Doublelist Privacy Policy changes — 20260811_rev02

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For more information on your do not sell rights, see the Do Not Sell subsection below.

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##### (2)California Consumer Privacy Rights.

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We 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#4636342f3027253f06222933242a232a2f35326825292b) or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquires we may make.

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We 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#dfafadb6a9bebca69fbbb0aabdb3bab3b6acabf1bcb0b2) or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquires we may make.

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Some 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.

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We 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.

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Consistent 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.

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Your California Consumer privacy rights are as follows:

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##### (a) Right to Know.

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To 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#2d5d5f445b4c4e546d4942584f414841445e59034e4240) 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.

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To 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#ccbcbea5baadafb58ca8a3b9aea0a9a0a5bfb8e2afa3a1) 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.

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##### **(i) Categories**

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You 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:

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- The categories of PI we have collected about you.

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211	211	### 8\. CHILDREN'S PRIVACY.
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213	213	The 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.
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215		If 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#93e3e1fae5f2f0ead3f7fce6f1fff6fffae0e7bdf0fcfe) or using the information provided below so we can take appropriate actions.
	215	If 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#bfcfcdd6c9dedcc6ffdbd0caddd3dad3d6cccb91dcd0d2) or using the information provided below so we can take appropriate actions.
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217	217	DL 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.
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221	221	### 9\. INTERNATIONAL TRANSFER.
277	277	### 12\. YOUR STATE PRIVACY RIGHTS.
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279	279	##### a. California Residents.
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281	281	1. Your California Privacy Rights Regarding Disclosures for Third-Party Marketing ("Shine the Light" Law).
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283		We 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#3444465d4255574d74505b41565851585d47401a575b59) or by sending a letter to Doublelist; ATTN: Legal Department, Go Social Trade OÜ, Harju maakond, Tallinn, Lasnamäe linnaosa, Sepapaja tn 6, 15551. 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.
	283	We 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#95e5e7fce3f4f6ecd5f1fae0f7f9f0f9fce6e1bbf6faf8) or by sending a letter to Doublelist; ATTN: Legal Department, Go Social Trade OÜ, Harju maakond, Tallinn, Lasnamäe linnaosa, Sepapaja tn 6, 15551. 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.
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285	285	4. California Privacy Notice.
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287	287	Effective Date of Notice: January 1, 2022
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289	289	This 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.
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534	534	For more information on your do not sell rights, see the Do Not Sell subsection below.
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536	536	##### (2)California Consumer Privacy Rights.
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538		We 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#4636342f3027253f06222933242a232a2f35326825292b) or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquires we may make.
	538	We 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#dfafadb6a9bebca69fbbb0aabdb3bab3b6acabf1bcb0b2) or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquires we may make.
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540	540	Some 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.
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542	542	We 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.
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544	544	Consistent 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.
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546	546	Your California Consumer privacy rights are as follows:
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548	548	##### (a) Right to Know.
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550		To 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#2d5d5f445b4c4e546d4942584f414841445e59034e4240) 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.
	550	To 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#ccbcbea5baadafb58ca8a3b9aea0a9a0a5bfb8e2afa3a1) 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.
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552	552	##### (i) Categories
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554	554	You 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:
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556	556	- The categories of PI we have collected about you.
571	571	##### (b) The Right to Delete.
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573	573	You 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.
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575	575	For 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.
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577		To make a Right to Delete request, email us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#e9999b809f888a90a98d869c8b858c85809a9dc78a8684) or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquiries we make.
	577	To make a Right to Delete request, email us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#6717150e1106041e27030812050b020b0e14134904080a) or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquiries we make.
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579	579	Deletion 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).
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581	581	##### (c) Do Not Sell.
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583	583	As 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.
606	606	- 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.
607	607	- Do Not Sell: No additional verification required.
608	608	- 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.
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610	610	##### (b)Authorized Agents.
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612		Authorized 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#2e5e5c47584f4d576e4a415b4c424b42475d5a004d4143) 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:
	612	Authorized 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#a1d1d3c8d7c0c2d8e1c5ced4c3cdc4cdc8d2d58fc2cecc) 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:
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614	614	- presenting a Power of Attorney granted under the Probate Code that we can reasonably verify; or
615	615	- signed permission by the Consumer.
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617	617	We 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.
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621	621	##### (4)Limitation of Rights.
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623	623	Notwithstanding 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.
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625	625	##### (b) Nevada Residents.
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627		Although 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#5525273c2334362c15313a20373930393c26217b363a38) 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.
	627	Although 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#a3d3d1cad5c2c0dae3c7ccd6c1cfc6cfcad0d78dc0ccce) 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.
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631	631	### 13\. CHANGES TO THIS PRIVACY POLICY.
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633	633	We 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.
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637	637	### CONTACT US.
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639		If you have any questions about this Privacy Policy, please contact us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#7b0b09120d1a18023b1f140e19171e1712080f55181416) or [here](https://doublelist.com/contact/).
	639	If you have any questions about this Privacy Policy, please contact us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#d7a7a5bea1b6b4ae97b3b8a2b5bbb2bbbea4a3f9b4b8ba) or [here](https://doublelist.com/contact/).
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Privacy Policy

Full text changes — 20260811_rev01 to 20260811_rev02