This Privacy Policy (“Privacy Policy”) describes (i) the information that relates to or could reasonably be associated with a natural person (“Consumer”) or household and is subject to applicable data protection laws (“Personal Information”) that Preferred Communications Data, LLC (“Preferred”), and its subsidiaries, affiliates and related companies (collectively, “Our,” “Preferred Entities,” “Us,” or “We”) collect when a person or entity accesses our websites and applications that post a link to this Privacy Policy (each a “Site”), and (ii) how We use and disclose this information. All of the different forms of data, content, and information described below are collectively referred to as “information.”
Participation in any Site, Content, and/or services provided by Us is completely voluntary; You are not required to provide any Personal Information identified in this Privacy Policy. Any person or entity which accesses Our Site, including without limitation any employee, representative, or agent of such entity (collectively “You” or “Your”) expressly consents to Our Privacy Policy and Terms of Use, and Our collection, use and disclosure of Your information in accordance with this Privacy Policy. Please be sure to review Our Site’s Terms of Use which, in addition to this Privacy Policy, govern Your use of Our Site. For a copy of Our Site’s Terms of Use, please click here. Capitalized terms that are used but not defined in this Privacy Policy have the meaning given them in Our Terms of Use.
Please note the distinction between Our Privacy Policy in connection with Your visit to Our Sites, and Our Content and services. Preferred is a data services company. Preferred Entities provide a variety of Content and services designed to help Our clients (“Licensed Users”) drive demand, increase sales and achieve operating efficiencies through direct mail, email, online and other marketing channels. As such, We primarily provide business-to-business services to Licensed Users and generally do not provide services directly to, or otherwise interact directly with, Consumers.
Except Personal Information you voluntarily provide to us when You access Our Site, We have no direct connection with any sources of your data. We may, however, collect Personal Information related to Consumers from third party sources as part of the Content and services provided to Our Licensed Users. The use of this information by Our Licensed Users is governed by Our contract with the applicable Licensed User and the Licensed User’s own privacy policies, not this Privacy Policy. We are not responsible for the privacy policies or practices of Our Licensed Users or other third parties.
Preferred Entities will use best efforts to honor requests received in accordance with our posted policies on our website, which policies are consistent with the provisions of California Consumer Privacy Act. Please note, however, that the Preferred Entities do not deal in “Personal Information,” as that term is defined in Cal. Civ. Code § 1798.99.140, relating to California consumers, nor do the Preferred Entities operate in jurisdictions subject to GDPR regulations
Please note, unless otherwise stated, this Privacy Policy does not apply to the following:
Residents of California and Nevada– please click here to learn more about Your privacy rights.
1. The Information We May Collect and Store
We may collect and store the following information:
Consumer Data. We may collect Information that may include name, email address, telephone number, occupation, employer, charitable or political contribution history, public information, and other information obtained from third parties. From the foregoing, We may identify issues, causes or purchasing activities that specific Consumers may be interested in.
User Data. When Licensed Users create an account or authorize a person affiliated with Licensed User to access Content on Licensed User’s behalf (a “User”), We may collect some Personal Information, such as the Licensed User’s name, the User’s name, phone numbers of Licensed User and/or User, billing information, email addresses and business postal addresses (collectively, “User Data”). We may also receive Personal Information through other Licensed Users. One example would be if a Licensed User referred You to Us.
Others’ Personal Information. If You provide Personal Information about someone else, You must ensure and hereby agree that You are authorized to disclose that information to Us and that, without Our taking any further steps required by applicable data protection or privacy laws, We may collect, use and disclose such information for the purposes described in this Privacy Policy. You must take reasonable steps to ensure that the individual or entity concerned is aware of and consents to the various matters detailed in this Privacy Policy, including the fact that that person’s or entity’s Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, Our identity, and how to contact Us.
Sensitive Personal Information. You are prohibited from uploading any Personal Information about Yourself or others that relates to health or medical conditions, Protected Health Information (as defined in 45 CFR 160.103), social security numbers or taxpayer identification numbers, driver’s license numbers, information concerning criminal charges or convictions, or racial or ethnic origin.
Log Data. When You access Our Site, We may automatically record information from the computer used to access Our Site, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device (a “Device”), its software, and Your activity while using Our Site. This may include the Device’s Internet Protocol (“IP”) address, browser type, the web page visited before You came to Our Site, information You select or search for on Our Site, locale preferences, identification numbers associated with Your Devices, Your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning Your files, and other interactions with Our Site or the Licensed Content contained on Our Site.
