Data Anonymization and Pseudonymization Policy

Last Updated on July 5, 2026

Welcome to Marketeq Digital Inc. (hereinafter referred to as "Marketeq," "we," "us," or "our"). This Data Anonymization and Pseudonymization Policy (the "Policy") describes how Marketeq applies anonymization and pseudonymization techniques to reduce the privacy risks associated with the processing of personal data. These techniques are important tools for protecting individuals while enabling legitimate uses of data. This Policy supplements our Privacy Policy, Data Encryption and Security Policy, and GDPR Compliance and Data Protection Statement and should be read together with them. If you have any questions about this Policy, you may contact us at legal@marketeqdigital.com.

1. Purpose and Scope

The purpose of this Policy is to explain how and when Marketeq uses anonymization and pseudonymization to protect personal data. This Policy applies to processing activities in which such techniques are employed to reduce the identifiability of individuals. Anonymization and pseudonymization support our commitment to data minimization and to protecting individuals against the risks associated with the processing of their data. This Policy reflects our approach to applying these techniques appropriately and effectively. It should be understood alongside our broader data protection practices.

2. Definitions

For the purposes of this Policy, "Anonymization" means the process of transforming personal data in such a way that individuals can no longer be identified, directly or indirectly, taking into account all reasonable means likely to be used. "Pseudonymization" means the processing of personal data in such a way that it can no longer be attributed to a specific individual without the use of additional information, which is kept separately and subject to safeguards. Anonymized data, when properly achieved, falls outside the scope of data protection law, whereas pseudonymized data remains personal data. These definitions guide how we apply and treat each technique. Understanding this distinction is important to the correct application of this Policy.

3. Use of Anonymization

Marketeq uses anonymization where it wishes to derive value from data, such as for analytics, research, or reporting, without processing identifiable personal data. When we anonymize data, we apply techniques designed to prevent re-identification, taking into account the means reasonably likely to be used to identify individuals. We assess the effectiveness of anonymization in light of the nature of the data and the context of its use. Where data has been effectively anonymized, it is no longer treated as personal data. We recognize that anonymization must be robust to be effective and apply it with appropriate rigor.

4. Use of Pseudonymization

Marketeq uses pseudonymization as a safeguard to reduce the risks associated with processing personal data while retaining the ability to re-identify individuals where necessary and permitted. When we pseudonymize data, we separate the additional information needed for re-identification and protect it with appropriate technical and organizational measures. Pseudonymization may be applied to support security, minimize exposure, and limit the impact of a potential data breach. Because pseudonymized data remains personal data, it continues to be subject to applicable data protection requirements. We treat the information enabling re-identification as sensitive and protect it accordingly.

5. Safeguards and Controls

Marketeq applies appropriate safeguards to support the effectiveness of anonymization and pseudonymization. For pseudonymized data, we implement controls to keep re-identification information separate and to restrict access to it. We consider the risk of re-identification when determining which technique to apply and how to implement it. We periodically review our techniques to ensure they remain effective against evolving methods of re-identification. These safeguards are designed to preserve the protective value of anonymization and pseudonymization over time. Our controls reflect the importance of maintaining the integrity of these techniques.

6. Use of Anonymized and Pseudonymized Data

Anonymized data may be used by Marketeq for purposes such as analytics, service improvement, benchmarking, and reporting, without the restrictions that apply to personal data. Pseudonymized data may be used to support processing activities where reducing identifiability is beneficial while retaining the ability to re-associate data where necessary. We use these forms of data in a manner consistent with the purposes for which they were created. We do not attempt to re-identify anonymized data, and we re-identify pseudonymized data only where there is a legitimate purpose and a valid legal basis. Our use of such data reflects the protective intent behind these techniques.

7. Limitations

Marketeq recognizes that anonymization and pseudonymization have limitations and that no technique can guarantee absolute protection against re-identification in all circumstances. The effectiveness of anonymization depends on the nature of the data, the techniques applied, and the context of use. We assess these factors and apply techniques proportionate to the risks involved. Where residual risk of re-identification exists, we treat the data with appropriate caution. We remain attentive to developments that may affect the effectiveness of these techniques.

8. Changes to This Policy

Marketeq reserves the right to modify or update this Data Anonymization and Pseudonymization Policy at any time to reflect changes in our practices or legal requirements. Any changes will become effective upon posting the revised Policy, and we encourage you to review it periodically. Where changes are material, we will endeavor to provide additional notice through appropriate means.

9. Contact Information

If you have any questions, concerns, or requests regarding this Data Anonymization and Pseudonymization Policy, please contact us at legal@marketeqdigital.com. We are committed to applying these techniques responsibly and to addressing your inquiries promptly and transparently.