Privacy Policy

20230127_rev01 · COMPARED WITH 20220416_rev01 · ARCHIVE SNAPSHOT, DATE APPROXIMATE

Full text changes — 20220416_rev01 to 20230127_rev01

1### 1) Scope of Privacy Policy
1Thank you for visiting an online service (e.g., website or mobile app) that posts a link to this Privacy Policy **("Service")** owned or operated by Interlaced Social LCC and its affiliates d/b/a Doublelist (**"DL"**, **"we,"** or **"us"** or **"our"**). DL has created this Privacy Policy because we value our members and recognize their right to keep personal information private.
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3The Doublelist.com ("DL") Privacy Policy may be found below. In this Privacy Policy, we describe the information that we collect about you, that you provide to us and will be processed by us as you use our website and services. Your use of the DL site, and services constitutes your acceptance of the terms and conditions of the DL Privacy Policy, of our [Terms of Use](https://doublelist.com/about/terms/) and of DL's [Community Guidelines](https://doublelist.com//guidelines/). You are responsible for reviewing and becoming familiar with all of these terms. By providing us with your personal data when using the DL site, services, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the DL site, mobile apps and services.
3The DL Privacy Policy may be found below. In this Privacy Policy, we provide you with information as to how DL collects, uses, and shares information about you, including the choices DL offers with respect to that information, and applies to your use of any Service, regardless of how you access or use it. It does not apply to DL's data collection activities offline or otherwise outside of the Service (unless otherwise stated below or at the time of collection). For certain Services, there may be additional notices about information practices and choices. Please read those additional privacy disclosures to understand how they apply to you.
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5DL has created this privacy policy because we value our members and recognize their right to keep personal information private. This statement discloses our information gathering and dissemination practices for the World Wide Web site located at www.Doublelist.com (the "DL"), and other services. We believe very strongly that private information should remain private. We'd like to hear your feedback about this statement. If you have comments or questions, please [Contact Us](https://help.doublelist.com/contact/).
5We are not responsible for information that you disclose to third parties, such as to other members of DL or other sites/apps throughout the Internet. By using the DL site or otherwise using the Service, you agree to the Service's [Terms of Use](https://doublelist.com/about/terms/), [Website Guidelines & Code of Conduct](https://doublelist.com/guidelines/),and [Prohibited](https://doublelist.com/about/prohibited/) List as well as DL's data collection, use, and disclosure practices, other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Service. If you do not agree and consent, please discontinue use of the Service and uninstall Service Downloads and applications.
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7Except as otherwise expressly discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties, whether they are other members of DL or other sites/apps throughout the Internet, different rules may apply to their use or disclosure of the personal information you disclose to them.
7### Your California and Nevada Privacy Rights
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9### 2) Information we collect and how we use it
9California and Nevada residents have certain privacy rights detailed in the Your State Privacy Rights section here.To the extent that there is a conflict between this Privacy Policy and the State Privacy Rights section, the State Privacy Rights section will control as to California and Nevada residents.
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11#### **Cookies**
11About Ads and Tracking: Learn about certain choices regarding Tracking Technologies, including certain sharing of activities, location and/or cross-device usage for interest-based advertising here.
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13Our Web site and services set cookies to administer our products, to gather broad demographic information, to deliver content requested by you or specific to your interests, to customize our site and services for you, and to save your username and city so that you don't have to enter it each time you visit.
13### TABLE OF CONTENTS
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15Some cookies expire after a certain amount of time, or upon logging out (session cookies), others remain on your computer or terminal device for a longer period (persistent cookies). Our site uses first party cookies (cookies set directly by DL) as well as third party cookies, as described below.
15To aid navigation, click on the section headings below:
1616
17**Type of Cookies Used**.
18The site and apps use the following technologies:
17**1\. Personal Information We Collect**
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20\- Strictly Necessary Cookies: Used to provide Users with the Services available through our Site to use some of their features, such as the ability to log-in and access to secure areas. These cookies are served by DL and are essential for using and navigating the Site. Without these cookies, basic functions of our Site would not work. Because these cookies are strictly necessary to deliver the Site and our Services, you cannot refuse them.
19**- Information About You That You Provide****- Registration Form****- Information Collected Automatically****- Information DL Collects From Other Sources****- Registration Form****- Control of Your Password****- Email Addresses and the Way Messaging Works**
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22\- Analytics/Performance: Used to better understand the behavior of the Users on our Site and improve our Site accordingly, for example by making sure Users are finding what they need easily. The Site use Google Analytics, a web analytic services. The information collected by Google (including your IP address) will be transmitted to and stored by Google on their secured servers. Some Google Analytics cookies expire at the end of your browser session, whilst others can remain for up to two years.
21**2\. How We Use the Information We Obtain**
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24Please note that if you limit the ability of our website and apps to set cookies, you may be unable to access certain parts of our services and you may not be able to benefit from the full functionality of DL.
23**- Generally****- Messaging**
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26If you access our services on your mobile device, you may not be able to control tracking technologies through the settings.
25**3\. Information We Share With Third Parties**
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28#### Registration Form
27**4\. Sweepstakes, Contests, and Promotions**
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30Membership on the DL Site and services is completely optional. DL's registration form requires users to give their email address. On our join form, required fields are marked. DL will never share e-mail addresses with third party organizations without your express permission.
29**5\. Information You Disclose Publicly or to Others**
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32Control of Your Password
31**6\. Third-Party Content, Third-Party Services, Social Features, Advertising & Analytics**
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34Do not disclose your password to any third parties nor share it with any third parties. If you lose control of your password, you may lose control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password. To change your password you can do so at any time through the Settings page then click Password, and the click Change Password.
33**7\. Data Security and Monitoring**
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36#### Email Addresses and The Way Messaging Works
35**8\. Children's Privacy**
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38You should be aware that DL does not currently have an on-site messaging capabilities. All messaging is done between users directly using their email addresses and email providers. When responding to a post that is posted on DL, DL will deliver your message via email to the post's poster. This message will be delivered along with an email address that you want the post Poster to respond to. The default email DL sends along with your message is the email that you originally used to sign up for an account on DL. This 'respond-to' email address can be changed by you to a different email address when you are sending a message. This allows you to provide a separate, more private email address users can respond to your message.
37**9\. International Transfer**
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40#### IP Addresses
39**10\. Accessing and Changing Information**
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42DL tracks individual IP addresses to help diagnose problems with our service, to administer our site and to gather broad information. User IP address information is used only for our internal purposes.