Cookies Data. We may also use “cookies” to collect information and improve Our services. A cookie is a small data file that We transfer to Your Device. We may use “persistent cookies” to save Your registration ID and login password for future logins to Our Site. We may use “session ID cookies” to enable certain features to better understand how You interact with Our Site and Licensed Content and to monitor aggregate usage and web traffic routing on Our Site. You can instruct Your browser, by changing its options, to stop accepting cookies or to prompt You before accepting a cookie from the websites You visit. If You do not accept cookies, however, You may not be able to use all aspects of Our Site.
2. How We Use Personal Information
Personal Information. Personal Information is or may be used: (i) to provide and improve Our Site, Content, and/or services, (ii) to administer Your use of Our Site, Content, and/or services (iii) to better understand Your needs and interests, (iv) to personalize and improve Your experience, (v) for marketing and advertising, and (vi) to provide or offer updates and product announcements. If You no longer wish to receive communications from us, please follow the “unsubscribe” instructions provided in any of those communications, or update Your account settings information.
Analytics. We may also collect some information (ourselves or using third party services) using logging and cookies, such as an IP address, which can sometimes be correlated with Personal Information. We use this information for the above purposes and to monitor and analyze use of Our Site and Services and Licensed Content, for the technical administration of Our Site and Services, to increase Our Site and Services’ functionality and user-friendliness, and to verify users have the authorization needed to access Our Site and Services and the Licensed Content. We may use third party services, including Google Analytics, for these purposes.
3. Information Sharing and Disclosure
We do not share Your Personal Information that We collected directly from You with third parties for their direct marketing purposes unless We have first given You the choice to consent or withhold consent to such sharing. We may share Your Personal Information in the following circumstances, or as otherwise described in any privacy notices provided to You at the time Your Personal Information was collected:
Your Use. Unless You specify otherwise in writing, User Data that You provide to us may be shared with Your Users.
Service Providers, Business Partners and Others. We may use certain trusted third party companies and individuals to help us provide, analyze, and improve Our Site, Content, and/or services (including but not limited to data collection, data storage, maintenance services, database management, web analytics, payment processing, and improvement of Our Site’s features). These third parties may have access to Your information only for purposes of performing these tasks on Our behalf and under obligations similar to those in this Privacy Policy.
Marketing Partners. We may share Your information with third party marketing partners for commercial/advertising purposes.
Third Party Applications. We may share Your information with a third party application with Your consent, for example when You choose to access Our Site and Content through such an application. We are not responsible for what those parties do with Your information, so You should make sure You trust the application and that it has a privacy policy acceptable to You.
Compliance with Laws and Law Enforcement Requests; Protection of Our Rights. We may disclose to parties outside the Preferred Entities information that You provide and that We collect when We have a good faith belief that disclosure is reasonably necessary to (a) comply with a law, regulation or compulsory legal request; (b) protect the safety of any person; (c) prevent fraud or abuse of Preferred or any Licensed User or User; or (d) to protect Our property rights.
Business Transfers. If We are involved in a merger, acquisition, sale of all or a portion of Our assets, or other change in corporate control (collectively a “Transaction”), Your information may be transferred as part of that Transaction or during the diligence process related to the Transaction.
Non-Private or Non-Personal Information. We may disclose Your non-private, aggregated, or otherwise non-personal information, such as usage statistics relating to our Site and Services or Licensed Content.
4. Your Rights and Choices
Individuals in certain jurisdictions may have certain rights under applicable privacy laws. Rights specific to residents of California and Nevada are described here. Subject to applicable law, You may have the right to request access to, modification or correction of, or deletion of Your Personal Information, and information on how it has been used or disclosed. To exercise Your rights, You may contact us at [email protected]. We will respond as soon as practicable, and in accordance with applicable law. We may take steps to verify Your identity prior to responding to Your request, and, where permissible by law, We may charge for such submissions.
5. Data Retention
We may retain and use Your information for the length of time needed to fulfill the purposes outlined in this Privacy Policy, comply with Our legal obligations, resolve disputes, and enforce Our agreements. We may also retain all anonymized Data.
6. Security
Information may be stored and processed in the United States (“U.S.”). If You are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that We may transfer information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as Your jurisdiction, and You consent to the transfer of information to the U.S. or any other country in which We maintain facilities and the use and disclosure of Your information as described in this Privacy Policy.
