Privacy Policy - PREVIOUS VERSION

Thank you for using FullContact!

Last Updated: July 16, 2020
Current version here.

FullContact Inc. (“FullContact”, “we”, “us”, “our”) is committed to protecting your privacy. FullContact operates a number of websites (each a “Site”) and provides services available through the Sites to access the API, to prevent fraud, to update contact information, or to improve contact information (collectively, the “Services”). This Privacy Policy describes how we collect, use, process, and disclose your information, including Personal Data (as defined below), in conjunction with your access to and use of our Services, and it applies to all of the Services offered by FullContact and its affiliates. “Users” as defined in this Privacy Policy includes any user of our Services including individual End Users, organizational Clients, and Developers.

Specifically, we’ll cover:

1. PERSONAL DATA WE COLLECT

“Personal Data” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular consumer or household. The following are categories (with non-exhaustive examples) of Personal Data we may collect about you and for each category the purpose for which it may be used:

Categories | Examples | Processing Purpose

1.1 Personal Data Related to Your Account as a User.

1.1.a. Contact Information

Examples: full name, organization, phone number, email address, password token, photos, type of business, business use case, general location, or other similar identifiersProcessing Purpose: Provide, Maintain, and Support Services; Improve, Personalize, and Develop the Services; Provide, Personalize, Measure, and Improve our Advertising and Marketing; Combine Contacts for Identity Resolution & Verification Service; Combine Contacts for Contact Enrichment Services; Creation of Deidentified, Aggregate, or Anonymous Information

1.1.b. Payment Information

Examples: full name, credit card, billing addressProcessing Purpose: Provide, Maintain, and Support Services

1.1.c. Product Related Communication

Examples: email address, phone, full name, audio, additional information you provideProcessing Purpose: Provide, Maintain, and Support Services; Improve, Personalize, and Develop the Services; Provide, Personalize, Measure, and Improve our Advertising and Marketing

1.1.d Usage Data

Examples: full name, email address, phone number, URLs, social handles, physical address, online identifiers, or other similar identifiersProcessing Purpose: Provide, Maintain, and Support Services; Improve, Personalize, and Develop the Services; Provide, Personalize, Measure, and Improve our Advertising and Marketing; Combine Contacts for Identity Resolution & Verification Service; Combine Contacts for Contact Enrichment Services; Creation of Deidentified, Aggregate, or Anonymous Information

1.1.e. Connected 3rd Party Services/Integrations

Examples: name, email address, passwordProcessing Purpose: Provide, Maintain, and Support Services; Improve, Personalize, and Develop the Services; Provide, Personalize, Measure, and Improve our Advertising and Marketing; Combine Contacts for Identity Resolution & Verification Service; Combine Contacts for Contact Enrichment Services; Creation of Deidentified, Aggregate, or Anonymous Information

1.2 Personal Data Provided or Generated When Using Our Services

1.2.a. Contact Data

Examples: full name, email address, phone number, URLs, social handles, profile photo, physical address, online identifiers, or other information associated with your accountProcessing Purpose: Provide, Maintain, and Support Services; Improve, Personalize, and Develop the Services; Provide, Personalize, Measure, and Improve our Advertising and Marketing; Combine Contacts for Identity Resolution & Verification Service; Combine Contacts for Contact Enrichment Services; Creation of Deidentified, Aggregate, or Anonymous Information

1.3 Website (any website information not provided below, such as online identifiers is aggregated or de identified using 3rd party providers)

1.3.a. Forms/Chats

Examples: full name, email, job title, phone, organization, industry, general location, additional information you provideProcessing Purpose: Provide, Maintain, and Support Services; Improve, Personalize, and Develop the Services; Provide, Personalize, Measure, and Improve our Advertising and Marketing; Combine Contacts for Identity Resolution & Verification Service; Combine Contacts for Contact Enrichment Services; Creation of Deidentified, Aggregate, or Anonymous Information

1.3.b. Analytics

Examples: Information on an individual's interaction with our website or advertisement, browsing historyProcessing Purpose: Provide, Maintain, and Support Services; Improve, Personalize, and Develop the Services; Provide, Personalize, Measure, and Improve our Advertising and Marketing; Creation of Deidentified, Aggregate, or Anonymous Information

