Questions? Feedback? powered by Olark live chat software Alliant Data Services and Website Privacy Policy

Last Modified: December 31, 2019

NOTICE TO CALIFORNIA RESIDENTS – CALIFORNIA CONSUMER PRIVACY ACT of 2018

The California Consumer Privacy Act of 2018 (“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” or “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):

  1. 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.

  2. Our Disclosure and Sale of Personal Information – the types of recipients to whom we disclose or sell Personal Information.

  3. Our Business Purposes – our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.

  4. Your California Privacy Rights and Choices – what rights you have under the CCPA, for instance, to request that we “opt out” your information from 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 in the table below. The following table also describes how we collect and use such categories of information.

Category

Sources

Identifiers

Name; alias; postal address; online identifiers; IP address; email address; telephone number; or similar identifiers.

From data compilers and consumer data resellers, consumer goods retailers, informational and retail websites, public records and other publicly available sources, content publishers, non-profit organizations, business-to-business companies, consumer surveys and survey companies, affiliate networks and government entities. In addition, from advertising networks, internet service providers, data analytics providers, operating systems and platforms and social networks.

Characteristics of protected classifications under California or federal law

Race; color; religion; sex/gender; marital status; medical condition; military or veteran status; national origin; ancestry; disability; age.

From data compilers and consumer data resellers, consumer goods retailers, informational and retail websites, public records and other publicly available sources, content publishers, non-profit organizations, business-to-business companies, consumer surveys and survey companies, affiliate networks and government entities. In addition, from advertising networks, internet service providers, data analytics providers, operating systems and platforms and social networks.

Commercial or transactions information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; product types, total orders, paid, returned, cancelled, or written off, etc.

From data compilers and consumer data resellers, consumer goods retailers, informational and retail websites, public records and other publicly available sources, content publishers, non-profit organizations, business-to-business companies, consumer surveys and survey companies, affiliate networks and government entities. In addition, from advertising networks, internet service providers, data analytics providers, operating systems and platforms and social networks.

Internet or other electronic network activity information

Browsing history; online interests; and information on a consumer's interaction with a website, application, or advertisement.

From data compilers and consumer data resellers, consumer goods retailers, informational and retail websites, public records and other publicly available sources, content publishers, non-profit organizations, business-to-business companies, consumer surveys and survey companies, affiliate networks and government entities. In addition, from advertising networks, internet service providers, data analytics providers, operating systems and platforms and social networks.

Geolocation data

Latitude and longitude, census block group.

From data compilers and consumer data resellers, consumer goods retailers, informational and retail websites, public records and other publicly available sources, content publishers, non-profit organizations, business-to-business companies, consumer surveys and survey companies, affiliate networks and government entities. In addition, from advertising networks, internet service providers, data analytics providers, operating systems and platforms and social networks.

Professional or employment-related information

Current or past job history.

From data compilers and consumer data resellers, consumer goods retailers, informational and retail websites, public records and other publicly available sources, content publishers, non-profit organizations, business-to-business companies, consumer surveys and survey companies, affiliate networks and government entities. In addition, from advertising networks, internet service providers, data analytics providers, operating systems and platforms and social networks.

Inferences about your predicted characteristics and preferences

Inferences reflecting your preferences, characteristics, behavior, attitudes; and median age, wealth rating and median income.

From data compilers and consumer data resellers, consumer goods retailers, informational and retail websites, public records and other publicly available sources, content publishers, non-profit organizations, business-to-business companies, consumer surveys and survey companies, affiliate networks and government entities. In addition, from advertising networks, internet service providers, data analytics providers, operating systems and platforms and social networks.

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 customers. 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.

Category

Categories of Third Parties We Share With

Whether We “Sold” This Category of Personal Information in the Last 12 Months

Identifiers

Name; alias; postal address; online identifiers; IP address; email address; telephone number; or similar identifiers.

