Foo Monk, LLC dba
Instantly.ai (“we,” “our,” “Instantly”) provides data marketing services (the “Services”) designed to assist a range of for-profit and not-profit organizations, and companies that work with them, in their customer outreach and marketing processes. In general, we help our customers (and sometimes, their own customers) to market their goods and services in a more targeted and efficient way by providing information and insights about their actual and potential customers. Our solutions, many of which are described on this website, may be used to support marketing across various platforms, including email, direct mail, and digital advertising.
We take seriously the privacy objectives of the individuals whose information we handle and maintain in our database. We in turn provide this Privacy Policy (“Privacy Policy”) to explain how we use and manage personal information, and what rights consumers have to control how their information is used in our various marketing services.
To review the “Addendum” we have created specifically to address disclosures required under the
California Consumer Privacy Act, please see our “
CCPA PRIVACY NOTICE.” We use the term “personal information” (also called “personal data” under some states’ or countries’ laws) to capture the various types of information and identifiers that are generally included in statutory definitions of these terms, particularly under U.S. state privacy laws that use those terms.
In addition to using personal information to create and provide our products and services, we operate corporate websites, which are designed for our own customers and prospective customers, and others who want to learn about our services. We address the information we collect and use for those and other business purposes (such as information we use to communicate with our corporate customers, and potential customers) in Section 6 of this Privacy Policy.
1. Information That We Collect and Use in Our Services
In order to provide our Services, we receive data, including personal information, from a variety of sources, including from websites and apps that collect the information, public sources, and other data compilers. We refer to the information that we collect and process throughout this Privacy Policy as “Information” or “the Information.” We generally seek to collect only “business intelligence” information – Information associated with work emails, phone numbers, job titles and related information; however, we may also collect Information such as identifiers that consumers employ for personal use as well.
The Information we use to provide our Services includes:
- First/last name, and date or month of birth
- Personal email
- Professional email
- Job title, history and other professional information such as organizations you belong to
- Personal or professional telephone number, and postal address
- IP address
- A cookie or device identifier, which uniquely identifies your browser or device. Please see Section 5 for more information on these identifiers.
- Usage data related to your email interactions, such as whether you receive, open or respond to an email, and related information, as well as whether an email is or recently has been in use
- Usage data related to your website interactions, such as whether you visit or log in to a website, page visits and related information
- Information and actions associated with consumer interactions, such as success rates of consumer outreach (whether by phone, email or other channels), and in turn which consumers (or types of consumers) may be interested in which types of products
- Demographic information, such as inferred income or age range, household size, or home ownership, and personal information such as jobs held or educational institutions attended.
- Information regarding consumer interests, such as what type of business products you may be interested in.
Some of the above Information may be inferred – for instance, if certain identifiers appear connected to the same person or phone number/email address, we may infer that they relate to the same individual. Or, if you are a marketing profession, we may infer that you may be interested in certain marketing products and services.
In addition, we may use certain information and actions associated with consumer interactions, such as success rates of consumer outreach (whether by phone, email or other channels), to provide or enhance our services, such as to allow our customers to gain insights, validation of data, or benchmarking, from pooled information.
Instantly also receives Information through this website (and any other website we operate), and our business operations. We describe this Information in Section 6.
2. How We Use the Information
Instantly uses the Information for various purposes, including the following.
As Part of Our Services:
- Data Marketing Services. Our Services include our licensing or other provision of marketing information (which may include personal information) to our customers, generally regarding which customers or prospective customers are most likely to be interested (or disinterested) in certain offers or certain products or services. We also help our customers identify and understand their customers better, by providing insights about them. Our customers may at any given time include (but are not limited to) small and medium-sized businesses, ad and media agencies, job recruiters, non-profits, brands and marketing data platforms that help their customers to market and advertise to their own customers (and prospective customers), or government agencies, particularly when engaged in quasi-commercial pursuits. Our customers also may include other data compilers, who work with their own customers.