41**11\. Choices: Tracking and Communications Options**
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44#### Information We Receive From Your Use of Our service
43**- Tracking Technologies Generally****- Analytics and Advertising Tracking Technologies****- Mobile Apps****- Cross-Device Data**
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46When you use our services, the following information is created and automatically logged in our systems:
45**12.Your State Privacy Rights**
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48Log data: Information ("log data") that your browser or device automatically sends whenever you visit the site or apps when you use it. Log data includes your Internet Protocol ("IP") address (so we understand which country you are connecting from when you visit the site or app), browser type and settings, the date and time of your request, and how you interacted with our services.
47**a.California Residents**
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50Device information: Includes type of device you are using, operating system, settings, unique device identifiers, network information and other device-specific information. Information collected may depend on the type of device you use and its settings.
49**- Your California Privacy Rights Regarding Disclosures for Third-Party Marketing ("Shine the Light" Law)****- California Consumer Privacy Act of 2018 ("CCPA")**
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52**How we use information**
51**(1)Personal Information We Collect**
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54We use your personal data for the following purposes:
53**- Sources of Personal Information****- Uses of Personal Information****- Sharing of Personal Information**
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56To authenticate our users and provide our services. This processing is necessary to perform the contract with you. As necessary for certain legitimate business interests, which include the following:
55**(2)California Consumer Privacy Rights**
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58- To respond to your inquiries and fulfill your requests for products and services;
59- To send administrative information to you, for example, information regarding the site and changes to our terms, conditions, and policies;
60- To provide, maintain and improving the content and functionality of our services. For example, we regularly fix bugs or user experience issues that may be tied to particular user accounts.
61- If you ask us to delete your data and we are required to fulfill your request, to keep basic data to identify you and prevent further unwanted processing;
62- To prevent fraud or criminal activity, misuses of our products or services, and ensure the security of our IT systems, architecture and networks;
63- To (a) comply with legal obligations and legal process, (b) respond to requests from public and government authorities including public and government authorities outside your country of residence; (c) enforce our Terms of Use; (d) protect our operations or those of any of our affiliates; (e) protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain, as required or permitted by the law.
64- For individuals in the EU, please see the "European Union (EU) Users" section below for information on what we mean by legitimate interests and your rights.
57**(a)Right to Know**
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66#### Publicly posted information
59**- Categories****- Specific Pieces**
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68This Privacy Policy shall not apply to any information you post to the public areas of our services. Posts posted to public areas may be viewed, accessed, and used by third parties subject to those parties' privacy practices and policies.
61**(b) The Right to Delete**
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70### 3) When and why we share information
63**(c) Do Not Sell**
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72Notwithstanding anything else in this policy, DL may also disclose personal and aggregate information when required by a valid legal mechanism such as a search warrant, subpoena, or court order, or when we deem it necessary, in our sole discretion, to protect our rights and the safety of others, or our members, employees, or properties.
65**(d) Non-Discrimination and Financial Incentive Programs**
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74DL believes that members' private communications in e-mail conversations should generally remain confidential. DL does not disclose private communications unless ordered to do so through a valid legal mechanism such as a search warrant, subpoena, or court order, to protect the company's rights and property, or during emergencies when we believe safety is at risk. Please remember that what you write or post in public areas such as posts is available to all DL members, and in many cases other visitors to the DL site. Also keep in mind that DL is not responsible for what other users may do with private communications you've had with them.
67**(3) How to Submit a Request Under the CCPA**
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76We may share or disclose your information at your direction, such as when you authorize a third-party service to access your account or when you voluntarily share information or content via our services. Other Users may share or disclose information about you, such as when they mention you.
69**(a) Methods to Submit a Request**
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78There are certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, unless required by the law, as set forth below:
71**(b) Authorized Agents**
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80- Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions: providers of hosting, email communication and customer support services, analytics, marketing, advertising. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us.
81- Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.
82- Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) act in urgent circumstances to protect the personal safety of Users of the Site, or the public, or (iv) protect against legal liability.
73**(4) Limitation of Rights**
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84### 4) Your rights and choices
75**b. Nevada Residents**
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86**OFF-SITE LINKS**
77**13\. Changes to This Privacy Policy**
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88The site and apps may contain links to other websites and apps not operated or controlled by us ("Third Party Sites"). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites or apps. Please contact those sites directly for information on their privacy practices and policies. DL is not responsible for the privacy practices or contents of these other sites.
79**14\. Contact Us**
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90### 5) Data retention
81### 1\. PERSONAL INFORMATION WE COLLECT.
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92We will keep your Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.
83##### a. Information About You That You Provide.
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94To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.
85DL and/or its Service Providers (defined below) may collect information you provide directly to DL and/or its Service Providers via the Service. For example, DL collects information when you set up an account and thereafter when you use the Service, subscribe to notifications, or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Third-Party Services' data collection and practices, click here. For more information on Service Provider data collection and practices click here.
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96### 6) Security
87Information DL, its Service Providers and/or Third-Party Services may collect may include: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, address, and full payment account number **("Personally Identifiable Information" or "PII")**; and (2) demographic information, such as your gender, age, zip code, interests, and recent and upcoming purchases
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98DL implements security measures to help protect your data from loss, theft, misuse and unauthorized access. We take data privacy and security seriously. However, no physical or electronic security system is impenetrable, but all information you provide to us is stored on secured servers.DL takes steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free.
89("Demographic Information")
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100You use our services at your own risk. We can't guarantee the security of the Service's servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet and any transmission is at your own risk.
91. Except to the extent required by applicable law, Demographic Information is
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102We cannot control the actions of other users with whom you may choose to share information. Therefore, we cannot, and do not, guarantee that information or content posted by a user on or through our Services will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on our Services. We ask you not to share a password with anyone.
93"non-Personally Identifiable Information"
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104### 7) Changes to Policy
95or
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106We may update this policy from time to time. If we make any significant changes to the way in which we treat your personal information, we will inform you of such changes via e-mail or by posting a notice on the DL site. If you have any questions about this privacy policy, please feel free to [Contact Us](https://help.doublelist.com/contact/).
97"non-PII"
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108### 8) How you can access your personal information and update your information
99(i.e., data that is not Personally Identifiable Information under this Privacy Policy). In addition, Personally Identifiable Information, including, without limitation, DL-Collected PII (defined below), once **"De-identified"** (i.e., the removal or modification of the personally identifiable elements, or the extraction of non-personally identifiable elements, including through anonymization, pseudonymization, and/or hashing) is also non-Personally Identifiable Information and may be used and shared without obligation to you, except as prohibited by applicable law. However, we do not make assurances that De-identified data is not capable of re-identification. To the extent any non-Personally Identifiable Information, or PII collected outside of the Service, is combined by or on behalf of DL with Personally Identifiable Information DL itself collects directly from you on the Service ("DL-Collected PII"), DL will treat the combined data as DL-collected PII under this Privacy Policy. The definition of "personal information" under certain state laws differs from the definition of PII used in this Privacy Policy. California and Nevada residents can learn more about their privacy rights here.
