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Privacy Policy

Effective Date: August 4, 2022

This is the Privacy Policy for Movable, Inc. (“Movable Ink”) and its affiliates. It covers our handling of two categories of information:

  1. Personal data we handle for our customers (“Service Data”). We collect this data through our Movable Ink platform, our Moments, Stories, Da Vinci and Builder services, additional Movable Ink products, and related training, support, consulting and professional services. We refer to all of these offerings as the “Services.” Under applicable law, Movable Ink is considered a “processor” of this data, and our customer (or our customer’s customer) is the “controller” of the data

  2. Personal data we handle for our own business (“Business Data”), other than for our own human resources activities. This includes certain data collected on our own website, such as newsletter signup forms, as well as data collected through other marketing-related efforts. Under applicable law, Movable Ink is a “controller” of this data.

This Privacy Policy has details specific to Service Data, details specific to Business Data, and information relevant to our handling of both kinds of data.

1. Privacy Practices Specific to Service Data

Types of Service Data. We receive limited information from or on behalf of our customers when they use the Services. This information may include:

  • Unique User ID (which may be an email address, though this is not required);

  • IP address;

  • User-agent from the HTTP header of a request for an image in an email;

  • Details about the user’s interaction with an ad, email or other communication that contains our technology;

  • Cookie identifiers;

  • Website or app behavior, including URLs associated with a consumer’s navigation of our client’s website or app, or with the user’s interaction with our client’s ad on a third-party site or app;

  • Images and other content;

  • Data described in the Cookies and Automated Data Collection section below; and

  • Any other data that our clients choose to transmit to us (or have us collect on their behalf) to provide the Services. Depending on the service, this may include:

    • Transaction history (e.g., goods or services purchased from the client, date, price, sales channel);

    • Customer-level segmentation information (e.g., category affinity scores, gender)

Uses of Service Data. Subject to our contractual obligations, and depending on the particular Services, we use the information described above as follows:

  • To provide the Services, including to:

    • allow clients to customize, personalize, optimize, target and automate marketing and other communications campaigns through various channels, including display ads, email, websites or apps, as applicable (for example, in the context of providing service to a shoe brand, we may do this by creating interest-based categories for that brand based on your interactions with that brand, such as an interest in particular kinds of women’s shoes, and we may use cookies and similar technologies to “remember” you in order to help tailor more relevant ads and communications to you for that brand);

    • provide data and feedback to our clients in connection with the provision of our Services;

    • facilitate and improve the Services, which may include analyzing usage trends, tracking the types of questions we receive and providing support to our clients and visitors to our websites;

  • To enforce the legal terms that govern the Services;

  • To comply with law and protect rights, safety and property; and

  • For other purposes requested or permitted by our customers or users.

Disclosures of Service Data. Subject to our contractual obligations, and depending on the particular Services, we share the information described above as follows:

  • To provide the Services;

  • To enforce the legal terms that govern the Services and our business;

  • To comply with law, and where we deem disclosure appropriate to protect rights, safety and property (for example, for national security or law enforcement);

  • As part of a business sale, merger, consolidation, change in control, transfer of substantial assets or reorganization; or

  • For other purposes requested or permitted by our customers or users.

  • For those purposes, we may share information with our affiliates and other entities that help us with any of the above.

Personal Data Rights and Choices. To exercise any rights you may have under privacy laws relating to Service Data, you should contact the Movable Ink customer on whose behalf we process the Service Data. If instead you contact us and identify the relevant customer, we may refer the request to the relevant customer and cooperate with their handling of the request, subject to any special contractual arrangement with that customer.

2. Privacy Practices Specific to Business Data

  • Types of Business Data We collect:

    • Contact details and professional details, e.g., name, email address, phone number, title, and name of company;

    • Information about customers’ experience with our Services;

    • Information about actual or prospective customer personnel’s other interactions with Movable Ink;

    • Information about actual or prospective users’ interests; and

    • Payment information for Movable products and services.

    • We also collect Business Data through cookies and other automated data collection tools described in Section 3.

We obtain Business Data directly from the relevant individuals, and also from third-party sources, such as their employers, marketing or lead generation companies, data brokers, and social networking platforms (e.g., LinkedIn).