- Retargeting Services. We sometimes help our customers to “retarget” marketing content to website visitors. In particular, our Services may help customers to send emails or other marketing to people who visited or logged in to their websites, by cross-referencing information such as cookie identifiers and emails and other personal information (including those compiled by third party data services) for those purposes.
- Additional Marketing Services. Other Services we may make available, which may supplement the above Services, may involve (a) assisting customers to target and optimize email campaigns, display, or other marketing; (b) measuring the effectiveness or performance of marketing 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; (c) analyzing and optimizing our customers’ (or their service providers’) proprietary databases; (d) helping customers detect and prevent fraud and provide “validation” or data hygiene services, e.g., by verifying or removing or correcting old, incorrect or outdated information or evaluating whether an email address recently has been active.
- Audience Segments. We may create groups of individuals we believe are interested in particular types of products or have other common interests or characteristics (for instance “Media Executives” or “Digital Marketing Professionals”). We refer to these as “Audience Segments” and may license them to our clients for use in marketing campaigns. We also may link (or work with other platforms that link) those Audience Segments to other identifiers or personal information that are then used by us, our customers, or third-party platforms to help target and advertise in a relevant way to those groups of individuals. In this way, visitors to clients’ website may receive advertising campaigns across other devices or marketing channels.
To Operate Our Services
We also use the Information described above for our own internal purposes – such as to improve, test, update and verify our own database; develop new products; operate, analyze, improve and secure our Services and our databases and servers.
Deidentified Personal Information. Sometimes, as part of our research and development (e.g., to evaluate potential new products), we may create aggregated, de-identified and/or anonymized data from personal information we collect. We compile, derive, and otherwise process de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business and will not attempt to reidentify any such data.
3. How We Share Information with Third Parties, including Service Providers
Instantly may share the Information with customers, marketing services and platforms, as well as service providers that help us to provide the Services we’ve described above (or other services we may add in the future). This includes sharing in the following ways:
- With Our Customers: As described above, we license the Information in various ways to our customers (and something to partners and resellers, who license the Information to their customer), when we provide our Services. We may sometimes share the Information with those Customers’ service providers (for instance, a provider that prints or sends direct mailings for a Customer, or sends email campaigns for a Customer).
- With Our Partners: We also may share the Information, including personally identifiable information and Audience Segments, with business and data partners to help provide more tailored targeted marketing, advertising and communications. Likewise, we may do so for analytical purposes, including to help these other parties measure campaign performance, inform future campaigns, or to handle, analyze, or segregate this Information on our or our customers’ behalf. Sometimes, we will share the Information with the service providers of those businesses, such as where they rely on particular ad or content delivery platforms to house or process Information they use.
- With Our Service Providers: We share the Information with a variety of service providers in order to operate, protect and advertise our Services and maintain our website(s). For instance, we may share the Information with our tech, hosting and customer support providers, marketing and advertising providers, other data providers (such as to enhance or verify our Information), security vendors, payment vendors (as to our business-to-business information), and other companies help us deliver, secure or develop our Services.
- Corporate transfers: If Instantly, its stock or its significant assets are acquired by or merged into another entity, our Information will be transferred to that entity, and may be shared during due diligence in anticipation of any such transaction.
- Affiliates, parent companies and subsidiaries: Instantly may share some or all of the Information in our possession with any affiliated or subsidiary companies (if we ever have any).
- As required by law or to protect any person or entity: Instantly may disclose Information if we believe that such disclosure is necessary to (a) comply in good faith with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or safety of Instantly, our customers, or any other person or entity.
4. Your Marketing and Opt-Out Choices
There are multiple ways that you can opt-out of having the Information used to market to you:
- First, you may visit our opt-out page
here, to have your personal information removed from our database. We will then in most cases remove your personal information from our active marketing databases within 15 business days, from the time we received the opt-out request. We may in certain cases (and where legally permissible) require that you verify any of the information that you submit, such as through a verified email response or another verified response.