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110You can access some of the personal information that we collect about you by logging in to your account. You also have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data.
101##### b. Information Collected Automatically.
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112If you need to change or correct your Personal Data, or wish to have it deleted from our systems, you may also contact us. Please send all requests for data deletion to privacy@doublelist.com. We will address your request as required by applicable law. You may also update your Personal Data from your user settings.
103DL, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service **("Usage Information")**. Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of DL with DL-Collected PII, DL does not consider Usage Information (including, without limitation, unique device identifiers) to be Personally Identifiable Information or DL-Collected PII. For more information on Third-Party Services' data collection and practices click here. For more information on Service Provider data collection and practices click here. For information on choices some of these third parties may offer you regarding automated data collection click here.
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114### 9) Information about children
105The methods that may be used on the Service to collect Usage Information include:
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116Our services are not available to anyone who is not at least 18 years of age. If you are not at least 18 years of age, you are not permitted to become a Member or use our services.
107- **Log Information:**Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
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118If you are aware that a child or minor uses our services please contact us using the information provided below so we can take appropriate actions.
109- **Information Collected by Cookies and Other Tracking Technologies:**Cookies, web beacons (also known as "tracking pixels"), embedded scripts, location-identifying technologies, device recognition technologies, in-app tracking methods, device and activity monitoring and other tracking technologies now and hereafter developed ("Tracking Technologies") may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior.
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120### 10) European and international users
111**Note the Links Above Should be Enabled and Should Go to the Following:**
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122DL is based in the USA. If you are accessing our Services from the European Union or other regions with laws governing data collection and use, please note that your Personal Data will be transmitted to our servers in the USA and the data may be transmitted to our service providers supporting our business operations (described above). Canada may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. Where we transfer your Personal Data out of the EU we will take steps to ensure that your Personal Data receives an adequate level of protection where it is processed, and your rights continue to be protected.
113- **Cookies:** A cookie is a small text file that is stored on a user's device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser's method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features, and functionalities of the Service may not work.
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124By providing your information to the Services you agree to the transfer of your information to the USA and processing globally in accordance with this Privacy Policy.
115- **Web Beacons ("Tracking Pixels"):** Web beacons are small graphic images, also known as "Internet tags" or "clear gifs," embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
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126### 11) Contacting Us
117- **Embedded Scripts:** An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from DL's web server, or from a third party with which DL works and is active only while you are connected to the Service and deleted or deactivated thereafter.
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128If you have any questions about this privacy statement, the practices of this site, or your dealings with this site, please feel free to [Contact Us](https://help.doublelist.com/contact/).
119- **Location-Identifying Technologies:** GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate you (sometimes precisely), or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content, including third party ads, based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked by us and third parties.
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130### 12) California Privacy Disclosure
121- **Device Recognition Technologies:** Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) **("Cross-Device Data")**.
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132Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent.
123- **In-App Tracking Methods:** There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as "Ad IDs," or may use "SDKs," to associate app user activity to a particular app and to track user activity across apps and/or devices. SDKs are blocks of code that may be installed in our mobile application by third party companies with which we work. SDKs help us understand how you interact with our mobile application and collect certain information about the device and network you use to access our application, such as the advertising identifier associated with your device and information about how you interact with our application.
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134This Privacy Notice for California Residents supplements the information contained in Doublelist.com's (DL) Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California. We adopted this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.
125- **Devices and Activity Monitoring:** Technologies that monitor, and may record, certain of your interactions with the Service, and/or collect and analyze information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes such as identification, security, fraud prevention, troubleshooting, tracking and/or improving the Services and customizing or optimizing your experience on the Services.
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136#### a) Information We Collect
127Some information about your use of the Service and certain other online services may be collected using Tracking Technologies across time and services and used by DL and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Service and certain other online services. See Section 11 regarding certain choices regarding these activities.
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138Our website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, our website have collected the following categories of personal information from its consumers within the last twelve (12) months:
129DL is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 11 so that your consent to encountering them is meaningfully informed.
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140<table><tbody><tr><td><p><strong>Category</strong></p></td><td><p><strong>Examples</strong></p></td><td><p><strong>Collected</strong></p></td></tr><tr><td><p>A. Identifiers.</p></td><td><p>A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.</p></td><td><p>YES</p></td></tr><tr><td><p>B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).</p></td><td><p>A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.</p></td><td><p>YES</p></td></tr><tr><td><p>C. Protected classification characteristics under California or federal law.</p></td><td><p>Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).</p></td><td><p>YES</p></td></tr><tr><td><p>D. Commercial information.</p></td><td><p>Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.</p></td><td><p>NO</p></td></tr><tr><td><p>E. Biometric information.</p></td><td><p>Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.</p></td><td><p>NO</p></td></tr><tr><td><p>F. Internet or other similar network activity.</p></td><td><p>Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.</p></td><td><p>YES</p></td></tr><tr><td><p>G. Geolocation data.</p></td><td><p>Physical location or movements.</p></td><td><p>YES</p></td></tr><tr><td><p>H. Sensory data.</p></td><td><p>Audio, electronic, visual, thermal, olfactory, or similar information.</p></td><td><p>NO</p></td></tr><tr><td><p>I. Professional or employment-related information.</p></td><td><p>Current or past job history or performance evaluations.</p></td><td><p>NO</p></td></tr><tr><td><p>J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).</p></td><td><p>Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.</p></td><td><p>NO</p></td></tr><tr><td><p>K. Inferences drawn from other personal information.</p></td><td><p>Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.</p></td><td><p>NO</p></td></tr></tbody></table>
131##### c. Information DL Collects From Other Sources.
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142#### b) Use of Personal Information
133DL may also obtain information about you from other sources, including Service Providers and Third-Party Services, and combine that with DL-Collected PII. Notwithstanding anything to the contrary, except to the extent such data is combined by or on behalf of DL with DL-Collected PII, this Privacy Policy is not intended to limit DL's activities regarding such third-party-sourced, or non-Service-sourced, information (including Personally Identifiable Information), and such data will only be treated as DL-Collected PII to the extend it is combined with DL-collected PII. DL is not responsible or liable for the accuracy of the information provided by third parties or for third party policies or practices.
