Alliant Data Services and Website Privacy Policy

Additional Information for U.S. State Privacy Law State Residents

NOTICE TO U.S. STATE PRIVACY LAW STATE RESIDENTS

Certain U.S. States have passed privacy laws. This policy applies to those States, currently California, Colorado, Connecticut, Utah, Virginia and any other States that pass privacy laws (collectively STATE PRIVACY LAW) and provide certain rights to residents of those States. This section is intended solely for, and is applicable only as to, such State residents: if you are not a State resident of such a State, these provisions do not apply to you.

In the below tables and sections, we describe (as required by the STATE PRIVACY LAW):

 

  1. Our Collection of Personal Information – the types of Personal Information that we collect, the types of sources we collect it from.
  2. Our Disclosure, Sale or Sharing of Personal Information – the types of recipients to whom we disclose or sell or share Personal Information.
  3. Our Business Purposes – our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.
  4. Sensitive Personal Information – what Sensitive Personal Information is, and how you can limit the sharing of your Sensitive Personal Information.
  5. Your State Privacy Rights and Choices – what rights you have under the STATE PRIVACY LAW, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell or share” rights), or to request categories and personal information that we may have collected about you.
  6. Report pursuant to CA Implementing Regulations – As of July, 2022.

 

The following sets forth the categories of personal information that we collect and how we may use State resident’s 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

E.g., name; alias; postal address; online identifiers; IP address; email address; account name; 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, 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

E.g., race; color; religion; sex/gender; marital status; medical condition; veteran status; national origin; ancestry; disability; age; 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, 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

E.g., 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. 

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, 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

E.g., 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, 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

E.g. 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, 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

E.g., 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, 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

E.g., 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, affiliate networks and government entities. In addition, from advertising networks, internet service providers, data analytics providers, operating systems and platforms and social networks 

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 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

E.g., name; alias; postal address; online identifiers; IP address; email address; account name; 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

E.g., 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. 

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; Service Providers. 

 YES

Geolocation data

E.g. latitude and longitude, census block group, not used for identification. 

Digital Media; Service Providers 

 YES

Inferences about your predicted characteristics and preferences

E.g., 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; Service Providers.   

 YES

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 section 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 consumers better, by providing insights about them and managing loyalty programs, as well as providing financial and other scoring products.
  • Assisting our Clients who 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 marketing 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 online ad campaigns across various display, mobile and other media channels.
  • Assisting Clients in create “identity” graphs, to help locate users across various devices and 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 the above, as well as for our own marketing purposes.

  • The Personal Information that we collect may include Sensitive Personal Information. Certain jurisdictions have enacted laws that require higher protection of certain Sensitive Personal Information. Sensitive Personal Information includes categories of information identified by the applicable privacy laws as requiring special treatment or protection. This information may include, but is not limited to, precise location data, citizenship or immigration status, racial or ethnic origin; political opinions; religious, philosophical, or other similar beliefs; membership of a trade union or profession or trade association; physical or mental health; biometric data; or sexual orientation.
  • We do not collect, use, share or otherwise process Sensitive Personal Information unless permitted to do so by law. To comply with the strictist privacy laws, we require explicit consent before the “sale” or “share” of any Sensitive Personal Information.
  • If you want to limit the use of your Sensitive Personal Information you may do so by opting-out here.

State privacy law 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.)

a. Right to Opt-out of the sale of your personal information

State residents may opt out of the “sale” or “share”of their personal information.

Depending on what information we have about you, and whether we have included any of it in our marketing products and services, we may have sold or shared (as defined by State law) certain categories of information about you in the last 12 months, as described in the above table in Section II of this Addendum, titled Our Disclosure, Sale or Share of Personal Information.

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

b. Right to know/request access to your personal information

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

c. 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 also opt-out if you would like to reduce the amount of information sold or shared about you.

d. Right to correction/rectification 

You have a right to correct or update your personal data if it is inaccurate or incomplete.  You may exercise your rights by emailing our privacy team at compliance@alliantdata.com and include the incorrect information to be corrected and the correct information that you want added. Alternatively, you may request that the data be deleted at this link. For security purposes (and as required under State law), we will verify your identity – in part by requesting certain information from you — when you request to exercise your State privacy rights

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

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

For security purposes (and as required under State law), we will verify your identity – in part by requesting certain information from you – when you request to exercise your State 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 STATE PRIVACY LAW and provided we do not believe there is an overriding privacy or security concern to doing so.
  • In some cases, we will seek to cinform 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.

f. 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.

g. Information About Persons Under 16 Years of Age

We do not knowingly collect personal information from minors under 16 years of age unless we have received legal consent to do so. If we learn that personal information from such people has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).

h. Authorized Agents

You may also designate an agent to make requests to exercise your rights under your State privacy law. 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.

The California privacy law (CCPA and CPRA) requires certain businesses to compile and disclose metrics on an annual basis regarding their compliance with the law and Consumer rights requests. Alliant handled the following requests from State residents who submitted requests via our online portal, by phone or email as of July 31, 2022:

  Requests to Know Requests to Delete Requests to Opt-Out
Total Requests Received 7 6 3247
Number of requests complied with in whole 3 1 2379
Number of requests complied with in part 0 0 1
Number of requests denied due to inability to verify consumer 4 5 867
Average number of days to substantively respond 20.02 2.29 6.3

Last modified: December 31, 2022