- Similarly, to opt out of our Retargeting Services described in section 2, go to our opt-out page
here and follow the instructions on that page regarding opting out of their cookies and other personal identifiers. You will need to do that from each browser that you use (because the retargeting and thus the “opt out” are cookie-based), and if you clear your browser cookies you will need to opt out again.
- To the extent the DAA continues to maintain it, you may visit the DAA Webchoices tool at
https://youradchoices.com/ to learn more about this type of advertising and how to opt out of this advertising on websites by companies participating in the DAA self-regulatory program. In addition, many websites and advertising platforms recognize a “GPC” signal, which may be deployed on a browser or through a browser extension, as a means of honoring a “do not sell” request. For more information on this method of “opting out,” please go to
https://globalprivacycontrol.org/.
- If we market to you by email, in our corporate capacity – such as if you are a customer or prospective customer of ours and we send communications about our Services -- you may “unsubscribe” from our marketing emails through a link placed in your emails.
- You can also opt out of Google Analytics and customize the Google Display Network ads by visiting the
Google Ads Settings page from each browser. Google also allows you to install a
Google Analytics Opt-out Browser Add-on for each browser.
5. Cookies and Similar Technologies
Cookies and How We Use Them
Instantly and its business partners use certain industry-standard technologies, including cookies and similarly functioning technologies, which we describe below. (We and/or our service providers use these technologies on our website, for instance, and our partners may use these technologies in their own marketing services.)
We may work with third parties or service providers to provide or enhance our services (e.g. for purposes of tailoring ads, or placing browser cookies), or to offer marketers ways to access or use our Information, often coded in “hashed” format. These partners may set and access their own cookies, pixel tags and similar technologies on your browser, which may have cookies with varying expiration periods. Those partners may, likewise, collect various types of information about your browser, device, or browsing activities through use of these cookies.
Cookies, in turn, are small data files that contain a string of characters, such as a unique browser identifier. Cookies are stored on your computer or other device and act as tags that identify your device. Our (or other companies’) servers send your device a cookie when you visit a website. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access web pages (such as the website of a marketer), pixel tags may generate a generic notice of the visit and permit our partners (or sometimes, us) to read the cookies that a respective company or server has deployed. Pixel tags can be used in combination with cookies to track the activity on a site by a particular device.
We or our service providers, and other online marketing platforms that we or they work with, may use cookies to, among other things, “remember” you, determine visitor patterns and trends, collect information about your activities on our clients’ sites, or interact with the advertising you see. Cookies are used in this way to provide relevant content to you and replace non-relevant communications with ads that better match your interests.
Disabling Cookies
Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of our website and other services may be difficult to use or become inoperable. For additional information about cookies and other tracking technologies employed by the Service and how to control them, see our
Cookie Notice.
6. Data Collected Through Our Corporate Website and in our Corporate Capacity
Information Collected
Instantly collects Information from users of our website(s) (including any page on which this Privacy Policy is posted), including:
- The domain name and IP address of a user’s web browser, as well as a user agent, time stamp and other Information about a user’s browser or device.
- Information about what content and pages users access, utilize or visit on our website, or how they interact with our content – for instance, if they spent a certain amount of time reviewing a particular blog post or description of particular services.
- Information, including personally identifiable and contact information that you provide, which could include (for instance) survey information, sign-up information (e.g., if you sign up for our webinars, events or newsletters), requests for information, mailing addresses and email addresses.
We may also collect Information in the course of conducting and marketing our business. For instance, we may collect Information through phone calls, at trade shows, during webinars, or during other marketing initiatives and activities.
Likewise, we collect Information from our customers in the course of interacting with them, including through the service platforms, technology and dashboards we offer. If you are our customer, we may, for instance, record the manner in which you interact with our Services, what tools you use, and what information you provide or receive, and we may combine or track this Information based on your account information, cookie identifiers or other electronic technologies.
How Instantly Uses the Information We Collect Through Our Website and In Our Corporate Capacity
We use the Information we collect through our website(s) and other platforms and technologies you may interact with to do the following:
- Create and manage your user account.
