Our Practices in Relation to Consumer Personal Data (Licensed and Publicly Available):

• Users and Consumers, when you give your data directly to one of our websites, affiliated companies, clients, or partners, or when you interact with our websites and services. 

• Cookie and Trackers may collect Personal Data about your online behavior.  For more information, please visit our Cookie Policy.

• Data Brokers who supply Personal Data obtained from public records, or who resell data obtained from private sources. 

• Data Partners with whom we may exchange Personal data, including lead generation. 

• Public Sources where we receive Personal Data from public or licensed APIs (“Open Data”), and data research. We do not control how the third parties process your Personal Data.

• Some of the Personal Data we receive from data providers may allow us to infer certain characteristics about you that may be considered sensitive information under applicable law, such as health information, religious or philosophical beliefs, political opinions, and citizenship or immigration status. These characteristics are included in our identity graph and may be shared in FullContact Data Services we offer to Users.

3. SENSITIVE PERSONAL DATA

We do not seek to collect or process sensitive personal information, such as, race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, or sex life. We ask that you not provide us with any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Platform, or otherwise to us.  

4. DIRECT MARKETING

We may use the contact details you provided us to reach out to you with information regarding services that may be of interest to you, for example, upcoming promotions. You may unsubscribe or opt out of SMS messages at any time at no cost. For more information see the section titled “How to Change Your Preferences.”

5. BEHAVIORAL ADVERTISING

Subject to your privacy choices and settings, may collect data about your behavior while using our services in order to provide you with more relevant interest-based advertising on other websites and applications, as well as our partners’ platforms and media channels. If you do not wish to receive this advertising, you can opt-out via our Privacy Portal, or change your preferences.  For more information see the section titled “How to Change Your Preferences.

6. COOKIES

We may collect information about you through the use of cookies and similar technologies on our sites and apps, or your devices. In compliance with your privacy choices and settings, we also may permit our third-party service providers to perform various analytics functions and to provide you with more relevant or interest-based advertisements using cookies.

Some third parties may choose to use their own cookies for the purposes of collecting information relating to the viewing of their advertising. To learn more about how we use cookies, and to manage your preferences, please see our Cookie Policy. This policy, and our Cookie Policy, are only intended to cover the use of cookies as they relate to FullContact.

 7. INFORMATION WE SHARE WITH THIRD PARTIES

Our business is owned by Ziff Davis Inc, a holding company which owns many brands in the areas of technology, shopping, entertainment, health, parenting, and connectivity. We share your information with other Ziff Davis Companies to assist us in the operation of our services, improve them, and further develop them.

We also share information with other Ziff Davis Companies for the purposes of targeted advertising. If you would like to opt out of the sale or sharing of your data with other Ziff Davis Companies, you can do so via our Privacy Portal.   

Other Third Parties: We may also share your personal information with the following:

• Relevant third party provider, where our services use third party advertising, plugins or content, subject to your privacy choices and settings, and our ToU. 
• Professional advisors, including companies providing FullContact with advice in accounting, administrative, legal, tax, financial, or debt collection

• Advertising partners where you consented and chose to participate in offers or other marketing. 
• Third party Processors (such as analytic providers; data centers; etc.), located anywhere in the world, subject to the requirements and limitations;
• Legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation; 
• Any party as directed by a law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
• Law enforcement for the purposes of prevention, detection, or investigation of criminal offenses and any legal proceedings associated with them. 
• In the case of a full or partial acquisition, relevant third parties.

You may authorize us to disclose your Personal Data to others, such as when you connect a third-party application or website to access your FullContact Account, when you utilize the Platform’s live chat feature, when you participate in promotional activities conducted by FullContact partners or third parties, or when you exercise consent as requested in the use of our Platform.

FullContact is based in the United States, but we operate globally. We may transfer your information to recipients in other countries. FullContact participates in the E.U.-U.S. Data Privacy Framework, the UK extension to the EU-U.S. DPF, the Swiss-U.S. Privacy Framework and the APEC Cross Border Privacy Rules System. Where we transfer information from the European Economic Area (“EEA”) to a recipient outside the EEA that is not in an adequate jurisdiction, we do so on the basis of standard contractual clauses.

Because of the international nature of our business, we may need to transfer your information within FullContact’s subsidiaries, affiliate companies, and to third parties as noted above, in connection with the purposes set out in this Policy. For this reason, we may transfer your information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. We remain liable under the DPF Principles if any third parties that we transfer your personal information to process it in a manner inconsistent with the DPF Principles, unless we prove that we are not responsible for the event giving rise to the damage.

