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.
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.
Marketing Partners. We may share Your information with third party marketing partners for commercial/advertising purposes.
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@example.com. 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 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 firstname.lastname@example.org.
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@example.com. 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
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 collect and purposes for which we may use California Consumers’ Personal Information:
1. OUR COLLECTION OF PERSONAL INFORMATION
Depending on how You interact with us, we may collect about You the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.
Categories of Sources
Identifiers, e.g., name; alias; postal address; telephone number; email address.
· Data compilers and consumer data resellers. public records and other publicly available sources, consumer surveys and survey companies. (Note that above categories may be overlapping in nature.)
· Data analytics providers.
(Collectively, “Commercial Data Sources.”)
· Government sources such as U.S. Census Bureau.
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.
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.
Commercial Data Sources, US Postal Service.
Professional or employment-related information
E.g., current or past job history or performance evaluations.
Commercial Data Sources
E.g., Inferenced consumer interests
2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION
We will share 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 share or disclose Personal Information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.
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
Data compilers and consumer data resellers, consumer goods and other consumer retailers, informational and retail websites, content publishers, non-profit organizations, food vendors, apparel vendors, business-to-business services and organizations, consumer surveys and survey companies, affiliate networks and government entities, including military services.
In addition, advertising networks, internet service providers, data analytics providers, operating systems and platforms and social networks.
(Collectively, “Commercial Data Recipient”)
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.
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.)
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.
Service Providers, Commercial Data Recipients.
Professional or employment-related information. E.g., current or past job history or performance evaluations.
We also may share any of the Personal Information we collect as follows:
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
Our Purposes for collecting, using and sharing Personal Information
Data marketing services, for example:
· Helping Our Licensed Users identify and understand consumers better, by providing insights about them, as well as providing financial and other scoring Content.
· Assisting Our Licensed Users through Our Content and services to provide their current and prospective customers with better service and improved offerings, for instance, advising on which current or prospective customers are most likely to be interested (or disinterested) in certain offers.
Online targeting, for example:
· Creating or helping to create defined audience segments based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., households seeking wealth management services).
Additional marketing services, for example (which may overlap with “data marketing services” above):
· Assisting in targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing.
· Measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases.
· Providing “verification” or data “hygiene” services, which is how companies update and/or “clean” their databases by either verifying or removing or correcting old, incorrect or outdated information.
Operating Our services, for example:
· improving, testing, updating and verifying Our own database.
· developing new Content and products.
· operating, analyzing, improving, and securing Our services.
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. We use the information collected from “business to business” interaction or from data compilers for the above, as well as for Our own marketing purposes.
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 firstname.lastname@example.org to specify the rights You wish to exercise.
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 may submit requests on behalf of California residents by email at email@example.com 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.