- Provide Services you have requested.
- Respond to and communicate with you (including regarding news and updates about our services).
- Send you offers and ads for our products and services, when you browse the website(s) or other companies’ websites on the Internet (such as to “retarget” you with marketing communications about our Services), or through other media and communication channels such as email.
- Send you offers and ads for products and services of partner brands, or other offers we believe may be of interest to you, such as invitations to events and webinars.
- Perform data analysis (including market research).
- We may combine the Information with other personal information we obtain from third parties, publicly available sources, and any other product or service we provide to further improve the relevance and effectiveness of products, and advertisements offered, including (but not limited to), those provided on or through our services.
- We may use IP addresses to help diagnose problems with our servers and to administer our website(s). We also may use IP addresses to help identify visitors to our website(s) for the duration of a session and to gather demographic information about our visitors. We may use clickstream data to determine how much time visitors spend on each web page of our website(s), how visitors navigate through the website(s), and how we may tailor our website(s) to better meet the needs of our visitors. We also use this Information for compliance with our legal obligations, policies and procedures, including the enforcement of our Terms and Conditions.
- If we collect Information from “offline” sources – such as if you provide us your business card at a trade show – we will maintain that Information and use it for marketing and business purposes, as well.
- Enrollment in a Service. We also separately collect personal information upon your enrollment and/or consent in a service. We may share such personal information with subscribers (also known as enterprise customers) to our Services and others who purchase personal information from us through our lead-generation services. For example, if you enroll in our “email warmup” service, your personal information, such as your name, email address and contact information as displayed in your email signature, will be shared with other participants in our “email warmup service.” In addition, certain User-generated content data may be publicly displayed and include your personal information. For example, when you leave a comment on our website, your name may be publicly displayed with your comment.
How Instantly Shares the Information We Collect Through Our Websites and Our Corporate Capacity
We may sometimes share or otherwise disclose the Information we collect about you, as described in this Section, as follows:
- We may share the Information with service providers who help us deliver the services you request or we provide. For instance, we share the Information with tech and customer support providers, marketing and advertising providers, other data providers (such as to enhance or verify our Information), security and data hygiene vendors, payment vendors (as to our corporate information), and other companies that may help us deliver or develop Services.
- We may share the Information to communicate with you and market to you, including through email, direct mail or display media.
- We will disclose your personal information (or other Information) if we believe in good faith that we are required to do so by law, regulation or other government authority or to protect the rights, safety or property of ourselves or any person or entity. We may also cooperate with law enforcement agencies in any official investigation and we may disclose any Information to the requesting agency in doing so.
- If we or all or substantially all of our assets, are purchased by another company (such as in a merger, consolidation, restructuring, the sale of stock and/or assets, or other corporate change or financing transaction), the Information in our possession will likely be transferred to the successor entity. We also may share the Information during the course of any due diligence process leading up to any such transaction.
Our website(s) use cookies and similar technologies, both for its internal and operational purposes and to market to you (such as to retarget ads to you when you visit other sites across the Internet). We may provide you with “cookie management” options, such as through a banner visible on our landing page.
7. Privacy Rights You May Have in Specific States, Europe and the United Kingdom
Certain states have passed state-specific privacy laws that grant residents of their state’s particular privacy rights. These states include California (as to which a separate “Addendum” is provided below), as well as Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia. It also includes other states as their own states’ laws have or will become effective over time (during 2025 and 2026) including Indiana, Kentucky, Maryland, Nebraska, Rhode Island, and Tennessee. A useful privacy “tracker” as to what these states are, and when each privacy law becomes effective, is provided by the “IAPP,” an industry association devoted to privacy issues, at
https://iapp.org/resources/article/us-state-privacy-legislation-tracker/. European Union nations as well as the United Kingdom have passed similar laws regarding their own residents.
If you live in one of these states or countries, you may have the following rights with respect to your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to herein as “personal information”).
Namely, you may have the right to ask that we:
- Provide you access to and/or a copy of certain personal information we hold about you.