  • Uses and Disclosures of Business Data. Movable Ink uses and discloses Business Data as follows:

    • To manage our customer relationships and deliver our services;

    • To send you information about our products and services, including marketing communications;

    • To respond to your questions, concerns, or customer service inquiries;

    • To analyze market conditions and use of our services;

    • To customize the content and advertising you see on our website, across the Internet, and elsewhere;

    • To enforce the legal terms that govern our business and online properties;

    • To comply with law and protect rights, safety and property (for example, making disclosures that we believe are required or otherwise appropriate for national security or law enforcement);

    • As part of an actual or potential business sale, merger, consolidation, change in control, transfer of substantial assets or reorganization; and

    • For other purposes requested or permitted by our customers or users.

    • For those purposes, we may share information with our affiliates and other entities that help us with any of the above.

  • Legal Basis for Processing Business Data. The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds for processing Business Data are as follows:

    • Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:

      • Customer service

      • Marketing

      • Protecting our customers, personnel and property

      • Analyzing and improving our business

      • Managing legal issues

    • We may also process personal data for the same legitimate interests of our customers and business partners.

    • Consent: Where required by law, and in some other cases, we handle personal data on the basis of consent.

    • To honor our contractual commitments to you: Some of our processing of personal data is to meet our contractual obligations to our customers, or to take steps at customers’ request in anticipation of entering into a contract with them.

    • Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.

    • We process Service Data pursuant to our contracts with our customers and applicable law.

  • Personal Data Rights and Choices (including Direct Marketing Opt-Out). You may be able to review and update certain user information in our Business Data by logging in to the relevant portions of the Movable Ink website. You can unsubscribe from Movable Ink’s own marketing emails by clicking the "unsubscribe" link they contain. Controls related to third-party cookies and other automated data collection are described in the Cookies and Automated Data Collection section below.
    Residents of the European Economic Area, United Kingdom, Switzerland and certain other and many other jurisdictions have certain legal rights (including, in certain cases, under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks) to obtain confirmation of whether we hold personal data about them as part of our Business Data, to access any such personal data we hold about them, and to obtain its correction, update, amendment, or deletion in appropriate circumstances. In limited cases, they have the right to receive information we hold about them in portable form and to have it transmitted to a third party.
    They also have rights to object to our handling of their personal data, to restrict its processing, and to withdraw any consent they have provided. For example, such individuals have a right to opt out of our processing of Business Data for direct marketing purposes.
    Many of the rights described here are subject to significant limitations and exceptions under the Privacy Shield Frameworks and applicable law. For example, objections to the processing of personal data, and withdrawals of consent, typically will not have retroactive effect.
    To exercise those rights for Business Data, they may contact us as described at the end of this Privacy Policy.
    For Service Data (which we process on behalf of our customer), you should contact the customer directly. If instead you contact us and identify the relevant customer, we may refer the request to the relevant customer and cooperate with their handling of the request, subject to any special contractual arrangement with that customer.

  • Additional detail for California residents.
    This subsection applies only to “personal information” about California residents, as that term is defined in the California Consumer Privacy Act (“CCPA”), and they supplement the information in the rest of our Privacy Policy. Data about individuals who are not residents of California is handled differently and is not subject to the same California rights described below. These subsections do not apply to Service Data, even when such data is about a resident of California.
    CCPA categories of California personal information we collect:
    Movable Ink collects all of the information described in Sections 2(a) and 3 of our Privacy Policy, from and about California residents. You should refer to those locations for more detail, but this information generally falls into the following CCPA categories, to the extent it is personally identifiable: identifiers (such as name, email address and other contact information); commercial information (such as information about an individual’s interests and interactions with Movable Ink, including transaction data); internet or other network or device activity, and other information described in Cookies and Automated Data Collection section of our Privacy Policy; professional or employment related data (such as title); other information that identifies or can be reasonably associated with you; and inferences drawn from any of the above.
    CCPA description of uses of California personal information:
    In CCPA terms, we and our service providers may use and disclose (and in the past 12 months have used and disclosed) all of the categories of California personal information that we collect for all of the purposes described in the Uses and Disclosures of Business Data section of our Privacy Policy. These purposes include but are not limited to activities that the CCPA describes as follows:

    • Auditing related to current interactions with you and concurrent transactions, including, but not limited to, counting ad impressions, and auditing compliance with the CCPA and other standards;

    • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity;

    • Debugging to identify and repair errors that impair existing intended functionality;
      Short-term, transient uses;

    • Performing or using services, including account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about our services, or providing or using similar services;

    • Undertaking internal research for technological development and demonstration;

    • Undertaking activities to verify or maintain the quality or safety of services, and to improve, upgrade, or enhance services;

    • Facilitating the operational purposes of Movable Ink or our service providers;

    • Other uses that advance our commercial or economic interests; and

    • Other uses that we notify you about.

