be set to reject all browser cookies. If you configure your computer to block all cookies, you may disrupt certain web page features, and limit the functionality Curinos can provide when you visit or use its Site. (e.g., Curinos will not be able to provide you with searches that you have asked us to save). You can change your cookie settings at any time.

Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These browser features are still not uniform, so Curinos is not currently set up to respond to those signals.

Data protection laws in your jurisdiction may treat cookie use differently or provide you an additional right to opt-out of such cookie use. If you are a visitor to this Site, and have any concerns about collection, or use of cookie information, contact us directly.

9. Security

Curinos implements a variety of technical, physical, and administrative security measures to secure the confidentiality of your Personal Information and to protect it from loss, misuse, alteration, and destruction.  Those measures include a variety of practices to keep Personal Information safe and prevent unauthorized access to, or use, or disclosure of it. Electronic data and databases are stored on secure computer systems with control over access to information using both physical and electronic means. Curinos personnel receive data protection training and there is a set of detailed security and data protection policies which personnel are required to follow when handling Personal Information.  But the safety and security of your information also depends on you.  And while Curinos strives to protect your Personal Information, it cannot guarantee or warrant the security of any information you transmit to it, or to or from our Services.  You transmit all such information at your own risk. Curinos is not responsible for circumvention of any privacy settings or security measures contained on the Site.

10. Data Retention

Depending on the product or service, Curinos will retain your Personal Information only for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by a law that applies to it.

11. How Curinos protects international transfers of Personal Information?

Curinos is based in the United States, but has operations and servers located in the United Kingdom, Canada, Australia, and other jurisdictions. If you are located in a jurisdiction that does not consider these countries to provide an adequate level of protection as does your home country, cross-border transfer of your information is necessary for the conclusion or performance of a transaction that you requested, and for the establishment, exercise, and defense of legal claims. To the extent permitted by local law, your use of this Site or provision of any Personal Information constitutes ̶ where legally permitted ̶ your consent to the cross-border transfer of Personal Information and other activities identified in this Privacy Notice.

12. Minors

This Site is not intended or directed to individuals under the age of 16, and Curinos does not knowingly collect any Personal Information from minors, or knowingly track the use of this Site by children. If you believe Curinos has impermissibly collected Personal Information from someone under the age of 16, please contact it directly.

13. How to update your Personal Information, file a complaint, ask questions, or send us comments about this Privacy Notice

If you have any questions or concerns about this Privacy Notice or wish to correct or update your Personal Information, or alert us about a concern, or unsubscribe from any updates you have requested, write to Curinos at privacy_support@curinos.com.

While Curinos will accept and review your inquiry, it can only process requests in situations where it has your Personal Information, since other pseudonymized data cannot be reversed by Curinos.  In these cases, Curinos suggests you refer to:

• Your financial institution to exercise your rights.
• For data sourced by Third Party Data Providers Curinos works with, you may also exercise your rights by contacting:
  • Acxiom (Third Party Data Provider): https://www.acxiom.com/optout/
  • Direct Mail Association Global Opt-Out: https://www.dmachoice.org/register.php.

14. Changes or Updates to this Privacy Notice

Curinos may amend this Privacy Notice at any time. If Curinos makes any material change in how it collects, uses, discloses, or otherwise processes Personal Information, it will post an updated Privacy Notice on this Site. Any changes to this Privacy Notice will be effective immediately upon posting of the updated Privacy Notice or as otherwise required by applicable law.

   15. Contact Information

If you have any questions or comments about this Privacy Notice, the ways in which Curinos collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under state privacy laws, please contact:

Curinos, Inc.
485 Lexington Avenue

20th Floor

New York, NY 10017
Email: privacy_support@curinos.com

16. US Privacy Addendum

If you reside in the United States, this U.S. Privacy Addendum supplements the information above for California and certain other U.S. states.