- Correct or update personal information we hold about you. (We may process a “correction” similar to a “deletion” if we cannot sufficiently verify your identify.)
- Delete certain personal information we have about you, which may also be referred to as the right of “erasure” under some laws. In addition, in the U.K. and E.U., the right to withdraw your consent for specific processing, to the extent our processing of personal information is based on your consent.
- Opt you out of the sale or sharing of personal information, or processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.
- You also generally have the right to not be discriminated against for exercising your rights.
You also have the right to disclosures, as we provide in the Policy about the types of personal information we collect and disclose, and from and to whom:
-
How to Exercise your Privacy Rights. You may submit requests to exercise your right to information/know, access, correction, or deletion by going here, or calling us toll free at 1-866-467-8688 Service Code 1974#.
- You can submit requests
to opt-out of tracking for targeted advertising purposes or other sales of Personal Information here:
Privacy Request Manager or via phone by calling 1-866-467-8688 Service Code 1974# or by broadcasting the global privacy control signal. If our website detects that your browser is transmitting an opt-out preference signal, such as the GPC signal, we will opt that browser out of cookies on our website that result in a “sale” or “sharing” of your personal information. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use to visit our websites.
For security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you — when you request to exercise certain California privacy rights. For instance, if you request specific pieces of personal information we have received about you, you may need to confirm your possession of an identifier (such as your possession of an email address or your residence at a home address in order to confirm you are the person you claim to be.
Certain Information may be exempt from such requests under applicable law. For example, we need to retain certain Information in order to provide our services to you. In addition, if you ask for a copy of your personal information (or ask to have that Information deleted), we will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, verifying your name and email address. If we cannot verify you, we may be unable to respond to your requests.
Separately, if you have registered for an account with us through our Service, you may review and update certain account information by logging into your account.
Authorized Agents. You may designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.
Right to Appeal. In certain states, residents have the right to appeal our decision to deny your request, if applicable. If you wish to do this, please send an email to
[email protected] with the word “Privacy Appeal” in the subject line.
Opt Out of Targeted Advertising. You may also opt out of targeted advertising, which we may occasionally engage in, such as to “retarget” with information about our services when you visit other websites (which in some states may be considered “selling” or “sharing” personal information). Please see the instructions in Section 4, above, to learn about those “opt out” methods. We do know knowingly sell the personal information of minors under 16 years of age, or deliberately target minors with advertising.
8. Links
This website may provide links to other websites that Instantly thinks users may be interested in. Instantly is not responsible for the privacy practices of these other sites or companies.
9. Security and Data Integrity
Instantly takes steps designed to help ensure that the data we possess is housed and transmitted securely. This may include various types of physical and electronic security, including firewall protections, encryption, hashing or truncation of data, and access controls to personal information. However, you should be aware that neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion.
10. Changes to this Privacy Policy
From time to time, we may update this Privacy Policy. Any changes to it will become effective when it is posted to our website. Please check back to learn of any changes to this Privacy Policy
11. Storage of Information in the United States
If you are accessing our website from outside of the United States, your connection likely will be through and to servers located in the United States and all Information you provide will likely be processed and securely maintained in our web servers and internal systems located within the United States. (We generally store the Information used in our Services in the United States.) Thus, you should be aware that in accessing this website or otherwise communicating with us, the Information we collect or receive from you may be subject to laws with lesser or different privacy standards than those in your own country (such as if you are in a country located in the European Union).
12. When We Act as a “Processor” or “Service Provider” We sometimes act as a “processor” when we receive and process our customers’ own proprietary personal information, such as their own list of customers, in order to perform services for them. For those data processing activities where we act as a “processor” of our customers’ information, also known as a “service provider” in jurisdictions such as California, this Privacy Policy does not apply to such personal information. If you have questions or requests regarding your personal information that we process at the direction of and on behalf of a customer of ours, please direct your question to that enterprise customer.