1.3.c Ad Networks

Examples: Information about an individual's experiences and interactions from our partner ad networksProcessing Purpose: Provide, Maintain, and Support Services; Improve, Personalize, and Develop the Services; Provide, Personalize, Measure, and Improve our Advertising and Marketing; Creation of Deidentified, Aggregate, or Anonymous Information

1.4 Personal Data we Receive from Third Parties or Affiliates for Use in our Services.

1.4.a Open Data

Examples: age gender, social URLs, full name, company name, company bio, general location, education, job titleProcessing Purpose: Provide, Maintain, and Support Services; Improve, Personalize, and Develop the Services; Provide, Personalize, Measure, and Improve our Advertising and Marketing; Combine Contacts for Identity Resolution & Verification Service; Combine Contacts for Contact Enrichment Services; Creation of Deidentified, Aggregate, or Anonymous Information

1.4.b Data Providers

Examples: age, gender, organization, job title, business email, interests, social affinities, social URLs, payment type, retail shopper, marital status.Processing Purpose: Provide, Maintain, and Support Services.; Improve, Personalize, and Develop the Services; Provide, Personalize, Measure, and Improve our Advertising and Marketing; Combine Contacts for Identity Resolution & Verification Service; Combine Contacts for Contact Enrichment Services; Creation of Deidentified, Aggregate, or Anonymous Information

1.5 Personal Data we Get from Third Party Services for Use in Sales/Marketing

1.5.a Prospect Lists

Examples: full name, company name, emailProcessing Purpose: Provide, Personalize, Measure, and Improve our Advertising and Marketing; Combine Contacts for Identity Resolution & Verification Service; Combine Contacts for Contact Enrichment Services; Creation of Deidentified, Aggregate, or Anonymous Information

1.6 Personal Data You Provide Us in Claim Your Data

1.6.a. Authorization Data

Examples: full name, email, physical address, phone number, access code
Processing Purpose: Provide, Maintain, and Support Services

We collect Personal Data, as described below.

Sources of Personal Data. We obtain the categories of Personal Data listed above on or through our Services from the following categories of sources:

1.1 Personal Data Related to Your Account as a User. FullContact collects Personal Data when you voluntarily submit it to us. For example, we may collect or receive Personal Data from Users when a User creates a FullContact Account; edits Registration Information; signs up to receive promotional communications; uses or accesses features available through the Services or FullContact Data; participates in one of our promotional sweepstakes, contests, or surveys; posts a review; submits a request to our customer service team; interacts with our social media pages; or otherwise interacts with us or other Users through the Services. 

1.1.a Contact Information. When you sign up for a FullContact Account, we may require certain information such as your full name, organization, phone number, email address(s) and password token. You may optionally choose to sign into FullContact using a third party (e.g., your Google login). If you choose to do this, you will be asked whether you agree to the third party providing certain information to FullContact, such as your name, email address, profile photo, and other information associated with your Account.

1.1.b Payment Information. Some of our Services require payment. We may use third party payment service providers such as Stripe to collect all the information necessary to complete the transaction. We never share your billing and payment information except with these payment service providers.

1.1.c Product Related Communication. If you contact or interact with us (for example via support, feedback, surveys, forum, chat, promotions) we may collect information such as your name, phone number, email address, as well as any other content that you provide. We also may create event logs to diagnose Service or product related issues, and capture information relating to any support issues. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives and analyze any feedback provided through voluntary customer surveys.

1.1.d Usage Data. Personal Data may be collected through your experiences and interactions within the developer dashboard and through the use of the FullContact API. For example, User may provide an email within our search feature to see additional contact elements that may be returned with that email.

1.1.e Connected Third-Party Services/Integrations. Many FullContact Services allow you to connect with external systems or databases. Examples include but are not limited to: (i) communication platforms such as email providers, video conferencing systems, calendar applications, and social networks, and (ii) sales, marketing, customer service, and media platforms. Connections to such services generally require you to sign into those services.

