Draft — pending legal review
Edisense privacy notice
This notice explains how Edisense (part of the Edisource family of products) processes personal information when we help publishers deliver personalized campaign content and related communications. It is a platform / processor notice — not a substitute for the publisher's own privacy policy, which governs their relationship with you as controller.
1. Who we are
Publishers use Edisense to run lead-generation and content campaigns. In that relationship, the publisher (and, where applicable, their advertiser partners) typically act as the controller of your personal data. Edisense acts as a service provider / processor: we process data on the publisher's instructions to deliver campaigns, host content, measure engagement where permitted, and honor preference / opt-out requests.
For questions about this notice, contact: privacy@edisense.com (placeholder address — confirm with counsel).
2. Categories of personal data
Depending on the campaign, we may process:
- Identity & contact data — for example name, email address, and other fields the publisher provides about you as a lead.
- Campaign & content context — campaign or segment identifiers, content you were sent or viewed, and related delivery metadata.
- Engagement / behavioral signals — limited interaction events on Edisense-hosted or embedded surfaces (for example opens, clicks, page or document engagement) when tracking is allowed under applicable consent rules.
- Technical data — IP address, user agent, device / browser type, approximate location derived from IP, timestamps, and security / fraud-prevention logs.
- Preference & suppression records — your marketing opt-out choices (campaign- or publisher-scoped), source, and timestamps so we can stop further marketing delivery.
We do not require you to create an Edisense account to receive or view campaign content.
3. Purposes of processing
We process personal data to:
- Deliver personalized campaign content and related emails or messages on behalf of the publisher.
- Host secure, tokenized access to content (for example a lead viewer or preference page).
- Measure campaign performance and content engagement for the publisher where measurement is permitted.
- Honor unsubscribe / preference requests and maintain suppression lists so opted-out leads are not re-messaged.
- Operate, secure, and troubleshoot the platform (including abuse prevention, delivery integrity, and auditability).
- Comply with legal obligations and respond to valid data-subject or regulator requests in coordination with the publisher.
4. Legal bases
Where GDPR / UK GDPR (or similar laws) apply, processing is typically based on one or more of the following, as determined with the publisher for each use case:
- Legitimate interests — operating the delivery and measurement platform, securing services, and providing reporting the publisher needs to run campaigns — balanced against your rights.
- Consent — where required for certain tracking or communications (for example non-essential measurement cookies or pixels on a site that uses a consent management platform).
- Contract / publisher instructions — processing necessary to perform services the publisher has engaged us to provide in connection with a campaign involving you.
- Legal obligation — where we must retain or disclose information to meet applicable law.
The publisher's privacy policy describes the bases that apply to their use of your data. This notice covers Edisense's role as processor / service provider.
5. Sharing
We may share personal data with:
- The publisher (and, under their direction, advertiser or agency partners) that runs the campaign — including engagement reporting and signed opt-out notifications.
- Infrastructure and subprocessors that help us host, deliver, or secure the service (for example cloud hosting, email delivery, and authentication providers), under appropriate contractual safeguards.
- Authorities when required by law or to protect rights, safety, and the integrity of the service.
We do not sell your personal information. We do not use lead data from one publisher to market unrelated products of another publisher outside the publisher's instructions.
6. International transfers
Edisense is operated using cloud infrastructure that may process data in the United States and other countries. Where required, we use appropriate transfer mechanisms (such as Standard Contractual Clauses) and contractual terms with publishers and subprocessors. Details for a specific engagement are set out in the publisher's agreement with Edisense / Edisource.
7. Retention
- Lead and campaign records — retained for the duration needed to deliver the campaign and provide publisher reporting, then according to the publisher agreement and our deletion / archival schedules.
- Engagement / event data — may be retained for a shorter operational window than lead records; exact TTLs are configured per environment and product policy.
- Marketing suppressions / opt-outs — retained longer than ordinary engagement events so we can continue to honor your choice and avoid re-contacting you.
Opting out of marketing is not the same as deleting your data. A suppression stops further marketing delivery; it does not erase historical records. To request access or erasure, use the rights process below (typically via the publisher as controller).
8. Your rights & choices
- Marketing preferences — use the unsubscribe / preference link in campaign emails (or the preference page you were sent to) to opt out of a campaign or a publisher's Edisense-powered marketing.
- Tracking / cookies on publisher sites — managed through the publisher's consent banner (for example Didomi / TCF). Declining measurement cookies does not by itself unsubscribe you from email.
- Access, correction, erasure, restriction, portability, objection — depending on your location, you may have these rights. Because the publisher is usually the controller, please contact the publisher first using the contact details in their privacy policy. You may also email privacy@edisense.com and we will coordinate with the relevant publisher where appropriate.
- Complaint — you may lodge a complaint with your local data protection authority.
9. Security
We apply administrative, technical, and organizational measures appropriate to the nature of the data we process — including access controls, encryption in transit, and encryption of sensitive lead fields at rest where designed into the platform. No method of transmission or storage is completely secure; we work continuously to improve protections.
10. Children
Edisense campaigns are directed at business / professional audiences and are not intended for children. We do not knowingly process children's data for marketing campaigns. If you believe we have received such data, contact us and we will work with the publisher to address it.
11. Changes
We may update this notice from time to time. The "Last updated" date at the top will change when we do. Material changes affecting lead-facing processing will be reflected here; publishers remain responsible for updating their own policies.
12. Relationship to publisher policies
When you interact with content or emails for a specific publisher, also review that publisher's privacy policy (linked from the preference page, email footer, and/or hosted viewer). That policy controls how the publisher uses your data as controller. This Edisense notice only describes our platform processing.
This page is a working draft for product and engineering use pending counsel sign-off. It is not final legal advice and should not be relied on as the definitive privacy statement until approved.