We follow generally accepted standards to protect the information submitted to us, both during transmission and once We receive it. No method of electronic transmission or storage is 100% secure, however. Therefore, We cannot guarantee its absolute security. If You have any questions about security on Our Site, You can contact us at [email protected].
7. Our Policy Toward Children
Our Site and Licensed Content are not directed to persons under 18. We do not knowingly collect Personal Information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at [email protected]. If We become aware that a child under 18 has provided us with Personal Information, We will take steps to delete such information from Our files.
8. Contacting Us
If You have any questions about this Privacy Policy or need to access an alternative format of this Privacy Policy, please contact us at [email protected].9. Changes to Our Privacy Policy
9. Changes to Our Privacy Policy
This Privacy Policy may change from time to time. We reserve the right to modify this Privacy Policy or Our policies relating to Our Site and the Licensed Content at any time, effective upon Our posting an updated version of this Privacy Policy on Our Site, at which time We will update the “last updated” date below. Continued use of Our Site or Licensed Content after any such changes shall constitute Your consent to such changes.
This Privacy Policy was last updated on April 2, 2024.
Preferred Entities will use best efforts to honor requests received in accordance with our posted policies on our website, which policies are consistent with the provisions of California Consumer Privacy Act. Please note, however, that the Preferred Entities do not deal in “Personal Information,” as that term is defined in Cal. Civ. Code § 1798.99.140, relating to California consumers, nor do the Preferred Entities operate in jurisdictions subject to GDPR regulations
If You are a natural person who is a resident of California or Nevada and use Our Sites, Content, or services. this Notice supplements the Preferred Entities’ Privacy Policy. Capitalized terms that are used but not defined in this Notice have the same meanings given them in the Preferred Entities’ Privacy Policy. If You are not a resident of California or Nevada, this Notice does not apply to You and You should not rely on it.
Opt-Out Rights For Residents of California and Nevada:
Residents of California and Nevada have the right to opt-out of “sales” of Personal Information (as defined by the applicable state law). You may exercise this right by executing the form provided here: CONSUMER OPT OUT. Be sure to fill out the form provided in the link in its entirety so that we have the necessary information in order for us to positively and uniquely identify You as the individual requesting the right to opt-out. If You fail to do so, we will not be able to satisfy Your request. If You execute such opt-out form, we will ensure that none of Your personal information will be licensed, sold or otherwise shared by us with third parties. We will respond to Your verified request as soon as reasonably practicable, but no later than 30 days after receipt. If, due to unforeseen circumstances, there is a delay in Our response, we will promptly notify you.
By executing the Preferred Entities opt-out form, You are opting out of databases purchased and licensed by the Preferred Entities only, not databases belonging to other companies. There are other companies similar to the Preferred Entities that provide consumer information to marketers for marketing purposes. Accordingly, please note that the fact that You opt-out by executing the Preferred Entities opt-out form does not prevent Your contact information from being used by vendors or marketers who access such information through other sources of data. Further, Your election to opt-out does not apply to information that is publicly available and can be derived from federal, state, or local government records, such as professional licenses and public real estate/property records.
By submitting a request to opt-out, You understand that the contact information You provide will only be used to facilitate the opt-out process and to maintain a record of Your request.
Additional Rights For Residents of California
In addition to the right to opt-out of “sales” of Personal Information, the California Consumer Privacy Act (“CCPA”) requires certain additional disclosures. As required by the CCPA, we describe the following in the tables and sections below:
The following sets forth the categories of information we may have collected and purposes for which we may have used California Consumers’ Personal Information in the preceding twelve (12) months:
1. OUR COLLECTION OF PERSONAL INFORMATION
Depending on how You interact with us, we may have collected about You the categories of information summarized in the table below. The following table also describes how we may have collected and used such categories of information.
Category | Categories of Sources |
Identifiers, e.g., name; alias; postal address; telephone number; email address. |
(Collectively, “Commercial Data Sources.”)
|
Characteristics of protected classifications under California or US law E.g., race; religion; sex/gender; marital status; military or veteran status; national origin; ancestry. | Commercial Data Sources. |
Commercial or transactions information E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Not applicable |
Internet or other electronic network activity information E.g., browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer’s interaction with a website, application, or advertisement. | Not applicable |
Geolocation data | Not applicable |
Professional or employment-related information E.g., current or past job history or performance evaluations. | Not applicable |
Inferenced Categories E.g., Inferenced consumer interests | Commercial Data Sources. |
2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION
We may have shared the information collected from and about You as discussed above for various business purposes, with service providers and with third parties, including Our Licensed Users. The chart below describes how and with whom we may have shared or disclosed Personal Information, and whether (based on the CCPA’s definition of “sell”) we believe we may have “sold” a particular category of information in the prior 12 months.