FullContact and its associated affiliates and subsidiaries complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. FullContact has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. FullContact has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit www.dataprivacyframework.gov.

We are committed to staying current with developments related to the Data Privacy Framework and may update our transfer mechanisms and safeguards as necessary to remain compliant. Any updates will be reflected in this Privacy Policy.

If you are a European individual with a privacy related complaint, concern or question about FullContact’s privacy practices, please contact us through our Privacy Portal. Under certain conditions, more fully described on the Data Privacy Framework website, European individuals may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Where we transfer your Personal Information from the EEA to recipients located outside the EEA who are not in a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Information, we do so on the basis of standard contractual clauses. You may request a copy of the relevant standard contractual clauses using our Privacy Portal. Please note that when you transfer any Personal Information directly to a Company entity established outside the EEA, we are not responsible for that transfer of your Personal Information. We will nevertheless Process your Personal Information, from the point at which we receive the data, in accordance with the provisions of this Privacy Policy.

Enforcement Authority

The Federal Trade Commission has jurisdiction over our compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

Complaints Mechanism

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, FullContact commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact FullContact at privacy@fullcontact.com.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, FullContact commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider. The services of JAMS are provided at no cost to you. For further information please visit https://www.jamsadr.com/dpf-dispute-resolution.

Under certain conditions, a binding arbitration option may be available to you in order to address complaints not resolved by any other means. For further information, please see Annex I of the EU-U.S. Data Privacy Framework Principles at: www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, FullContact commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship. For a list of our subsidiaries and affiliates who also adhere to the DPF Principles, please click here. Our privacy practices described in this Policy comply with the Asia-Pacific Economic Cooperation (“APEC”) Cross Border Privacy Rules System. To learn more about this program, please click here.

9. DATA SECURITY AND BREACH HANDLING

We implement appropriate technical and organizational security measures to protect your personal information against unlawful destruction, loss alteration, misuse, or unauthorized access while in our possession. All parties we contract with must agree to provide reasonable data security measures for the customer information we share with them, in compliance with applicable laws and regulations. 

If we learn of a security breach that affects our Users or Consumers, we may send an email or other direct communication to you, or post a blog to notify the public on our Help and Support Security Center. If you have any reason to believe that your data with us has been compromised (for example, there has been unauthorized access to your account), please contact us at  privacy@fullcontact.com

10. HOW TO CHANGE YOUR PREFERENCES

Marketing Emails. We offer Users choices regarding the collection, use, and sharing of their Personal Data. If you are a User of our Platform, we may periodically send you free newsletters and emails that promote our Platform as well as third-party products or services we think you may be interested in. When you receive such promotional newsletters or communications from us, you may indicate a preference to stop receiving them from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly. Despite your indicated email preferences, we may send you service-related communications, such as those about your FullContact Account.

Advertising Choices. You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins and extensions, or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Digital Advertising Alliance or Network Advertising Initiative in the U.S., the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe. Mobile app users may opt out of receiving behavioral-based advertising in mobile apps provided by participating members of the Digital Advertising Alliance by installing the AppChoices mobile app. Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here. Many of the opt-out preferences described in this section must be set on each device or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Do Not Track. Some web browsers and devices permit you to broadcast a ”Do Not Track” signal to the online services that you visit. Where your browser signal is set to “Do Not Track” you are automatically opted out of data collection through tracking technologies. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. Our Site does respond to the Global Privacy Control (GPC) signal as described in the “Right to Opt-Out of Sales and Targeted Advertising” section below.

Many privacy regulations afford consumers a number of specific rights. If you are a resident of the EU (under GDPR), UK (under the UK GDPR), Brazil (under the LGPD), several U.S. States, including California (CCPA), Virginia (under VCDPA), Colorado (under the CPA), and Connecticut (under the CTDPA), or another jurisdiction with an existing privacy regulation, you have certain rights which may include those listed below.