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144We may use or disclose the personal information we collect for one or more of the following business purposes:
135Return to navigation
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1461. To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
1472. To process your requests, purchases, transactions, and payments and prevent transactional fraud.
1483. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
1494. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
1505. As described to you when collecting your personal information or as otherwise set forth in the CCPA.
1516. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our or our affiliates' assets in which personal information held by us or our affiliates about our website users is among the assets transferred.
1527. We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.
1538. Sharing Personal Information
137### 2\. HOW WE USE THE INFORMATION WE OBTAIN.
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155We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
139**Generally.**
156140
157We share your personal information with the following categories of third parties:
141DL may use information about you, including DL-Collected PII and other Personally Identifiable Information, for any purposes not inconsistent with DL's statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including, without limitation, the following:
158142
159- Service providers.
143- Allow you to participate in the features we offer on the Service;
144- Facilitate, manage, personalize, and improve your online experience;
145- Process your registration, manage your account and/or upload your User Generated Content **("UGC")**. (For more information on how UGC is treated under the Service's Terms of Use click here . For more on the public nature of UGC, see Section 5;
146- Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices;
147- Improve the Service and for any other internal business purposes;
148- Tailor our content, advertisements, and offers;
149- Fulfill other purposes disclosed at the time you provide Personally Identifiable Information or otherwise where we are legally permitted or are required to do so;
150- Determine your location and manage digital content rights (e.g., territory restrictions); and
151- Prevent and address fraud, breach of policies or terms, and threats or harm.
160152
161#### c) Your Rights and Choices
153Return to navigation
162154
163The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
155### 3\. INFORMATION WE SHARE WITH THIRD PARTIES.
164156
165Access to Specific Information and Data Portability Rights
157Except as restricted by applicable law, this Privacy Policy, or any other representation DL makes to you, DL may share non-Personally Identifiable Information, and Personally Identifiable Information that is not deemed DL-Collected PII hereunder (provided that DL is aware of no restrictions of DL's use, if any), with third parties for any purpose. Without limiting the generality of the foregoing, we and third parties may convert your Personally Identifiable Information, including DL-Collected PII, to non-Personally Identifiable Information, including without limitation through hashing it or substituting a unique identifier for the Personally Identifiable Information and we and third parties may use and share that data as permitted by applicable law, including to match data attributes to and from other sources. Any such third-party activities are subject to their privacy policies and practices. DL's sharing of DL-Collected PII is, however, subject to the following:
166158
167You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
159- **Marketing:** Subject to your communications choices explained in Section 11.D, and the rights of California and Nevada residents explained here, we may use your Personally Identifiable Information to send you marketing communications. Absent your consent (which may be by means of opt-in or a third party interaction described in the next bullet point), however, DL will not share your DL-Collected PII with third parties, for their own direct marketing purposes, except in connection with Corporate Transactions (defined below).
168160
169- The categories of personal information we've collected about you.
170- The categories of sources for the personal information we've collected about you.
171- Our business or commercial purpose for collecting or selling that personal information.
172- The categories of third parties with whom we share that personal information.
173- The specific pieces of personal information we've collected about you (also called a data portability request).
161- **Your Disclosure or Consent:** As more fully described in Section 5 (Information You Disclose Publicly or to Others) and Section 6 (Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics), your activities on the Service may, by their nature, result in the sharing of your DL-Collected Personally Identifiable Information (as well as your other Personally Identifiable Information and your non-Personally Identifiable Information) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties. Such third-party data receipt and collection is subject to the privacy and business practices of that third party, not DL.
174162
175If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
163DL may also share any information about you (including, without limitation, DL-Collected PII) for any purposes not inconsistent with this Privacy Policy, or our written statements at the point of collection, and otherwise not prohibited by applicable law, including, without limitation as follows:
176164
177- sales, identifying the personal information categories that each category of recipient purchased; and;
178- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
165- DL's agents, vendors, consultants, and other service providers (collectively **"Service Providers"**) may receive, or be given access to, your information,including, without limitation, Personally Identifiable Information, Demographic Information, and Usage Information, in connection with their work on DL's behalf, provided however, DL does not authorize its Service Providers to use DL-Collected PII provided by DL to the Service Providers to send you direct marketing messages other than related to DL absent your consent. For more information on choices Service Providers may offer you click here.
179166
180**Deletion Request Rights**
167- To comply with the law, law enforcement or other legal process, and, where permitted, in response to a government request; and .
181168
182You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
169- If DL believes your actions are inconsistent with DL's Terms of Use, user agreements, applicable terms or policies, or to protect the rights, property, life, health, security and safety of DL, the Service or its users, or any third party.
183170
184We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
171- In addition, DL may share your DL-Collected Personally Identifiable Information (as well as your other Personally Identifiable Information and your non-Personally Identifiable Information), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of DL assets, or transfer of all or a portion of DL's business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding **("Corporate Transactions")**.
185172
186- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
187- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
188- Debug products to identify and repair errors that impair existing intended functionality.
189- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
190- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
191- Comply with a legal obligation.
192- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
193- Exercising Access, Data Portability, and Deletion Rights
173Return to navigation
194174
195To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
175### 4\. SWEEPSTAKES, CONTESTS, AND PROMOTIONS.
196176
197 Emailing us at [privacy@doublelist.com](mailto:privacy@doublelist.com)
177DL may offer sweepstakes, contests, and other promotions (each, a **"Promotion"**), including Promotions jointly sponsored or offered by third parties, which may require submitting Personally Identifiable Information. If you voluntarily choose to enter a Promotion, your information, including Personally Identifiable Information, may be disclosed to DL, co-sponsors, Service Providers, and other third parties, including for administrative purposes and as required by law (e.g., on a winners list). By entering, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing data practices from those contained in this Privacy Policy. Please review those rules carefully.
198178
199Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
179Return to navigation
200180
201- You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
202- Provide enough information that allows us to reasonably verify you are the person about whom we've collected personal information or an authorized representative.
203- Describe your request with enough detail that allows us to properly understand, evaluate, and respond to it.
181### 5\. INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS..
204182
205We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
183The Service may permit you to post or submit UGC including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personally Identifiable Information. If you choose to submit UGC to any public area of the Service, your UGC will be considered "public" and will be accessible by anyone, including DL. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personally Identifiable Information included in UGC is not subject to DL's usage or sharing limitations, or other obligations, regarding DL-Collected PII or other Personally Identifiable Information under this Privacy Policy or otherwise, and may be used and shared by DL and third parties to the fullest extent not prohibited by applicable law. DL encourages you to exercise caution when making decisions about what you disclose in such public areas. For more information on how UGC is treated under the Service's Terms of Use click [here]().Although use of the Service is restricted to adults, California minors should see Section 13 of the Terms of Use regarding potential removal of certain UGC they have posted on the Service.