Category | Categories of Third Parties We Share With | Whether We “Sold” This Category of Personal Information in the Last 12 Months |
Identifiers, e.g., name; alias; postal address; telephone number; email address | Non-profit organizations, data analytics providers (Collectively, “Commercial Data Recipient”) | Yes. |
Characteristics of protected classifications under California or US law, e.g., race; religion; sex/gender; marital status; military or veteran status; national origin; ancestry. (Data may be inferenced.) | Commercial Data Recipients. | Yes. |
Commercial or transactions information, e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. (Data may be inferenced.) | Not applicable | No. |
Internet or other electronic network activity information, e.g., browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer’s interaction with a website, application, or advertisement. | Not applicable. | No. |
Geolocation data | Not applicable | No. |
Professional or employment-related information. E.g., current or past job history or performance evaluations. | Not applicable | No. |
Inferenced Categories E.g., Inferenced consumer interests | Commercial Data Recipients. | Yes. |
We also may share any of the Personal Information we collected as follows:
Sharing for Legal Purposes: In addition, we may share Personal Information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce Our Terms of Use, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of Us, Our platform, Our agents and affiliates, Our Users and Licensed Users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.
Sharing In Event of a Corporate Transaction: We may also share Personal Information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of Our assets, or for purposes of due diligence connected with any such transaction.
Sharing With Service Providers: We share any Personal Information we collect with Our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve Our services.
Aggregate and Deidentified Information. We may aggregate and/or de-identify any information collected so that such information can no longer be linked to You or Your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in Our discretion. Please also refer to Section 3 below, which further describes Our business purposes for collecting and sharing Personal Information.
3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION
Generally speaking, we may have collected and shared the Personal Information that we collected for the following purposes, as we also have described in Our Privacy Policy.
Our Purposes for collecting, using and sharing Personal Information |
Data marketing services, for example:
|
Online targeting, for example:
|
Additional marketing services, for example (which may overlap with “data marketing services” above):
|
Operating Our services, for example:
|
Other internal purposes, for example: For internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance. |
4. YOUR CALIFORNIA PRIVACY RIGHTS AND CHOICES
In addition to the right to opt-out of “sales” of Personal Information, the CCPA also provides that California residents may ask us to disclose what personal information we have about them, what we do with that information, and to delete their Personal Information. If You are a California resident that would like to exercise these other rights in accordance with the CCPA, You can submit Your request executing the form provided at the following link: CONSUMER OPT OUT or by email at [email protected] to specify the rights You wish to exercise.
Preferred Entities will use best efforts to honor requests received in accordance with our posted policies on our website, which policies are consistent with the provisions of California Consumer Privacy Act. Please note, however, that the Preferred Entities do not deal in “Personal Information,” as that term is defined in Cal. Civ. Code § 1798.99.140, relating to California consumers, nor do the Preferred Entities operate in jurisdictions subject to GDPR regulations
Verification:
In order to protect Your Personal Information from unauthorized access or deletion, we may require You to verify Your identity and proof of residency before You can submit a request. If we cannot verify Your identity, we will not process Your request.
Authorized Agents:
Authorized agents may submit requests on behalf of California residents by email at [email protected] and presenting signed written permission to act on an individual’s behalf. If You submit a request through an authorized agent You may also be required to independently verify Your identity and submit proof of Your residency directly to us.
California Consumer Requests
In compliance with the California Delete Act of 2023, we provide the following information regarding consumer requests received in the previous calendar year (January 1, 2023 – December 31, 2023).
Requests to Delete, to Know, to Access, to Opt-out of Sale or Sharing, or to Limit the Use of a Consumer’s Personal Information:
Total received: 27
Complied with: 27
Denied: 0
Median Response Time: 5 Days
Mean Response Time: 6 Days
Non-required Deletions:
Instances where deletion was not required under California Consumer Privacy Act of 2018 Section 1798.145: 25
Instances where deletion was not required under California Consumer Privacy Act of 2018 Section 1798.146: 25
This Notice of Privacy Policy and Right to Opt-Out For Residents of California and Nevada was last updated on June 30, 2024.
