PRIVACY POLICY

Effective Date: January 1, 2024

Verbose Marketing, LLC (“we,” “us,” or “our”) is committed to protecting the privacy and security of our clients and their customer data. This Privacy Policy explains how we handle client data and any customer data we may interact with while providing lifecycle marketing services.

Although this Privacy Policy is being formally published in February 2025, we have been operating under these best practices since January 1, 2024.

1. Scope of this Policy

This Privacy Policy applies to our handling of client data and any customer data we may access while performing lifecycle marketing services. It does not apply to data collection, usage, or storage practices of our clients or third-party service providers they use.

2. Our Approach to Data Handling

We prioritize data security and privacy by operating within our clients’ existing tools, platforms, and structures. Our standard practices include:

No Local Data Storage: We do not download, store, or retain any client or customer data on our own systems, devices, or servers.
Platform-Based Access: We access and work within our clients’ marketing platforms, customer relationship management (CRM) systems, email service providers (ESPs), and analytics tools as authorized users.
Minimal Data Interaction: We only interact with client or customer data as necessary to provide lifecycle marketing services, such as segmentation, campaign execution, reporting, and optimization.
Data Confidentiality: Any data we access remains confidential and is not shared, copied, or transferred outside of the client’s designated platforms.

3. Client Responsibilities

As data controllers, our clients remain responsible for:

Obtaining all necessary consents and permissions from their customers for data collection and usage.
Ensuring compliance with applicable privacy laws and regulations, including but not limited to GDPR, CCPA, and CAN-SPAM.
Managing and maintaining the security of their own platforms, tools, and access credentials.

4. Third-Party Tools and Integrations

In cases where we recommend third-party tools, platforms, or integrations to improve marketing performance, clients are responsible for reviewing and agreeing to the privacy policies of those services. We do not assume liability for data handling practices of third-party providers.

5. Data Security Measures

To maintain data security, we follow these best practices:

Limited Access: Our team only accesses client data on a need-to-know basis and within the scope of assigned work.
Secure Connections: We use secure, password-protected logins and, where applicable, multi-factor authentication (MFA) to access client platforms.
No Data Sharing: We do not sell, share, or transfer client or customer data to any third party outside of our agreed-upon services.

6. Confidentiality and Non-Disclosure

We uphold strict confidentiality regarding client information and customer data. Any proprietary information, marketing strategies, or business insights shared with us remain confidential and will not be disclosed to unauthorized parties.

7. Compliance with Privacy Laws

We work in good faith to align with applicable data privacy laws and best practices, including:

General Data Protection Regulation (GDPR) for clients handling EU-based customer data.
California Consumer Privacy Act (CCPA) for businesses with California-based customers.
Controlling the Assault of Non-Solicited Pornography and Marketing Act (CAN-SPAM) for email marketing compliance.

Clients are responsible for ensuring their marketing activities comply with relevant regulations.

8. Updates to This Policy

This Privacy Policy may be updated periodically to reflect changes in our practices or legal requirements. Clients will be notified of significant changes.

9. Contact Information

For any questions or concerns about this Privacy Policy, please contact:

Verbose Marketing, LLC
14716 26th Avenue Northeast

Shoreline, WA 98155