1.2 Personal Data Provided or Generated When Using Our Services. FullContact provides a variety of Services that may collect Personal Data such as submitting Contacts through FullContact’s API (both lookup and search), upload of lists/files of Contacts for processing, or with the transfer of Contacts from certain third-party integrations. We also provide a variety of Services that enable you to effectively manage contact information that you provide to us as part of those Services (your “Contacts”, also referred to as “End User Contact Data” in our Terms of Use). Contacts typically contain information on individuals (or organizations) including names, email addresses, phone numbers, URLs, social handles, online identifiers, and physical addresses. Your Contacts may also contain additional information on individuals such as organizational affiliations, job titles, birthdays, key dates, age, gender, general location, relationships, skills, interests, preferences, notes, photos, tags and other categorizations.

1.3 Website. We may collect information on User interacts with our Site, promotions, or advertisements. Third parties may also collect Personal Data as described below.

1.3.a Forms/Chats. If you contact or interact with us on the site via chat or site forms, we may collect information such as your name, phone number, email address, as well as any other content that you provide.

1.3.b Analytics. We may collect and allow third parties to collect information about how you use and interact with our Site and Services. Examples of third-party providers of analytics and similar services we currently use include:o   Google Analytics. Used to track site statistics and user demographics, interests and behavior on websites.

1.3.c Ad Networks. We may receive Personal Data about you and your activities whether as part of or outside our Services through partnerships, or about your experiences and interactions from our partner ad networks.

1.4 Personal Data we Receive from Third Parties or Affiliates for Use in our Services. We may receive Personal Data that others provide about you when they use the Services (through Contacts provided to us as described above), or obtain information from other sources, including but not limited to public or licensed APIs (“Open Data”), third-party data partners and affiliates (Contacts+), and data research. We do not control, supervise, or respond for how the third parties process your Personal Data.

1.4.a Open Data. Open Data includes information that is in the public domain or has been declared public knowledge by someone with the authority to do so and can freely be given to anyone. Personal Data may be collected through our open data sources. We openly share this data, while abiding by relevant terms and conditions.

1.4.b Data Providers. We may collect Personal Data from reliable marketing/data providers gathered from sources including but not limited to public records, warranty information, surveys, opt-in subscriptions, public filings, public directories, and other publicly available sources.1.5 Personal Data we Receive from Third Party Services for Use in Sales/Marketing. We may receive Personal Data from other third-party sources, third-party data partners and affiliates, and data research.

1.5.a Prospects Lists. In an effort to personalize and provide information on FullContact products or Services that may be of interest to you, we may collect Personal Data from third-party sources such as name, email, company name, job titles, and more.

1.6 Personal Data You Provide Us in Claim Your Data

1.6.a Authorization Data. When you want to verify your Personal Data via our Services, we may require you to provide certain information such as your general location, phone number, and email address(s) prior to granting access to your Personal Data for verification purposes only.To the extent permitted by applicable law, Personal Data does not include:Publicly Available Data – Publicly available information from government records.

Deidentified, Aggregate, or Anonymous Information – “Deidentified Information” means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular individual, and for which FullContact has implemented technical safeguards and business processes that prohibit reidentification of the individual. “Aggregate Information” means information that relates to a group or category of individuals, from which individual identities have been removed, that is not linked or reasonably linkable to any individual or household, including via a device. “Anonymous Information” means information that is not associated with or linked to an individual and does not, by itself, permit the identification of an individual. 

Excluded Information – Certain laws require separate privacy notices or are exempt from general personal information privacy policy disclosure requirements. Such laws include health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or clinical trial data; the Gramm-Leach-Bliley Act (GLBA); Fair Credit Reporting Act (FCRA); and the Driver’s Privacy Protection Act of 1994.

2. HOW WE USE PERSONAL DATA

We primarily use, store, and process Personal Data to provide, understand, improve, and develop our Services, create and maintain a trusted and safer environment, and comply with our legal obligations. We also use Personal Data for the following purposes:

2.1 Provide, Maintain, and Support the Services

Using Personal Data we collect, we are able to deliver the Services to you and honor our Terms of Use. We need to use Personal Data you provide to facilitate the creation of and secure your Account on our network, identify you as a User in our system, provide improved administration and quality of experience of our Site and Services, send email, call, or send SMS text messages to you to verify ownership of the email address or phone number provided when your Account was created, send you Service, support or maintenance messages, updates, security alerts, and Account notifications. Your Personal Data may also be used for the detection and prevention of fraud, spam, abuse, and other harmful activity, and for any purpose you authorize at the time of collection.Additionally, to provide you technical support, we may need to review your Account and the contents of your Account to identify, research, troubleshoot, and resolve any issues that you report to us or that we otherwise become aware of.