The extent to which our service providers engage in the uses and disclosures described above varies from provider to provider.

California privacy rights

If you are a California resident, California law may permit you to request that we:

  • Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.

  • Provide access to and/or a copy of certain information we hold about you.

  • Delete certain information we have about you.

Certain information is exempt from such requests under applicable law. You also may have the right to receive information about the financial incentives that we offer to you (if any). You also have certain rights under the CCPA not to be subject to certain negative consequences for exercising CCPA rights. We do not respond to browser-based do-not-track signals or similar mechanisms.

To request to exercise those CCPA rights and receive the fastest response, please visit if you are an existing client or email us at Alternatively, you can make your CCPA request via voicemail at the following number: 1-800-270-6033. For security and legal reasons, Movable Ink will not accept requests that require us to access third-party websites or services.

CCPA “sale” of California personal information

The CCPA requires businesses that “sell” personal information, as the term “sell” is defined under the CCPA, to provide an opt-out from such sales. Some people have taken the position that when a website uses third parties’ cookies or similar technology for its own analytics or advertising purposes, the website is engaged in a “sale” under the CCPA if the third parties have some ability to use, disclose or retain the data to improve their service or to take steps beyond the most narrowly drawn bounds of merely providing their service to the website. Some take this position even when the website pays the third party (not vice versa), and merely provides the third party with an opportunity to collect data directly, instead of providing personal information to the third party. If you take the position that those relationships involve a “sale” within the meaning of the CCPA, then you may consider Movable Ink to have “sold” what the CCPA calls “identifiers” (like IP addresses), “internet or other electronic network activity information” (like information regarding an individual’s browsing interactions on, and “commercial information” (like the fact that a browser visited a page directed to people who are considering purchasing from us) to those sorts of companies. To limit those companies’ collection and/or use of this data, use the controls described in the Cookies and Automated Data Collection section of our Privacy Policy.

3 Additional Information About Our Privacy Practices (applicable to both Service Data and Business Data)

  • Security and Data Retention

    To provide security for Service Data, we maintain physical, organizational and technical safeguards, which are subject to periodic changes. We use different safeguards to help secure Business Data.

    We will hold your information for as long as necessary to fulfill the purposes set forth in this Privacy Policy or as long as we are legally required or permitted to do so. Information may persist in copies made for backup and business continuity purposes for additional time.

  • Cookies and Automated Data Collection

    In our websites, apps and emails, we and third parties may collect certain information by automated means such as cookies, Web beacons, JavaScript and mobile device functionality. This information may include unique browser identifiers, IP address, browser and operating system information, geolocation, other device information, Internet connection information, as well as details about individuals’ interactions with our apps, websites and emails (for example, the URL of the third-party website from which you came, the pages on our website that you visit, and the links you click on in our websites).

    We and third parties may use automated means to read or write information on users’ devices, such as in various types of cookies.

    Cookies are files that contain data, such as unique identifiers, that we or a third party may transfer to or read from a user’s device for the purposes described in this Privacy Policy, such as recognizing the device, service provision, record-keeping, analytics and marketing, depending on the context of collection.

    You may be able to set your web browser to refuse certain types of cookies, or to alert you when certain types of cookies are being sent. However, if you block or otherwise reject certain cookies, JavaScript or other technologies, certain websites (including our own websites) may not function properly.

    These technologies help us (a) keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you; (b) remember your settings on the pages you visit, so that we can display your preferred content the next time you visit; (c) display personalize content; (d) perform analytics, and measure traffic and usage trends, and better understand the demographics of our users; (e) diagnose and fix technology problems; and (f) otherwise plan for and enhance our business.