• • Right to Know: You have a right to know what personal information we collect, process, and share or sell. This policy is meant to provide transparency with regard to your data. If you have additional questions, you can email us at privacy@fullcontact.com.
  • Right to Access: You have the right to request that FullContact provide you access to your Personal Data.
  • Right to Delete: You have the right to request that FullContact delete any of your Personal Data.
  • Right to Correct: You have the right to request that FullContact correct inaccurate or incomplete Personal Data that we maintain about you, taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data.
  • Right to Opt-Out of Sales and Targeted Advertising: If FullContact sells your Personal Data, you have the right to opt-out. You may exercise these rights by visiting the Privacy Portal.
  • Right to Limit the Use or Disclosure of Sensitive Personal Data: If FullContact collects or processes sensitive Personal Data for the purpose of inferring characteristics about you, you have the right to request that we limit the use or disclosure of your sensitive Personal Data for certain limited permitted purposes by law. We will provide an individual opt-out choice, or opt-in for sensitive Personal Data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please visit the Privacy Portal or email us at privacy@fullcontact.com. FullContact will process your Right to Limit as a request to delete, thereby removing your Consumer profile from the FullContact identity graph.
  • Right to Revoke Consent and Restrict Processing: Where you are requested to consent to the processing of your personal information, you have the right to withdraw your consent at any time. 
  • Right to Object to Processing: In some jurisdictions, applicable law may entitle you to require FullContact not to process your Personal Data for certain specific purposes, where such processing is based on legitimate interest. You can object to our processing of your personal information by emailing privacy@fullcontact.com, under certain circumstances. By objecting to processing, you may not be able to access some or all of our services. This right is limited to personal data processed for commercial purposes. 
  • Right to Not be Discriminated Against: You have a right to not be discriminated against by FullContact for exercising your rights.

• Right to Object to Automated Processing: You have a right to object to automated processing of your data for the purposes of automated decision making about you. 

• Right to an Authorized Agent (CA): If you would like to make a request on behalf of a California consumer who is a current or former customer, please provide an email from the email address we have on file for the customer authorizing the request. You may also make a request under the California Consumer Privacy Act on behalf of a California consumer if you provide (1) a signed, written permission from the consumer to act on your behalf, and the consumer verifies their own identity directly with us; or (2) proof that the consumer has provided you with power of attorney pursuant to Probate Code sections 4000 to 4465. We may deny a request from an agent that does not submit proof that they have been authorized by the consumer to act on their behalf.
• Right to Complain (EU,UK, Switzerland): Should you wish to raise a complaint about the collection or use of your information, you have the right to do so without prejudice to any other rights you may have. You may lodge a complaint with your local data protection authority.

How to Exercise Your Request: You, or an agent authorized to act on your behalf, may exercise these choices through the mechanisms described above, by emailing us at privacy@fullcontact.com, or through our interactive webform available through the Privacy Portal.

How We Process Your Request: For security purposes and in order to complete your request appropriately,  we may need to ask specific information from you to help us confirm your identity and/or clarify your request. 

How to Appeal a Decision Concerning Your Request: If we notify you that we will not take action on your request, you may appeal such refusal within a reasonable period after receipt of the notice by following the instructions provided in the notice or by submitting an appeal through the Privacy Portal. 

12. ACCESSIBILITY

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

13. CONTACT DETAILS

If you have any questions or complaints about this Privacy Policy, please contact us at: privacy@fullcontact.com.

For any additional questions, you can contact us by emailing privacy@fullcontact.com or at the following address:

Ziff Davis, Inc.
Attention: Legal Department
360 Park Avenue South, 17th Floor
New York, New York 10010

We have registered our DPO with the Irish Data Protection Commission. If you have any questions or concerns about our privacy practices, we encourage you to contact our DPO at the following email address dpo@ziffdavis.com or at the following address:

Ziff Davis
Attention: Legal Department
Unit. 3.1, Woodford Business Park
Santry,
Dublin 17
Ireland

14. CHILDREN

These services are not intended for use by children, especially those under 16. We reserve the right to remove a user’s account at any time, when necessary, if we discover that a user is under the required age limit for the service. If you have reason to believe we have collected personal information from someone under 16, please report it to us so we can take appropriate steps to rectify this. 

15. CALIFORNIA CONSUMER RIGHTS METRICS

Pursuant to the California privacy regulations, our consumer rights metrics can be found on our Regulatory Information Site.
  

16. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is subject to revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an email to the last email address associated with your Account, or by prominently posting notice of the changes on our Site. If any changes materially affect the manner in which we use or disclose Personal Data, we will provide advance notice of the change by email to the last email address associated with your Account, or by prominently posting notice of the changes on our Site. Continued use of our Platform, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.