206184
207Making a verifiable consumer request does not require you to create an account with us.
185Additionally, the Service may offer you the option to send a communication to a friend or other contact. If so, DL relies on you to only send to people that have given you permission to do so. The recipient's Personally Identifiable Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by DL for any other marketing purpose unless DL obtains consent from that person. Your contact information and message may be included in the communication.
208186
209We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
187Return to navigation
210188
211**Response Timing and Format**
189### 6\. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING & ANALYTICS.
212190
213We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
191The Service may include or link to third-party websites, apps, locations, platforms, code (e.g., plug-ins, application programming interfaces **("API")**, and software development kits **("SDKs"))** or other services **("Third-Party Service(s)")**. These Third-Party Services may use their own cookies, web beacons, and other Tracking Technologies to independently collect information about you and may solicit Personally Identifiable Information from you.
214192
215We will deliver our written response by mail or electronically, at your option.
193Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third party social networks **("Social Features")**. Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; "liking" or "sharing" DL's content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see [Section 5]()) or by the Third-Party Service that you use. Similarly, if you post information on a Third-Party Service that references the Service (e.g., by using a hashtag associated with DL in a tweet or status update), your post may be used on or in connection with the Service or otherwise by DL. Also, both DL and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
216194
217Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
195DL may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on other online services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the Internet, which may include use of precise location and/or Cross-device Data, sometimes referred to as "interest-based advertising" and "online behavioral advertising" **("Interest-based Advertising")**, which may include sending you an ad on another online service after you have left the Service (i.e., "retargeting"). We may use Microsoft and Google for advertising services. See Section 11 for more information on your choices regarding certain personalized advertising.
218196
219We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
197DL may use Google Analytics, Adobe Analytics or other Service Providers for analytics services. These analytics services may use cookies and other Tracking Technologies to help DL analyze Service users and how they use the Service. Information generated by these analytics services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the Service, compiling statistic reports on the Service's activity, and providing other services relating to Service activity and other Internet usage. See Section 11 for more information on your choices regarding these services.
220198
221**Personal Information Sales**
199DL is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Service, and encourages you to familiarize yourself with and consult their privacy policies and terms of use. See Section 11 for more on certain choices offered by some third parties regarding their data collection and use, including regarding Interest-based Advertising and analytics.
222200
223We will not sell your personal information to any party. If in the future, we anticipate selling your personal information to any party, we will provide you with the opt-out and opt-in rights required by the CCPA.
201Return to navigation
224202
225#### 4) Non-Discrimination
203### 7\. DATA SECURITY AND MONITORING.
226204
227- We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
228- Deny you goods or services.
229- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
230- Provide you a different level or quality of goods or services.
231- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
205DL takes reasonable measures to protect DL-Collected PII (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and DL does not guarantee the security of your information collected through the Service.
232206
233#### 5) Other California Privacy Rights
207To help protect you and others, DL and its Service Providers may (but make no commitment to) monitor use of the Service, and may collect and use related information including DL-Collected PII and other Personally Identifiable Information for all purposes not prohibited by applicable law or inconsistent with this Privacy Policy, including, without limitation, to identify fraudulent activities and transactions; prevent abuse of, and investigate and/or seek prosecution for, any potential threats to or misuse of the Service; ensure compliance with the [Terms of Use](https://doublelist.com/about/terms/) and this Privacy Policy; investigate violations of or enforce these documents; improve the Services and your Services experiences, and to protect the rights and property of DL, third parties, and other users. Monitoring may result in the collection, recording, and analysis of online activity or communications through our Service. If you do not consent to these conditions, you must discontinue your use of the Service.
234208
235California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [privacy@doublelist.com](mailto:privacy@doublelist.com)
209Return to navigation
236210
237#### 6) Changes to Our Privacy Notice
211### 8\. CHILDREN'S PRIVACY.
238212
239We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice's effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
213The Service is intended for adults and not directed to individuals that are not at least 18 years of age (or 21 years of age in places where 18 years is not the age of majority). In addition, the Service is not available to anyone who is not at least 18 years of age (or 21 years of age in places where 18 years is not the age of majority). If you are not at least 18 years of age, you are not permitted to become a member, or to directly or indirectly view, possess, or otherwise use the Service.
240214
241#### 7) Contact Information
215If you are aware that a child or minor uses the Service, please contact us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#2656544f5047455f66424953444a434a4f55520845494b) or using the information provided below so we can take appropriate actions.
242216
243If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
217DL does not intend to collect personal information as defined by the U.S. Children's Online Privacy Protection Act **("COPPA") ("Children's Personal Information")** in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children's Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.
244218
245[privacy@doublelist.com](mailto:privacy@doublelist.com)
219Return to navigation
220
221### 9\. INTERNATIONAL TRANSFER.
222
223DL is based in the U.S. and the information DL and its Service Providers collect is governed by U.S. law. If you are located in the European Union (EU), European Economic Area (EEA), and/or Switzerland, please note that DL does not intend to offer goods and services (include the Service) to EU, EEA, or Swiss individuals. The U.S. may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence.
224
225Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personally Identifiable Information, in the U.S. as set forth in this Privacy Policy.
226
227Return to navigation
228
229### 10\. ACCESSING AND CHANGING INFORMATION.
230
231DL may provide web pages or other mechanisms allowing you to delete, correct, or update some of the DL-Collected PII, and potentially certain other information about you (e.g., profile and account information). DL will make good faith efforts to make requested changes in DL's then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from DL's databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required or permitted by applicable law; (b) to enforce our Terms of Use, and (c) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
232
233Return to navigation
234
235### 11\. CHOICES: TRACKING AND COMMUNICATIONS OPTIONS.
236
237**a. Tracking Technologies Generally.**
238
239Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Please be aware that if you disable or remove certain Tracking Technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
240
241Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.
242
243Your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, there is no consensus among industry participants as to what "Do Not Track" means in this context. Like many online services, DL currently does not alter DL's practices when DL receives a "Do Not Track" signal from a visitor's browser. To find out more about "Do Not Track," you can visit[http://www.allaboutdnt.com](http://www.allaboutdnt.com/), but DL is not responsible for the completeness or accuracy of this third party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. DL is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section. We may, from time-to-time, and in certain jurisdictions, offer or point you to tools that allow you to exercise certain preferences regarding cookies and other Tracking Technologies associated with the Services, but such tools rely on third parties and third party information so we do not guaranty that the tools will provide complete and accurate information or be completely effective. For instance, here is where you can find cookie controls for popular browsers:
244
245- **Google Chrome**
246- **Firefox**
247- **Internet Explorer**
248- **Edge**
249- **Safari**
250
251We do not represent that these third-party tools, programs or statements are complete or accurate. You will need to do this on each browser that you use to access our Services, and clearing cookies on your browser(s) may disable your preference settings. Also, our Services may not function properly or as intended if you block all or even certain cookies. Accordingly, you may want to consider the more limited opt-out choices noted in the next section.