2.2 Improve, Personalize, and Develop Services

We use Personal Data we collect to improve and personalize the Services and to develop new ones. For example, we use Personal Data to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and Services.

2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing

We may process Personal Data for marketing purposes including offering you products or Services that may be of interest to you (such as information about FullContact Services or partner campaigns and other third party services). We may also administer referral programs, rewards, surveys, sweepstakes, contests, newsletters, or other promotional activities or events sponsored or managed by FullContact or its third party partners. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your FullContact Account.

2.4 Combine Contacts for Identity Resolution & Verification Services

Certain categories of Personal Data may be combined to build more complete contact records of individuals (“Completed Contact Data”). Completed Contact Data reside in the FullContact Database and may be processed for the following purposes in connection with providing Identity Resolution and Verification Services: Grouping contacts and contact elements into unique individuals to create Completed Contact Data.Generating and returning a unique identifier for an individual and associated Completed Contact DataLinking (or “matching”) input contact records to Completed Contact Data for purposes of identifying an individual, searching for an individual, and/or linking to other contact records (such as those submitted by 3rd-parties) associated with the same individual.Deduplicating a set of input contact records based on unique individualsInferring linkages between and/or deduplicating existing Completed Contact DataVerifying the accuracy and recency of contact elements contained within input contact recordsFor example, someone may search or lookup a Contact by name and email address. FullContact connects the name and email with a Completed Contact Data within the FullContact Database for one of the reasons above. No additional Contact Data beyond the unique identifier are returned to the User submitting the search.

2.5 Combine Contacts for Contact Enrichment Services

Certain categories of Personal Data may be made available to our customers and partners in connection with providing Enrichment Services.

Contact enrichment is often combined with Identity Resolution so that, for example, a User is able to match a Contact that they possess to our Completed Contact Data, and receive back a subset of the contact information from the relevant Completed Contact Data for that individual and/or other contacts records linked to the same individual. For example, we may return an individual’s name to support features such as caller ID. Other examples of data that may be returned by our Enrichment Services include: social handles, hashed identifiers, basic demographic information, profile photos, consumer interests, and professional information such as business emails, organizational affiliation and job title. See our developer docs for a list of currently available enrichment data.

2.6 Creation of Deidentified, Aggregate, or Anonymous InformationWe may create Deidentified Information, Aggregate Information, or Anonymous Information records from Personal Data by excluding certain private data in a manner that makes the data not personally identifiable. We use this Deidentified Information, Aggregate Information, or Anonymous Information to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. FullContact reserves the right to use Deidentified Information, Aggregate Information, and Anonymous Information for any purpose, including providing Services to our Users, and disclose Deidentified Information, Aggregate Information, and Anonymous Information to third parties in its sole discretion, including (but not limited to) regulatory compliance, industry and market analysis, demographic profiling, modeling, marketing and advertising, and other business purposes.

3. HOW PERSONAL DATA IS SHARED

3.1 When You Consent, Agree or Direct Us to Share

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 participate in promotional activities conducted by FullContact partners or third parties or when you exercise consent as requested in the use of our Services.

3.2 Sharing Between Users

To provide our Services, for commercially purposes, specifically our Identity Resolution and Verification Services and Enrichment Services, we may need to share certain Personal Data with other Users of our Services, as it is necessary for the adequate performance of the contract between you and us and for performance of certain features of our Services based on our legitimate interest. Examples include, but are not limited to, sharing information for the fulfillment of our Terms of Use or Master Services Agreement or through our  Services for the purposes of improving the Services for both you and other End Users and Developers.