Agencies; Auto; Continuity; Data Provider; Digital Media; Financial Services; Health Services; Home and Personal Services; Media and Communications; Multi Channel Retail; Non-Profit; Other; Partner/Vendor; Publishing; Service Bureau; Travel/Hospitality (referred to below together as “Customer Categories”). Our service providers (as described in section 3 of the Privacy Policy), including for purposes of tech and customer support, marketing, data enhancement, billing, hosting, legal and accounting services (“Service Providers”).

Yes

Commercial or transactions information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; product types, total orders, paid, returned, cancelled, or written off, etc.

Agencies; Auto; Continuity; Data Provider; Digital Media; Financial Services; Health Services; Home and Personal Services; Media and Communications; Multi Channel Retail; Non-Profit; Other; Partner/Vendor; Publishing; Service Bureau; Travel/Hospitality.

Yes

Geolocation data

Latitude and longitude, census block group.

Digital Media.

Yes

Inferences about your predicted characteristics and preferences

Inferences reflecting your preferences, characteristics, behavior, attitudes; and median age, wealth rating and median income.

Agencies; Auto; Continuity; Data Provider; Digital Media; Financial Services; Health Services; Home and Personal Services; Media and Communications; Multi Channel Retail; Non-Profit; Other; Partner/Vendor; Publishing; Service Bureau; Travel/Hospitality. In addition, from advertising networks, internet service providers, data analytics providers, operating systems and platforms and social networks.

Yes

3. Our Business Purposes for Collecting and Sharing Personal Information

Generally speaking, we collect and share the Personal Information that we collect for the following purposes, as we also have described in our Privacy Policy, in the sections titled, “Our Services: Background”, “How We Use the Information”, and “How We Share Information with Third Parties, including Service Providers”:

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, fundraising, customer service and engagement, and outreach activities.

  • Helping our Clients identify and understand their customers better, by providing insights about them and managing loyalty programs, as well as providing financial and other scoring products.

  • Assisting our Clients with 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 (“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 work with a data partner that “matches” our or other Information through de-identification 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 and other media channels.

  • Assisting Clients in creating “identity” graphs, to help locate users across various channels, such as based on common personal, device-based, or network-based identifiers (e.g., IP address, email address).

Additional marketing services, for example:

  • 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.

  • 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, 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 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 our own website 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 about 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.)

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. If you would like to view your information, please follow this link.

b. Right to request deletion of your personal information

You may also request that we delete 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. If you would like to request deletion of your information, please follow this link. Although we attempt to comply with your requests and the requests of our partners that we collect your information from, we cannot guarantee that we will delete all of your information, and suggest that you opt-out to limit sharing, if you would like to reduce the amount of information sold about you.

c. How to exercise your access, opt-out and (if applicable) deletion rights

California residents may exercise their California privacy rights by submitting your request at this link, or by contacting us at (833) 926-0701.

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 your California privacy rights.  For instance, if you request categories or specific pieces of personal information we have received about you, you may need to confirm your possession of an identifier (such as an email address) or to provide a piece of identification that confirms you are the person you claim to be. For security reasons, any specific information we provide to you will be obfuscated.

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.

  • In some cases, we will seek to confirm whether your request is for an “opt out” or a “deletion” (“deletion” rights only apply to information that we have collected “from” consumers – which does not apply to much of the information in our databases.)

  • 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.

d. 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.

e. Right to Opt-out of the sale 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 in the definition 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, titled Our Disclosure and Sale of Personal Information.

If you would like to opt out, you may do so as outlined on the following page: Do Not Sell My Personal Information

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 also designate an agent to make requests to exercise your rights under CCPA as described above. We will 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.

If you are seeking to make a consumer information choice request on behalf of a third party as an authorized agent or with power of attorney, please submit the attached form for authorized agents, signed by the individual and by you. Both signatures must be notarized. If you are a company or other legal entity, submit official documents from the state where the individual resides showing your registration in the state. You must also send proof of power of attorney, if claiming such, valid under state law.

 If you are seeking to make a consumer information choice request on behalf of a family member, please submit the attached form for family members, signed by the individual and by you. Both signatures must be notarized.