252
253**b. Analytics and Advertising Tracking Technologies.**
254
255You may exercise choices regarding the use of cookies from Google Analytics by going to [https://tools.google.com/dlpage/gaoptout](https://tools.google.com/dlpage/gaoptout) or downloading the Google Analytics Opt-out Browser Add-on. You may exercise choices regarding the use of cookies from Adobe Analytics by going to [http://www.adobe.com/privacy/opt-out.html](https://www.adobe.com/privacy/opt-out.html) under the section labeled "Tell our customers not to measure your use of their web sites or tailor their online ads for you."
256
257You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance's **("DAA")** Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit [http://www.aboutads.info/choices/](http://www.aboutads.info/choices/,), and [http://www.aboutads.info/appchoices](http://www.aboutads.info/appchoices) for information on the DAA's opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative **("NAI")**. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. DL supports the ad industry's [Self-regulatory Principles for Online Behavioral Advertising](https://www.iab.com/wp-content/uploads/2015/05/ven-principles-07-01-09.pdf) and expects that ad networks DL directly engages to serve you Interest-based Advertising will do so as well, though DL cannot guaranty their compliance.
258
259We may also use Microsoft Advertising Services. To learn about the data Microsoft collects and how your data is used by it and to opt-out of certain Microsoft browser Interest-based Advertising, please visit here.
260
261We may also use Google Ad Services. To learn more about the data Google collects and how your data is used by it and to opt-out of certain Google browser Interest-Based Advertising, please visit here.
262
263In addition, we may serve ads on other online services that are targeted to reach people on those services that are also identified on one of more of our data bases **("Matched List Ads")**. This is done by using Tracking Technologies or by matching common factors between our data bases and the data bases of the other online services. For instance, we may use such ad services offered by Twitter and other Third-Party Services. We are not responsible for these Third-Party Services, including without limitation their security of the data. If we use Twitter Matched List Ads, you should be able to review your ad options in account settings on Twitter. We are not responsible for such third parties' failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.
264
265DL is not responsible for effectiveness of, or compliance with, any third-parties' opt-out options or programs or the accuracy of their statements regarding their programs.
266
267##### c. Communications.
268
269You can opt out of receiving certain promotional communications (emails or text messaging) from DL at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; and (ii) for text messages, following the instructions provided in text messages from DL to text the word, "STOP". Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, DL may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or DL's ongoing business relations
270
271##### d. Cross-Device Data.
272
273To learn more about how you can exercise certain choices regarding Cross-device data for Interest-based Advertising, see the prior section regarding the DAA's Interest-based Advertising choices.
274
275Return to navigation
276
277### 12\. YOUR STATE PRIVACY RIGHTS.
278
279##### a. California Residents.
280
2811. **Your California Privacy Rights Regarding Disclosures for Third-Party Marketing **("Shine the Light" Law)**.**
282
283We do not share personal information as defined by California Civil Code Section 1798.83 **("Shine the Light Law")** with third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#1b6b69726d7a78625b7f746e79777e7772686f35787476) or by sending a letter to Doublelist; ATTN: Legal Department, 2261 Market Street #4626, San Francisco, CA 94114. Any such request must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.
284
2854. **California Privacy Notice.**
286
287**Effective Date of Notice:** January 1, 2022
288
289This California Privacy Notice **("Notice")** applies to **"Consumers"** as defined by the California Consumer Privacy Act (together with its regulations, the **"CCPA")** as a supplement to DL's Privacy Policy and any other privacy policies or notices. In the event of a conflict between any other DL policy, statement or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA. Please see also any the general privacy policy or notice posted or referenced on our websites, apps, products, or services.
290
291Consistent with the CCPA, Section (1) of this Notice covers our collection, use, disclosure, and sale of California Consumers' "Personal Information" **("PI")** as defined by the CCPA, except to the extent such PI is exempt from the notice obligations of the CCPA for the twelve months preceding the Effective Date and will be updated annually. Our current privacy notices at the point of collection, as well as our general privacy policies and other privacy notices may reflect practices that are more current. Section (2) of this Notice explains the rights California Consumers have under the CCPA.
292
293Consistent with the CCPA, job applicants, current and former employees and independent contractors **("Personnel")**, and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered "Consumers" for purposes of this California Privacy Notice or the rights described herein. Publicly available information is also not treated as PI under the CCPA, so this notice is not intended to apply to that data and your Consumer privacy rights do not apply to that data. Terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.
294
295##### (1) Personal Information We Collect.
296
297In 2021, we collected, retained, used, and disclosed PI about California Consumers as follows:
298
299<table><tbody><tr><td><p><b><b>Category of PI</b></b></p></td><td><p><b>Examples of PI</b></p></td></tr></tbody></table>
300
301<table><tbody><tr><td><p><b>Identifiers</b></p></td><td><p>This may include but is not limited to: a real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.</p></td></tr><tr><td><p><b>Personal Records</b></p></td><td><p>This may include information such as: physical characteristics or description, signature, telephone number, zip code, city, billing address, credit card number, debit card number, or any other financial information.</p></td></tr><tr><td><p><b>Personal Characteristics or Traits</b></p></td><td><p>This may include, but is not limited to: sex, marital status, gender identity, and creed.</p></td></tr><tr><td><p><b>Customer Account Details/Commercial Information</b></p></td><td><p>This may include, but is not limited to: records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. .</p></td></tr><tr><td><p><b>Internet Usage Information</b></p></td><td><p>This may include, but is not limited to: browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement.</p></td></tr><tr><td><p><b>Geolocation Data</b></p></td><td><p>This may include, but is not limited to: precise physical location or movements and travel patterns.</p></td></tr><tr><td><p><b>Sensory Data</b></p></td><td><p>This may include, but is not limited to: audio recordings of customer care calls.</p></td></tr><tr><td><p><b>Inferences from PI Collected</b></p></td><td><p>This may include, but is not limited to: creating a profile about a Consumer reflecting the Consumer's preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.</p></td></tr></tbody></table>
302
303The chart above reflects that categories of PI required by the CCPA. There may be additional information that we collect that meets the CCPA's definition of PI but is not reflected by a category, in which case we will treat it as PI as required by the CCPA, but will not include it when we are required to describe our practices by category of PI.