13. Your California Privacy RightsIf you are a resident of California, the California Consumer Protection Act, as amended by the California Privacy Rights Act (together the “CCPA”) provides certain rights of disclosure, access and deletion of your Information as described below in the “
CCPA PRIVACY NOTICE” at the end of this Privacy Policy.
14. Additional Information for European Data SubjectsIn addition to the above rights granted to EU and UK residents, we comply with other applicable legal requirements related to EU and UK laws related to personal information (referred to as “personal data” under those laws), including the General Data Protection Regulation (GDPR), including as follows:
Legal Basis Upon Which We Rely. We will only use your personal information when the law allows us to. If you are based in the United Kingdom or Europe, when we act as a data controller we will only use your personal information if we have one of the following legal bases:
a. Where we need to perform the contract we have entered into with you (for example, a client agreement we have with you);
b. Where it furthers our legitimate interests (or of our customers, business partners, or suppliers) in business activities such as the ones listed below, and because that handling of data does not unduly impact your interests, rights, and freedoms, such as:
i. using identifiers and financial information to protect business activities, individuals, and property;
ii. using identifiers to potentially further mutual business relationships (such as to help marketers of business services to offer or communicate about business opportunities)
iii. using identifiers to communicate for customer service;
iv. using identifiers for marketing and advertising (including sending certain direct marketing);
v. using commercial information to analyze and improve our business activities;
vi. using identifiers and Internet or other electronic network activity information to provide cybersecurity, manage information technology assets, and manage risks and legal issues;
c. Where we need to comply with a legal obligation;
d. Where we need to protect your interests (or someone else’s interests); and/or
e. Where we have obtained your consent. (We may request your consent before engaging in certain activities described in this Privacy Policy, such as if we retarget ads to visitors of our own website.)
f. for more information on our specific purposes and use cases of personal information/personal data and the data types involved, see Sections 2 and 3, above.
Data Transfers Across Borders and Overseas. European and U.K. law imposes certain conditions on overseas and in some cases cross-border transfers of personal information (personal data). We make such transfers under the following conditions:
- Transfers to countries that have been deemed to provide an adequate level of protection for personal information by the relevant authorities.
- Transfers using specific approved contracts, such as the EU Standard Contractual Clauses for transfers of personal information to third countries, with appropriate modifications for other jurisdictions.
- Transfers in reliance on the EU-U.S. Data Privacy Framework, the UK-U.S. Data Bridge, or other programs approved by relevant authorities.
- Transfers based on appropriate consent.Transfers necessary to perform a contract with the data subject.
- Transfers that are legally mandated in appropriate circumstances.
- Please contact us at the following address if you would like further information on the specific mechanism used by us when transferring your personal information out of the United Kingdom or Europe.
Email:
[email protected]
Mail: 30 N. Gould St., Ste. R, Sheridan, Wyoming, 82801, United States
Phone: +1 657 242 8111
Our GDPR Representatives. Our EU representative appointed under the EU GDPR is EDPO. You can contact them by using EDPO’s online request form or by postal mail to Avenue Huart Hamoir 71,1030 Brussels, Belgium. Our UK representative appointed under the UK GDPR is EDPO. You can contact them by using EDPO’s online request form or by postal mail to 8 Northumberland Avenue, London WC2N 5BY, United Kingdom.
Supervisory Authority. All individuals also have a right to complain to their local data protection supervisory authority about any company’s handling of their personal information. If you have a concern about our data practices, we invite you to please contact us first so that we can do our best to address your concern.
15. Contact UsIn addition to the above-referenced communication methods, Instantly has a designated privacy contact. If you have questions related to this Privacy Policy, or regarding our products or services, please contact us:
Privacy Officer
Instantly, Inc.
Mail: 30 N. Gould St., Ste. R, Sheridan, Wyoming, 82801, United States
Phone: +1 657 242 8111
Email:
[email protected] We appreciate your comments and questions regarding Instantly’s privacy practices.
