Privacy Policy 1. Introduction to Data Axle’s Services Data Axle Inc. and its various affiliates and subsidiaries provide to clients a wide variety of data management, distribution, analytic and marketing services and products, which help our clients and the platforms and partners they work with to provide more relevant marketing and communications, and to understand their consumers better. These clients may reach their customers and others, for instance, through direct mail, email, display, mobile and multi-media channels. Many of these services are described in greater detail on our website, https://www-dev.data-axle.com. Most of the information that we handle is not collected on this website, but rather through relationships we have with other companies such as data suppliers, business partners (such as ad networks and other online partners), data services providers, agencies and our clients. We provide this Privacy Policy as a service to consumers and others who want to learn more about the data we handle and how we use it. If you are interested particularly in the information we collect on this website, please go to the Section titled “Data Collected On Our Website.” This privacy policy addresses both information collected from third parties and through this website. Data Axle is a member of the Association of National Advertisers (“ANA”), and we adhere to the principle that consumers should have choices regarding how marketers use their data and market to them. For information about how to opt out of our database, or out of certain services provided by our business partners, please go to our section titled “Your Choices and Rights.” 2. The Types of Data That We Obtain and Use Data Axle receives data from, and handles data on behalf of, a variety of consumer-facing companies, applications and services, business-facing companies, and data compilers and suppliers. We also may obtain data through public sources, such as census data and other public records. Some of the data we receive, use and make available is Personal Information (“PI”) or is linked to PI. PI includes, for instance, name, postal address, telephone number or email address. In addition, some of our services involve using and making available “business to business” (“B2B”) data, which is obtained from a number of sources, including public directories, filings and publications, surveys and subscriptions. We also collect certain information when you visit our website, https://www-dev.data-axle.com, as described in the below section titled “Data Collected On Our Website.” 3. Our Services and How We Use Personal Information We use and make available PI for various purposes in connection with the products and services we offer. For instance: a. We help marketers to deliver, target and optimize direct mail and email campaigns, display, mobile and social media marketing; b. We help marketers to measure the effectiveness of ad campaigns (online and offline), such as by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases; c. We create sets of consumer attributes – categories of personal interests that are grouped together based on common interests or preferences (“Data Segments”). These Data Segments may be associated with a person, household, or when used online, a unique online identifier, such as enjoying sports, travel, living in a middle-class neighborhood, or being a member of a certain profession. Marketers may use these Data Segments to tailor more relevant ads and offers to groups of users, or to learn more about their own customers and improve their own databases. d. We provide other data services, such as (but not limited to) verification, record look-ups, anti-fraud services, B2B records and services, and other analytics and database tools. We may use PI and Data Segments to help marketers and other data platforms perform “cross-channel” marketing – analyzing, locating and creating potential marketing “audiences” through multiple channels, e.g., web and mobile, or TV/radio. In addition, when we work with online marketing applications such as through web-based, mobile, or cable TV technologies, these marketing applications may de-identify PI (such as by creating a “hashed” version of an email address, or another associated identifier) in order to reach consumers through online display media. These marketing applications use cookies and similar technologies, often associated with unique online identifiers. Similarly, when we interact with consumers online, such as through a website or online ad or an email, we may employ cookies and similar technologies, which also may contain unique online identifiers. To learn more about these technologies, please go to the below section titled “Cookies, Web Pixels and Similar Technologies”, and to opt out of the use of these technologies by many marketing applications that employ them for third party behavioral tracking and similar types of ad targeting, please go to the below section titled “Your Choices and Rights.” The above is not necessarily an exclusive description of the ways we may employ PI and other data. (You may learn more about our products and services by reviewing descriptions of our services on our website.) Generally, however, by permitting marketers to reference PI and other data when they send offers to their customers and others, we do so to help increase the likelihood that marketers will send relevant and desired, rather than unwanted offers, content, coupons and ads. 4. Data Collected On Our Website This website itself is primarily directed to businesses that may wish to use our services, but we welcome consumers who want to know more about our services. When you access this website or engage with us by email, we may collect the following information: a. Personal Information. When you provide us with information through our website, such as to request or download information, sign up for a newsletter, event or service, or log in to a service or application we provide, we may request and you may provide certain PI to us. We may use your PI for any business purpose, including to administer your account and provide you services, to send communications and administrative emails, to respond to your inquiries, and to send marketing and product update messages. We may also use it to analyze how customers are using our website or services. b. Non-Personal Information. Whether or not you sign up for an account or provide us with PI, we may collect other information when you visit our website. This may include: i. The type of browser and operating system you have used to access the website, a time-stamp, and other browser or device information; ii. Your IP address (which is a number automatically assigned to your computer when you access the Internet and can be used to derive your general geographic location); iii. Your clickstream data and any URL referral information (such as any website or social media platform that referred you to our