304
305As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information, and may elect not to treat publicly available information as PI. We have no obligation to re-identify information or keep it longer than we need it to respond to your requests.
306
307##### (a) Sources of Personal Information.
308
309We may collect your PI directly from you or from your devices, and from service providers, as well as public sources of data
310
311##### (b) Uses of Personal Information.
312
313Generally, we collect, retain, use, and share your PI to provide you services and as otherwise related to the operation of our business. For more detail on our disclosures and sale of PI, see the next section.
314
315We may collect, use and share the PI we collect for one or more of the following business purposes:
316
317- Processing Interactions and Transactions;
318- Managing Interactions and Transactions;
319- Performing Services;
320- Research and Development;
321- Quality Assurance;
322- Security; and
323- Debugging.
324
325Additional business purposes include sharing PI with third parties for other than a sale or one of the foregoing business purposes as required or permitted by applicable law, such as to our vendors that perform services for us, to the government or private parties to comply with law or legal process, and to the consumer or other parties at the consumer's request, and for the additional purposes explained in our Privacy Policy, and to assignees as part of an acquisition, merger, asset sale, or other transaction where a third party assumes control over all or part of our business **("Other Business Purposes")**.
326
327Subject to restrictions and obligations of the CCPA, our vendors may also use your PI for some or all of the above listed business purposes. Our vendors may themselves engage services providers or subcontractors to enable them to perform services for us,which sub-processing is, for purposes of certainty, an Other Business Purpose for which we are providing you notice.
328
329We may collect and use your PI for commercial purposes, such as for interest-based advertising.
330
331In addition, we may collect, retain, and use PI for the purpose of sharing it as set forth in the next section.
332
333##### (c) Sharing of Personal Information.
334
335In 2021, we disclosed PI about California Consumers to our service providers, other vendors, including those that facilitate interest-based and other advertising and marketing and/or other third parties, including without limitation as follows:
336
337<table><tbody><tr><td><p><b><b>Category of PI</b></b></p></td><td><p><b>Categories of Recipients</b></p></td></tr></tbody></table>
338
339<table><tbody><tr><td><p><b>Identifiers</b></p></td><td><p><b>Business Purpose Disclosure:</b></p><ul><li>Service Providers (e.g., IT service providers, marketing service providers, security providers)</li><li>Third Parties (where the disclosure is not a sale, e.g., Other Business Purposes)</li></ul><p><b>Sale:</b> Cookie Operators (as defined in the Do Not Sell section below)</p></td></tr><tr><td><p><b>Personal Records</b></p></td><td><p><b>Business Purpose Disclosure:</b> Third Parties (where the disclosure is not a sale, e.g., Other Business Purposes)</p><p><b>Sale:</b> Not Sold</p></td></tr><tr><td><p><b>Personal Characteristics or Traits</b></p></td><td><p><b>Business Purpose Disclosure:</b></p><ul><li>Service Providers</li><li>Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes)</li></ul><p><b>Sale:</b> Not Sold</p></td></tr><tr><td><p><b>Customer Account Details/Commercial Information</b></p></td><td><p><b>Business Purpose Disclosure:</b></p><ul><li>Service Providers</li><li>Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes)</li></ul><p><b>Sale:</b> Not Sold</p></td></tr><tr><td><p><b>Internet Usage Information</b></p></td><td><p><b>Business Purpose Disclosure:</b></p><ul><li>Service Providers</li><li>Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes)</li></ul><p><b>Sale:</b> Cookie Operators (as defined in the Do Not Sell section below)</p></td></tr><tr><td><p><b>Geolocation Data</b></p></td><td><p><b>Business Purpose Disclosure:</b></p><ul><li>Service Providers</li><li>Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes)</li></ul><p><b>Sale:</b> Cookie Operators (as defined in the Do Not Sell section below)</p></td></tr><tr><td><p><b>Sensory Data</b></p></td><td><p><b>Business Purpose Disclosure:</b></p><ul><li>Service Providers</li><li>Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes)</li></ul><p><b>Sale:</b> Not Sold</p></td></tr><tr><td><p><b>Inferences from PI Collected</b></p></td><td><p><b>Business Purpose Disclosure:</b></p><ul><li>Service Providers</li><li>Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes)</li></ul><p><b>Sale:</b> Not Sold</p></td></tr></tbody></table>
340
341For more information on your do not sell rights, see the Do Not Sell subsection below.
342
343##### (2)California Consumer Privacy Rights.
344
345We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any request you submit to us is subject to an identification and residency verification process **("Verifiable Consumer Request")** as more fully explained in the Right to Know and Right to Delete sections below. We will not fulfill your Right to Know or Right to Delete request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. To make a request, email us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#4333312a3522203a03272c36212f262f2a30376d202c2e) or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquires we may make.
346
347Some PI we maintain about Consumers is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer's PI when a Consumer request that requires verification pursuant to the CCPA's verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA we do not include that PI in response to those requests. If we cannot comply with a request, we will explain the reasons in our response. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.
348
349We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose and otherwise use and to respond to your California Consumer privacy rights requests. In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest that you receive the most recent or a summary of your PI and give you the opportunity to elect whether you want the rest or not. We reserve the right to direct you to where you may access and copy responsive PI yourself. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.
350
351Consistent with the CCPA and our interest in the security of your PI, we will not deliver to you financial account number, or an account password in response to a CCPA request; however, you may be able to access some of this information yourself through your account if you have an active account with us.
352
353Your California Consumer privacy rights are as follows:
354
355##### (a) Right to Know.
356
357To make a Right to Know (Categories) or Right to Know (Specific Pieces) request, email us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#c9b9bba0bfa8aab089ada6bcaba5aca5a0babde7aaa6a4) or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquiries we make. We will respond to your request as outlined in the How to Submit a Request Under the CCPA section below. Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
358
359##### **(i) Categories**
360
361You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
362
363- The categories of PI we have collected about you.
364- The categories of sources from which we collected your PI.
365- The business or commercial purposes for our collecting or selling your PI.
366- The categories of third parties to whom we have shared your PI.
367- A list of the categories of PI disclosed for a business purpose in the prior 12 months and, for each, the categories of recipients, or that no disclosure occurred.
368- A list of the categories of PI sold about you in the prior 12 months and, for each, the categories of recipients, or that no sale occurred.
369
370For Categories of Information requests, as required by the CCPA, we will apply the verification standards set forth in the How to Submit a Request Under the CCPA section below.
371
372##### **(ii) Specific Pieces.**
373
374You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.