Last updated: February 16, 2026
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CCPA PRIVACY NOTICE: ADDENDUM FOR CALIFORNIA RESIDENTS
CALIFORNIA PRIVACY RIGHTS
Last Modified: February 16, 2026
The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (together, the “CCPA”) provides certain rights to residents of California. This section of the Privacy Policy applies if you are a natural person who is a resident of California (“California Consumer”) and uses our Services. This Addendum supplements the information in the Privacy Policy. However, this Addendum is intended solely for, and is applicable only as to, California Consumers: if you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it.
In the below tables and sections, we describe (as required by the CCPA):
- Our Collection of Personal Information – the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from
- Our Disclosure, Share and Sale of Personal Information – the types of recipients to whom we disclose, share or sell Personal Information.
- Our Business Purposes – our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.
- Your California Privacy Rights and Choices– what rights you have under the CCPA, for instance, to request that we “opt out” or delete or correct your Information from or in our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.
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 below. The following table also describes how we collect and use such categories of Information for purposes of our Services. The data types listed below each category are provided solely for purposes of example: we do not necessarily collect or use each such data type.
2. OUR DISCLOSURE, SHARE, 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 customers. The chart below how and with whom we sell, share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” or “shared” a particular category of information. (“Sharing” under the CCPA includes disclosure for purposes of cross contextual behavioral advertising, sometimes called targeted advertising or interest-based advertising.) Note that the examples we provide under the column “Category” simply reflect statutory, exemplary language: we do not necessarily collect all types of information reflected within each category.
We also may disclose any of the personal information we collect as follows:Sharing for Legal Purposes: In addition, we may disclose 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 Service, 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 customers, our agents and affiliates, its 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.
Disclosure In Event of a Corporate Transaction: We may also disclose 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.
Disclosure to Service Providers: We disclose 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 or 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 disclose such data to any third parties, including advertisers, promotional partners, and sponsors, in our discretion.
3. OUR BUSINESS PURPOSES FOR COLLECTING AND DISCLOSING PERSONAL INFORMATION
Generally speaking, we collect and disclose the Personal Information that we collect 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:
- Operating our data cooperative and providing marketing information to our Clients (which may include companies, non-profit organizations, other data compilers, resellers and platforms, advertising networks, and political organizations), generally regarding their marketing, recruiting, fundraising, customer service and engagement, and outreach activities.
- Helping our Clients identify and understand their consumers better, by providing insights about them and managing loyalty programs, as well as providing financial and other scoring products.
- Assisting our Clients with use our Services to provide their End Users and prospects with better service, improved offerings, and special promotions, for instance, advising on which End Users or prospective End Users 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 with prospective students). When we do this, we may work with a data partner that “matches” our or other Information through coding techniques (such as through coded data “hashing”) with online cookies and other identifiers, in order to target and measure ad campaigns online across various display, mobile, email or direct mail or other media channels.
Additional marketing services, for example:
- Assisting in targeting and optimizing 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.
- Analyzing and optimizing our Clients’ (or their service providers’) proprietary databases, or helping Clients to identify and mitigate potential fraud.
- Providing “verification” or data “hygiene” services, to help 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 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 sometimes use the Information collected from our own website from social networks, from other “business to business” interaction (such as at trade shows) or from data compilers for the above, as well as for our own marketing purposes.
4. YOUR CALIFORNIA RIGHTS AND CHOICES
Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.) Please note that sometimes we act as a “service provider” for our clients, in which case we receive and act on instructions from the client(s) as to the client data provided: any requests to exercise rights with respect to data we handle on behalf of a client should be directed to the particular client.
a. Right to request access to your personal information
California residents have the right to request that we disclose what categories of your personal information that we collect, use, or sell. You may also request the specific pieces of personal information that we have collected from you. However, we may withhold some personal information where the risk to you or our business is too great to disclose the Information.
b. Right to request deletion or correction of your personal information
California residents may also request that we delete or correct any personal information that we collected from you, such as if you have been a customer of ours. (Note that this is different from your right to “opt out” of us selling your personal information, which is described below; also note that we do not generally collect personal information directly from consumers.)