3.3 Sharing Between Business PartnersWe may provide Personal Data for commercial purposes to business partners and third parties that we believe may offer products or services of interest to you. We screen all such third parties that receive such Personal Data and review the intended use of the information before providing any information to them. These parties may include such companies as software and hardware providers, consumer product providers, marketing coops, information providers, digital marketers, ad agencies, web publishers, data management platforms, and social media networks

3.4 Compliance with Law, Responding to Legal Requests, Preventing Harm, and Protection of Yours or Our Rights

Regardless of any choices you make regarding your Personal Data (as described below), FullContact may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with applicable laws, including laws outside your country of residence; (c) to respond to requests from public and government authorities (including authorities outside your country of residence) or to respond to subpoenas or warrants served on FullContact; (d) to protect or defend the rights or property of FullContact or that of you or other End Users or Developers; or (e) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or Terms of Use. In addition, under certain applicable laws, individuals may have the right to require that we disclose to them their Personal Data that we store in the FullContact Database. FullContact will make such disclosures required by law, but we will not disclose you as the source of that information unless required by law.

3.5 Service Providers

FullContact uses a variety of third party service providers to help us provide our Services. These Service providers may be located anywhere worldwide in countries outside your country of residence. In particular, currently use service providers based in Europe, India, Asia Pacific and North and South America.In order to facilitate payments for Services we provide, certain information as described above may be shared with the relevant payments service providers. This payment related data sharing is necessary for the performance of the contract between you and us.These service providers may have limited access to your information as necessary to perform these services on our behalf, and are contractually bound to protect and to use your Personal Data only for the purposes for which it was disclosed and consistent with this Privacy Policy.FullContact may need to share your Personal Data in order to deliver the Services to you and honor our Terms of Use.

3.6 Corporate Affiliates

To enable or support us in providing the Services, we may share your  Personal Data, in compliance with local data privacy laws, within our corporate family of companies that are related by common ownership or control.

Sharing with FullContact, Inc. Even if your country of residence is not the United States, your Personal Data may be shared with FullContact, Inc. which provides the technical infrastructure for the Services, product development and maintenance, customer support, trust and safety and other business operation services to other FullContact affiliates and subsidiaries.

Sharing with FullContact Affiliates and Subsidiaries. Your Personal Data may be shared with our wholly owned affiliates and subsidiaries. Personal Data shared in these circumstances may include Contact information.

3.7 Social Media Platforms

Where permissible according to applicable law we may use certain derivative Personal Data about you, such as a cryptographic hash of a personal email and share it with social media platforms, such as Linkedin or Google, to generate leads, drive traffic to our Sites or otherwise promote our Services. The social media platforms with which we may share your Personal Data are not controlled or supervised by FullContact. Therefore, any questions regarding how your social media platform processes your Personal Data should be directed to such platform.Please note that you may, at any time ask FullContact to cease processing your Personal Data for these direct marketing purposes by sending an email to: opt-out@FullContact.com.

3.8 Business Transfers

If FullContact undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your Personal Data, in connection with such transaction, or in preparation for or contemplation of such transaction (e.g., due diligence).

4. PERSONAL DATA RETENTION

We generally retain your Personal Data for as long as is necessary for the performance of the Services to you and our other Users and to comply with our legal obligations. This includes information that you have made available to the FullContact Database for the purposes of improving the Services for both you and other Users of our Services.

You may request that we delete your Personal Data and close your FullContact Account or you can delete your End User Contact Data and close your Account on your own. Please note that if you request the deletion of your Personal Data or if you delete your Personal Data:

We may retain some of your information as necessary for fraud detection and prevention and enhancing safety. For example, if we suspend a FullContact Account for fraud or safety reasons, we may retain certain information from that Account to prevent that user from opening a new FullContact Account in the future.

We may retain and use your information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting, and auditing obligations.

Information you have shared with other systems (e.g., Google) may continue to exist in those systems, and in some cases be publicly visible.

Some copies of your information (e.g., log records) may remain in the FullContact Database, but are disassociated from personal identifiers.

Because we maintain backup to protect our Services from accidental or malicious loss and destruction, residual copies of your information will be included in backups and may not be removed from our backup systems.

5. THIRD PARTY WEBSITES

6. PERSONAL DATA PROTECTION

7. YOUR RIGHTS

8. CALIFORNIA PRIVACY RIGHTS

9. EUROPEAN PRIVACY RIGHTS

10. EXERCISING YOUR PRIVACY RIGHTS

11. CHANGES TO THIS PRIVACY POLICY

12. HOW TO CONTACT US

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