375
376For Specific Pieces of Information requests, as required by the CCPA, we will apply the heightened verification standards set forth in the How to Submit a Request Under the CCPA section below.
377
378##### **(b) The Right to Delete.**
379
380You may request that we delete your PI that we have collected directly from you and are maintaining. However, we may have a basis for retention under CCPA.. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your PI that we did not collect directly from you.
381
382For Delete requests, as required by the CCPA, we will apply the verification standards set forth in the How to Submit a Request Under the CCPA section below.
383
384To make a Right to Delete request, email us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#49393b203f282a30092d263c2b252c25203a3d672a2624) or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquiries we make.
385
386Deletion of your personal information will not deactivate your account. As a result, we cannot delete personal information necessary to maintain the account. If you would like to deactivate your account, please follow the instructions in your account settings or email us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection)
387
388##### (c) Do Not Sell.
389
390As noted in our Privacy Policy above, there may be cookies and other Tracking Technologies on our Service that may provide data, which may be treated as PI under the CCPA, to other parties that may use it for their own purposes, which in turn may provide that data to other parties for their own purposes. We do not believe that we sell PI collected by third-parties that operate their own cookies in association with our Services **("Cookie Operators")**. Cookie Operators collect PI that falls under the other identifiers (e.g., cookie ID, IP address, and other online IDs) and internet or other electronic activity information categories. However, we will treat PI collected by Cookie Operators, where not limited to acting as our service provider, as a sale and subject to a Do Not Sell opt-out request. We offer a cookie management tool that enables you to exercise your Do Not Sell opt-out request and enable certain cookie preferences on your device here. You must exercise your preferences on each of our websites you visit and from each browser and on each device that you use. Since your opt-out is designated by a cookie, if you clear or block cookies, your preferences will not be effective and you will need to enable them again via our cookie management tool. For additional information on cookies and alternative choices regarding them, including how to opt-out of certain interest-based advertising, see the Cookies and Tracking Technologies sections of our Privacy Policy above.
391
392We do not knowingly sell the PI of Consumers under 16, as the Service is not available to anyone who is not at least 18 years of age.
393
394We may disclose your PI for the following purposes, which are not a sale: (i) if you direct us to share PI; (ii) to comply with your requests under the CCPA; (iii) disclosures amongst the entities that constitute Company as defined above, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.
395
396##### (d) Non-Discrimination and Financial Incentive Programs.
397
398We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale, retention and use of your PI as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.
399
400##### (3) How to Submit a Request Under the CCPA.
401
402You have the right to exercise your CCPA rights. You may submit a request to exercise your CCPA rights (1) as an individual; or (2) via an authorized agent who meets the agency requirements of the CCPA and related regulations.
403
404##### (a) Methods to Submit a Request.
405
406As permitted by the CCPA, any request you submit to us must be a Verifiable Consumer Request. This means that your request is subject to an identification and residency verification process. We will not fulfill your Right to Know (Categories), Right to Know (Specific Pieces), or Right to Delete request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected Personal Information.
407
408We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.
409
410In addition to the above, we verify each request as follows:
411
412- **Right to Know (Categories):** We are required to verify a consumer's request to know categories of PI to a reasonable degree of certainty, which may include matching at least two data points provided by the Consumer with data points maintained by us, which we have determined to be reliable for the purpose of verifying the Consumer.
413- **Right to Know (Specific Pieces):** We are required to verify a Consumer's request to know specific pieces of PI to a reasonably high degree of certainty, which may include matching at least three data points provided by the Consumer with data points maintained by us, which we have determined to be reliable for the purpose of verifying the Consumer together with a signed declaration under penalty of perjury that the requestor is the Consumer whose PI is the subject of the request. If you fail to provide the data points we will be unable to verify you sufficiently to honor your request, but we will then treat it as a Right to Know (Categories) request.
414- **Do Not Sell:** No additional verification required.
415- **Right to Delete:** We are required to verify a Consumer's request to delete to a reasonable degree of certainty, which may include matching at least two data points provided by the Consumer with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by the Consumer with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the consumer posed by unauthorized deletion. If you fail to provide the data points specified above, we will be unable to verify you sufficiently to honor your request.
416
417##### (b)Authorized Agents.
418
419Authorized agents may exercise rights on behalf of California Consumers, but we reserve the right to also verify the Consumer's identity directly as described above. Authorized agents must contact us to submit a request by emailing us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#80f0f2e9f6e1e3f9c0e4eff5e2ece5ece9f3f4aee3efed) or follow the instructions at our Consumer Rights Request page here and indicating that they are submitting a request as an agent. We will require the agent to demonstrate authority to act on behalf of the Consumer by providing, for example, evidence of the agent's identity, proof of registration with the California Secretary of State (if the agent is a business), and at least one of the following evidencing proof of the agent's legal authority to act on behalf of the individual Consumer:
420
421- presenting a Power of Attorney granted under the Probate Code that we can reasonably verify; or
422- signed permission by the Consumer.
423
424We may also require the Consumer to verify their own identity directly with us and to directly confirm with us that they provided the authorized agent permission to submit the request.
425
426In the absence of any of the general conditions detailed above, we are entitled to reject any request submitted through an agent. In addition, the agent is subject to the verification standards applicable to the type of request(s) made.
427
428##### (4)Limitation of Rights.
429
430Notwithstanding anything to the contrary, we may collect, use, and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party's rights or conflict with applicable law.
431
432##### (b) Nevada Residents.
433
434Although we do not "sell" "covered information" of Nevada "consumers" as those terms are defined by Chapter 603A of the Nevada Revised Statutes, you may contact us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#09797b607f686a70496d667c6b656c65607a7d276a6664) and register an e-mail contact address for us to provide you notice in the event we should do so in the future, at which point you will have an opportunity to be verified and exercise your opt-out rights under that law. Contact us in the same manner to update your contact email for notices. Changing your email elsewhere (e.g., informational requests, account information, etc.) will not update your Nevada notice contact information. It is your responsibility to keep your notice contact information current.
435
436Return to navigation
437
438### 13\. CHANGES TO THIS PRIVACY POLICY.
439
440We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not treat your previously collected DL-Collected PII, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent. If you have a subscription to a Service, material changes to the Privacy Policy will only become effective with respect to the aspect of that subscription Service at the end of the then current term unless you otherwise consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
441
442Return to navigation
443
444### CONTACT US.
445
446If you have any questions about this Privacy Policy, please contact us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#f686849f8097958fb6929983949a939a9f8582d895999b) or [here](https://doublelist.com/contact/).
447
448Return to navigation