website); iv. What part(s) of our website you visit, click and view, and how long you view it; v. A unique identifier, which we may associate with a cookie, device identifier or similar technology. We may collect or store the above information by using cookies, web beacons, and similar technologies, and may target or retarget ads to you using those cookies, device identifiers, or similar technologies, when you browse the Internet or use your mobile device. We may combine any information including PI you provide to us. While we would be sorry to see you go, you can unsubscribe from our corporate emails by accessing the “opt out” or “unsubscribe” (or similar) link we provide in the footer of each email that we send. Keep in mind, however, that even if you delete your account, we may retain your PI to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our agreements and policies, and take other actions permitted by law. Note that even if you unsubscribe or opt-out, we may still send you communications related to your use of and transactions with our services. 5. How We Work With and Share Data With Third Parties Data Axle may share and sell data, including PI and Data Segments, as follows: a. Agents and Service Providers: We may share data, including PI and Data Segments, with agents, business partners and service providers who work on our behalf, or to help us provide services requested by our customers, including to perform any of the services described in this Privacy Policy. We may do so, for instance, to help send or target advertising on behalf of our clients (or ourselves), for analytical purposes, to measure campaigns, or inform future campaigns. We may do so to facilitate the sending of display media, email, or other requested services. b. Partners: We may share or sell data, including PI and Data Segments, with and to business and data partners (such as business partners who provide to marketers their own applications or data services) or with clients, to help provide more tailored advertising and for analytical purposes. c. Corporate transfers: If Data Axle or its significant assets are purchased by another entity, our data will likely be transferred to that entity, including for due diligence prior to any such potential purchase. d. Affiliates, Parents and Subsidiaries: We may share some or all of the data in our possession with affiliated or subsidiary companies. Our affiliates and subsidiaries include (but are not limited to): Direct Media Holdings, Inc.; Direct Media, LLC; GoTime Corporation; infoUSA Inc.; infoUSA Marketing, Inc.; Walter Karl, Inc.; Yesmail, Inc.; and Yesmail International Holdings, Inc. (You may learn more about several of these on this website.) e. As Required by Law or to Protect Any Party: Data Axle may disclose data if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or safety of Data Axle or any other party. f. Data We Collect on Our Website. We use data that you provide to us on our website to market, we may use this data for our business purposes. For instance, if you provide us with your name and email address, we may put your into our proprietary database and send you newsletters about our company, our services, and events. We will provide you a way to opt out of these emails, usually through a link in the email footer. 6. Cookies, Web Pixels, and Similar Technologies This section provides more information about cookies and similar technologies that we and our business partners may use, and how they work. a. Cookies. Cookies are small text files that websites and other online services use to store information about users on users’ own computers. For instance, cookies can be used to store sign-in credentials so that you don’t have to enter them each time you return to a website, or to store other information to make web viewing more customized or efficient upon future visits. Cookies also may store a unique identifier tied to your computer so that web services and content and advertising networks can recognize you across visits to different websites. You can configure your internet browser to warn you each time a cookie is being sent or to refuse all or certain cookies completely. However, this may interfere with the functionality of your web browsing or your ability to fully use many websites. b. Pixels or web beacons. Pixels or web beacons may also communicate information from your Internet browser to a web server. Pixels can be embedded in web pages, videos, or emails, and can allow a web server to read certain types of information from your browser, check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the Web beacon, the IP address of your computer, and the URL of the web page from which the Web beacon was viewed. We sometimes work with partners to enhance our services (e.g. for purposes of retargeting and tailoring ads, or placing browser cookies). These partners may set and access their own cookies, pixel tags and similar technologies on your device, which may have cookies with varying expiration period. Those partners may, likewise, collect various types of anonymous or de-identified information about your browser, device, or browsing activities through use of these cookies. We also may place cookies when you open an email that we send, in order to help understand how email recipients respond to email campaigns, or to learn more (or help our clients learn more) about those recipients. We may use cookies to store your login information and other information on your computer in order for us to improve our website functionality and narrowly tailor our services and products to your specific preferences and interests. When you visit our website, we (or a partner we work with) may place cookies to help us target or re-target marketing to you when you visit other websites or web or mobile applications – for instance, to tell you about our services, events and other information about our company. The use of cookies also helps display relevant content to you as well as assist us in maintaining a secure and usable website. Please note that our business partners may also use cookies and pixels, which we have no control over. For instance, we sometimes provide our clients’ proprietary data lists to companies that de-identify PI and Data Segments and associate them with online cookies or similar technologies (such as mobile identifiers). Some of these partners may also associate online cookies with mobile identifiers (or other device identifiers) in order to associate use identities across browsers, devices, or technologies. 