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Safe Harbor Privacy Policy.

This Safe Harbor Privacy Policy Statement (the “Policy”) sets forth the privacy principles eMarketer follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and Switzerland to the United States.


The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA or Switzerland to the United States (the "U.S.-EU or Switzerland Safe Harbor"). eMarketer adheres to the principles set forth in the U.S.-EU Safe Harbor framework and the U.S.-Swiss Safe Harbor framework (the “Safe Harbor Principles”), and certifies its adherence to the Safe Harbor Principles. For more information about the U.S.-EU or Swiss Safe Harbor, please visit the Safe Harbor website (available at http://export.gov/safeharbor/).


This Safe Harbor Privacy Policy Statement (the “Policy”) applies to all personal information received by eMarketer in the United States from the EEA or Switzerland in any format.


For purposes of this Policy, the following definitions shall apply:

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, eMarketer or to which eMarketer discloses personal information for use on eMarketer's behalf.

“eMarketer” means eMarketer, Inc., its successors, subsidiaries, divisions and groups in the United States.

“Personal information” means any information or set of information that identifies or could be used by or on behalf of eMarketer to identify an individual. Personal information does not include information that is anonymized, or publicly available information that has not been combined with non-public personal information.

“Sensitive personal information” means personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information concerning the sex life of the individual. In addition, eMarketer will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.


The privacy principles in this Policy have been developed based on the Safe Harbor Principles.

NOTICE: Where eMarketer collects personal information directly from individuals in the EEA or Switzerland, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which eMarketer discloses that information, the choices and means, if any, eMarketer offers individuals for limiting the use and disclosure of personal information about them, and how to contact eMarketer. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to eMarketer, or as soon as practicable thereafter, and in any event before eMarketer uses or discloses the information for a purpose other than that for which it was originally collected. Where eMarketer receives personal information from its subsidiaries, affiliates or other entities in the EEA or Switzerland, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: eMarketer will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, eMarketer will give individuals the opportunity to affirmatively and/or explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. eMarketer will provide individuals with reasonable and affordable mechanisms to exercise their choices.

DATA INTEGRITY: eMarketer will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. eMarketer will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS: eMarketer will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding. Where eMarketer has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, eMarketer will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Except where the burden or expense of providing access would be disproportionate to the risks to an individual’s privacy, or where the rights of any persons would be violated, eMarketer will grant individuals reasonable access to personal information that it holds about them and will take reasonable steps to permit such individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY: eMarketer will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT: eMarketer will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that eMarketer determines is in violation of this policy will be subject to appropriate disciplinary action.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to eMarketer at the address given below. eMarketer will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between eMarketer and the complainant, eMarketer has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:

  1. For disputes involving employment-related personal information received by eMarketer from the EEA, eMarketer has agreed to cooperate with the data protection authorities in the EEA or to participate in the dispute resolution procedures of the panel established by the European data protection authorities, as appropriate consistent with the Safe Harbor Principles;
  2. For disputes involving all other personal information received by eMarketer from the EEA or Switzerland, eMarketer has agreed to an independent dispute resolution mechanism, TRUSTe. Please click here for fax and postal mail information. TRUSTe's Dispute Resolution process is only available in English.


Adherence by eMarketer to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent permitted by the Safe Harbor Principles, precedent or FAQs of the United States Federal Trade Commission or U.S. Department of Commerce, or any other applicable law, rule or regulation.


eMarketer has created a specific online Privacy Policy (the "OPP") governing the treatment of personal information collected through eMarketer’s online service. With respect to personal information that is transferred from the European Economic Area or Switzerland to the U.S., the OPP is subordinate to this Policy. eMarketer's Privacy Policy for its online service can be found at http://www.emarketer.com/about/Privacy.aspx


Questions or comments regarding this Policy should be submitted to eMarketer by mail to:

eMarketer, Inc.

11 Times Square

New York, NY 10036

Attn: M. Grotell, Senior Director

We self-certify compliance with:


This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. Changes to this Policy will be effective upon posting to this website.

EFFECTIVE DATE: January 6, 2014