However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. Additionally, we need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.
c. Right to “opt-out” of the sale or “sharing” of your personal information.
California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” – including making available a wide variety of information in exchange for “valuable consideration.”
Depending what Information we have about you, and whether we have included any of it in our marketing products and services, we may have sold (as defined by California law) certain categories of Information about you in the last 12 months, as described in the above table in Section 2 of this Addendum.If you would like to opt out, you may do so as outlined on the following page:
Privacy Request Manager.
You may also opt out of “sharing” as it is defined in the CPRA, also known as “targeted” or “personalized” advertising, by viewing the opt-out methods in Section 4 in our main Privacy Policy, above.
d. How to exercise your access, correction and (if applicable) deletion rights
- You may submit requests to
exercise your right to information/know, access, correction, or deletion through our
Privacy Request Manager, or calling us toll free at 1-866-467-8688 Service Code 1974#.
- You can submit requests
to opt-out of tracking for targeted advertising purposes or other sales of Personal Information here:
Privacy Request Manager or via phone by calling 1-866-467-8688 Service Code 1974# or by broadcasting the global privacy control signal. If our website detects that your browser is transmitting an opt-out preference signal, such as the GPC signal, we will opt that browser out of cookies on our website that result in a “sale” or “sharing” of your personal information. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use to visit our websites.
For security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you — when you request to exercise certain California privacy rights. For instance, if you request specific pieces of personal information we have received about you, you may need to confirm your possession of an identifier (such as your possession of an email address or your residence at a home address in order to confirm you are the person you claim to be.
Once we have verified your identity, we will respond to your request as appropriate:
- Where you have requested the categories of personal information that we have collected about you, we will provide a list of those categories.
- Where you have requested specific pieces of personal information, we will provide the information you have requested, to the extent required under the CCPA and provided we do not believe there is an overriding privacy or security concern to doing so.
- Where you have requested that we delete personal information that we have collected from you, we will seek to confirm whether your request is for an “opt out” or a “deletion”: because “opt out” or “do not sell” rights enable us to maintain your Information for “suppression” purposes – i.e., to prevent us from selling Information about you in the future (which is what many consumers requesting “deletion” actually desire to occur) — we try to explain this in order to ensure we are meeting consumers’ preferences. (In addition, “deletion” rights only apply to Information that we have collected “from” consumers – which does not apply to much of the Information in our databases.)
- Upon completion of the above process, we will send you a notice that explains the categories of personal information we were able to locate about you, whether we (1) deleted, (2) deidentified, or (3) retained the Information we collected from you. Certain Information may be exempt from such requests under applicable law.
If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.
e. Right to nondiscrimination.
We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
f. Information about persons under 16 years of age
We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their Information from our database (or to obtain legally required consent).
g. Authorized agents
You may designate an agent to make requests to exercise your rights under the CCPA as described above. When we receive such a request, we may (as appropriate) take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.
h. Data retention
We retain personal information in our commercial database for as long as it is useful or being used We generally retain personal information to fulfill the purposes for which we collected it, including to provide services, such as to assist our clients in selecting offers or advertisements, or correcting and validating their own customer information, but also for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.
5. California Delete Act Information
Consumer Request Statistics Pursuant to California Delete Act
From January 1, 2025 to December 31, 2025, we maintained processes to facilitate requests pursuant to the California Consumer Privacy Act. We received the following requests, and responded as follows:
a. As to Requests to Know
- We received 253
- We complied in whole or in part with 253
- We denied 0Our median response time was 3 days.
- Our mean response time was 4 days.
b. As to requests to opt out/delete
- We received 5229 requests
- We complied in whole or in part with 5229 requests
- We denied 0 requests
- Our median response time was 1 day. Our mean response time was 1 day.
c. As to requests to correct (which we interpret as a “deletion” and “suppression” request)
- We received 0 requests
- We complied in whole or in part with 0 requests
- We denied 0 requests
- Our median response time was 1 day. Our mean response time was 1 day.