7. Your Choices and Rights a. Opting Out of Data Axle’s Database. You may click here to send an email to us, to opt out of Data Axle’s database. If you do so, please include the following information in your email: (a) first and last name, and (b) current address. We also recommend that you provide us with other addresses you have lived at in the past five years, which may help us to opt you out even if we have not yet acquired your current address information. If you decide to opt out in this way, we will stop using data in Data Axle’s proprietary database to help our customers send or tailor ads and content to you, including through email, direct mail or online display marketing. (It usually takes us between 30 to 60 days to process this opt out through all of our databases.) Doing so will not opt you out of our customers’ or our partners’ databases, only data in Data Axle’s own database – so other companies that we work with may still send ads, offers and content to you. b. Opting Out of Your PI Being Shared with Third Parties or Online Targeting. If you would like to opt out of your PI being shared with third parties, please click here and fill out the form as directed. If you wish to opt out of other third party ad platforms and ad networks (including ones we work with and may have transferred data to in the past), we recommend visiting the opt-out pages offered by the Network Advertising Initiative and the DAA’s AboutAds program. Opting out through the above methods will cause one or more opt-out cookies to be set on your browser or device, to indicate that you have opted out. Opting out in this way won’t prevent you from seeing ads, but it will in many cases lead the companies listed to stop customizing ads based on inferences they have made about you or your interests. Note that opt-outs are browser-specific, so opting out on one browser will not affect a second browser or device that you use. For the same reason, if you buy a new device, change browsers or clear all cookies, you’ll need to perform this opt-out task again. c. Receiving a Copy of, Amending, Modifying, or Deleting Your PI. If you would like to have your PI deleted (subject to certain exceptions) or if you would like to exercise any of your other rights, please send an email to [email protected] and provide us with (a) your first and last name; (b) your current address; and (c) which right you would like to exercise. Please note, additional verification may be required in order to exercise these rights. d. Unsubscribing from Our Emails. In addition, when we send an email to you (whether on our behalf or on behalf of a client), we will provide a way for you to opt out of receiving emails from us in the future. Usually, this appears as an “unsubscribe” or “opt out” link in the footer of the email. e. Deleting or Disabling Cookies. You may delete or disable cookies at any time through your web browser settings. However, choosing to delete or disable cookies may limit your ability to use some features on our websites and services. 8. Contact Policy In certain instances when you enter your PI into a form on our website, such as when you sign up for a free trial for one of our products, you agree that Data Axle and its subsidiaries and affiliates may use your email address and phone number for marketing and analytical purposes, including to contact you regarding Data Axle products. You may opt out at any time by contacting [email protected]. 9. Security and Data Integrity Data Axle takes steps to ensure that the data we possess is housed and transmitted securely. These steps may include various methods of physical and electronic security, firewall protections, encryption and hashing of data, and access controls to PI. However, neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, so this Privacy Policy does not guarantee against that possibility. 10. California Residents If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides you with specific rights regarding your PI, including: (i) the right to know what information we collect, disclose, and sell; (ii) the right to request deletion of your PI, subject to certain exceptions; and (iii) the right to opt out of the sale of your PI. For a description of the PI we collect and how we collect that PI, please see the section above titled “The Types of Data That We Obtain and Use”. For a description of how we use your PI, please see the section above titled “Our Services and How We Use Personal Information”. If you are a California resident and would like to exercise any of these rights under the CCPA, please click here to send an email to us or please click “Do Not Sell My Data” at the bottom of this page. We will respond as soon as we can and within the timeframe permitted under applicable law. We will verify your identity prior to fulfilling your request, which may require government identification. Authorized agents may be utilized by consumers to submit such requests, in which we will take certain measures to verify the consumer’s identity and that the agent has the authority to act on the consumer’s behalf. Please note, we are only required to respond to two such requests per consumer each year. You also have the right not to be discriminated against if you exercise any of your rights under the CCPA. 11. Residents of the European Union and United Kingdom If you are a resident of a European Union member state or the United Kingdom, the General Data Protection Regulation (“GDPR”) and its UK equivalent provides you with specific rights regarding your PI, including: (i) the right to request access to your PI; (ii) the right to correct your PI; (iii) the right to restrict or delete your PI; and (iv) the right to object to our processing of your PI. For a description of the PI we collect and how we collect that PI, please see the section above titled “The Types of Data That We Obtain and Use”. For a description of how we use your PI, please see the section above titled “Our Services and How We Use Personal Information”. If you are a resident of a European Union member state or the United Kingdom and would like to exercise any of these rights under the GDPR, please click here to send us an email with a description of the nature of your request and the PI at issue, if any. We will respond as soon as we can and within the timeframe permitted under applicable law. We will verify your identity prior to fulfilling your request, which may require government identification. 12. EU-U.S. Data Privacy Framework Principles Data Axle and our various affiliates and subsidiaries in the United States participate in the EU-U.S. DPF, the UK-US DPF and the Swiss-U.S. DPF and are committed to comply with the DPF Principles regarding the collection, use, and retention of PI transferred from the European Union, the United Kingdom, and Switzerland to the United States. Please click here https://www-dev.data-axle.com/data-privacy-framework-principles/ to view our Notice on EU-U.S. Data Privacy Framework Principles, which is incorporated into and forms a part of this Privacy Policy. 13. Questions or Concerns If you have questions or concerns about Data Axle’s privacy efforts or data products, please contact us at: Data Axle Inc. Chief Privacy Officer 13155 Noel Rd #1750 Dallas, TX 75240 [email protected] Phone: (402) 836-3377 Fax: (402) 836-7055 (Last updated: September 27, 2023)