    Also, in some cases (not when providing our Services), we arrange for the collection of information by advertising services administered by third parties. The ad services may track users’ online activities over time by collecting information through automated means such as cookies, and they may use this information to show users ads that are tailored to their individual interests or characteristics and/or based on prior visits to certain sites or apps, or other information we or they know, infer or have collected from the users. For example, we and these providers may use different types of cookies, other automated technology, and data (a) to recognize users and their devices; (b) to inform, optimize, and serve ads; and (c) to report on our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services (including how they are related to visits to specific sites or apps).

    To learn more about interest-based advertising generally, including how to opt out from the targeting of interest-based ads by some of our current ad service partners, visit from each of your browsers and devices. You can opt out of Google Analytics and customize the Google Display Network ads by visiting the Google Ads Settings page. Google also allows you to install a Google Analytics Opt-out Browser Add-on for your browser. If you replace, change or upgrade your browser, or delete your cookies, you may need to use these opt-out tools again. We do not respond to browser-based do-not-track signals.

    Please visit your mobile device manufacturer's website (or the website for its operating system) for instructions on any additional privacy controls in your mobile operating system, such as privacy settings for device identifiers and geolocation.

  • International Data Transfers

    We are based in the United States, and recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as the country in which you are located. Movable Ink complies with legal requirements for cross-border data protection, including through the use of European Commission-approved Standard Contractual Clauses.

    As a business subject to the investigatory and enforcement authority of the United States Federal Trade Commission, Movable Ink has certified that its U.S. operations adhere to the Privacy Shield with respect to the personal data that Movable Ink receives in reliance on the Privacy Shield. This includes the relevant personal data that we receive in the U.S. from the U.K., regardless of when or how Brexit happens. Our Privacy Shield certification is available at To learn more about the Privacy Shield program, please visit

    We acknowledge that the Court of Justice of the European Union ruled in 2020 that a certification under the EU-U.S. Privacy Shield Framework no longer can serve as the basis by which entities subject to the GDPR transfer Personal Data to the United States, and the Federal Data Protection and Information Commissioner later reached a similar view regarding data subject to Swiss law. As affected customers who relied only on our Privacy Shield certification transition to Standard Contractual Clauses and other safeguards, we continue to honor our legal obligation to comply with the Privacy Shield.

    When Movable Ink receives personal data under the Privacy Shield and then transfers it to a third-party service provider acting as an agent on Movable Ink’s behalf, Movable Ink may have certain responsibility under the Privacy Shield if both (a) the agent processes the information in a manner inconsistent with the Privacy Shield and (b) Movable Ink is responsible for the event giving rise to the damage.

    Covered European residents should direct any questions, concerns or complaints regarding Movable Ink’s compliance with the Privacy Shield to Movable Ink as described at the bottom of this Privacy Policy. Movable Ink will attempt to answer your questions and satisfy your concerns in a timely and complete manner as soon as possible. If, after discussing the matter with Movable Ink, your issue or complaint is not resolved, Movable Ink has agreed to participate in the Privacy Shield independent dispute resolution mechanism operated by JAMS, free of charge to you. You can file a complaint with JAMS here: Please contact Movable Ink first. Every individual also has a right to lodge a complaint with the relevant supervisory authority, regardless of whether Privacy Shield applies.

    If after following all of the steps above, your complaint still is not resolved, under limited circumstances, an additional binding arbitration option may be available before a Privacy Shield panel, as described at

    Please note that Movable Ink’s customers may transfer personal data to Movable Ink on the basis of other legal mechanisms approved by the European Commission and other relevant authorities for cross-border data transfers, such as Standard Contractual Clauses. To exercise any legal right to see copies of the data transfer mechanism documents that Movable Ink uses to transfer data to third parties, please contact us.

  • Notification of Changes

    Movable Ink may change this Privacy Policy to reflect changes in the law, our data handling practices or the features of our business. The updated Privacy Policy will be posted on

  • Contact Information

    If you have questions regarding our practices or this Privacy Policy, or to send us requests or complaints relating to personal data, please contact us:

    Movable, Inc.
    Attention: Legal Department
    5 Bryant Park, 9th Floor
    New York, NY, 10018


    Movable, Inc.
    48 Warwick Street, 2nd Floor
    London, W1B 5AW, United Kingdom
    Attention: Legal Department

    To submit a Data Subject Rights Request in relation to our Business Data, please email For requests relating to Service Data (personal data that we process on behalf of our customers), please contact that customer directly.