Privacy Policy

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 individual. The following tables identify the categories (with non-exhaustive examples) of Personal Data we may collect about Users and Consumers, respectively, by source of data and, for each category, the purposes for which it may be used. Further descriptions are provided below the tables. We may also collect other Personal Data that is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Collection of User Personal Data

Unless we specifically request it, 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.

Collection of Consumer Personal Data

Sources of Personal Data. We collect the above Personal Data from a variety of sources, as further described below.

Sources by Category of User Personal Data

1.1 Personal Data Provided or Generated When Using FullContact Data Services.
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 or edits Registration Information. We also automatically log certain event data about a User’s use of FullContact Data Services.

1.1.a. Account Information. When you sign up for a FullContact Account, we may require certain information to set up your Account. You may optionally choose to sign into your Account 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 associated with your third party account.

1.1.b. Payment Information. All payment processing services connected with your use of FullContact Data Services are provided by third-party payment processors. We do not access or keep information related to User payment cards, banking information, or other financial account information.

1.1.c. FullContact Data Services Related Communications. If you contact or interact with us (for example via support, feedback, surveys, forum, chat, promotions) we may collect information and other content that you provide. We also may create event logs to diagnose FullContact Data Services 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. FullContact Data Services 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, we may log API calls and login frequency.

1.2 Personal Data Provided or Generated When Using Our Platform. We collect information when a User interacts with our Platform.

1.2.a. Contact Information. We may collect your contact information when you attend a conference; subscribe to our email program; participate in one of our promotional sweepstakes, contests, or surveys; post a review; interact with our social media pages, or otherwise provide such information through use of our online or offline Platform.

1.2.b. Customer Service Communications. If you contact or interact with us on the Platform via live chat or webforms, or call customer service, we and our service providers may collect information and content that you provide. Your communications may be monitored or recorded in real time by our third-party service providers.

1.2.c. Internet or Network Activity. We may collect and allow our service providers and other third parties to automatically collect information about you, your computer, or mobile device, and your activity over time with our Platform and other sites and online services. Like many online services, we use cookies and similar technologies to facilitate some of the automatic data collection described above, such as:

• • • Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
    • Flash cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.
    • Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.

For more information, please visit our Cookie Policy.

1.3 Personal Data Received from Lead Generators for Direct Sales/Marketing. We may receive Personal Data from third-party data partners and affiliates.

1.3.a. Prospect Contact Information. In an effort to personalize and provide information about aspects of the FullContact Platform that may be of interest to you, we may collect Personal Data about prospects from third-party sources.

1.4 Personal Data Provided to the “Your Privacy Choices” Portal

1.4.a. Authentication Data. When you (Users and Consumers alike) want to verify your Personal Data through the “Your Privacy Choices” Portal, we may require you to provide certain information prior to granting access to your Personal Data for verification purposes only.

1.5 Personal Data We Collect from Public Sources for Use in the FullContact Data Services. We may 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.

1.5.a. Public Profile Data. Open Data includes information that is in the public domain by you, widely distributed media, a person to whom you disclosed the information without restriction, or federal, state, or government records, and can freely be given to anyone. Personal Data may be collected through our open data sources, such as social media platforms. We share this data through FullContact Data Services, while abiding by relevant terms and conditions of that provider.

1.6 Personal Data We Receive from Data Providers for Use in FullContact Data Services. 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. We do not control how these third parties process your Personal Data.

1.6.a-e. Profiles. We collect contact information, demographic data, professional information, and commercial information from third-party data providers to build consumer profiles for use in FullContact Data Services we offer to Users.

11.6.f. Sensitive Data. Certain 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.

1.6.g. Sensitive KYC Data. We may receive Personal Data from data providers necessary to provide Know Your Customer (KYC) services through our identity verification services (Verify) to Users to verify an individual’s identity and to protect against fraud and other financial crimes. KYC data may include, for example, government issued identification numbers and account login credentials. KYC data is not shared with Users for enrichment purposes, or any purpose other than providing our identity verification services.

2. HOW WE USE PERSONAL DATA

We primarily use, store, and process Personal Data to provide, understand, improve, and develop our Platform, create and maintain a trusted and safer environment, and comply with our legal obligations. We also use Personal Data for the purposes set forth below and as otherwise described in this Privacy Policy or at the time of collection.

2.1 Provide, Maintain, and Support the Platform. Using Personal Data we collect from you, we are able to deliver the Platform to Users 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 Platform, including to 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 Platform support or maintenance messages, updates, security alerts, and Account notifications.

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 Research and Development. We use Personal Data we collect for research and development purposes, including to study and improve the Platform and our business, to understand and analyze the usage trends and preferences of our Users, and to develop new features, functionality, products, and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from Personal Data we collect. We make Personal Data into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including (but not limited to) regulatory compliance, industry and market analysis, demographic profiling, modeling, marketing and advertising, and other business purposes.

2.3 Direct Marketing. We may process User Personal Data for marketing purposes including offering you products and services that may be of interest to you (such as information about FullContact Data 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. Users 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 and as further described in the “YOUR RIGHTS” section below.

2.4 Interest-Based Advertising. We work with third-party advertising companies and social media companies to help us advertise our business and to display ads for our Platform. These companies may use cookies and similar technologies to collect information about Users (including the online activity information and device information described above in paragraph 1.2.c., “Internet or Network Activity”) over time across our Platform and other websites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. In addition, some of these companies may use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms. You can learn more about your choices for limiting interest-based advertising in the “YOUR RIGHTS” section below.

2.5 To Comply with Laws and Regulations. We will use your Personal Data as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

2.6 For Compliance, Fraud Prevention, and Safety. We may use your Personal Data and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the Platform and our business, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the Terms of Use that govern the Platform; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

2.7 With Your Consent. We will disclose your Personal Data in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your Personal Data, such as when required by law.

2.8 Combine Contacts for Identity Resolution Services (Resolve). We combine certain categories of Consumer Personal Data to build more complete contact records of individuals. These Consumer profiles reside in the FullContact identity graph and may be processed for the following purposes in connection with providing Resolve:

• • Grouping contacts and contact elements into unique individuals to create a Consumer profile
  • Generating and returning a unique identifier for an individual and associated Consumer profile
  • Linking (or “matching”) input contact records from our Users to the Consumer profile found in the FullContact identity graph for purposes of identifying an individual, searching for an individual, and/or linking to other contact records associated with the same individual
  • Deduplicating a set of input contact records from our Users based on unique individuals
  • Inferring linkages between and/or deduplicating existing Consumer profiles

For example, someone may search or lookup a contact by name and email address. FullContact connects the name and email with a Consumer profile within the FullContact identity graph for one of the reasons above. No additional Personal Data beyond the unique identifier is returned to the User submitting the search.

2.9 Combine Contacts for Identity Verification Services (Verify). Certain categories of Consumer Personal Data may be made available to our Users in connection with providing Verify. Verify provides the accuracy and recency of contact elements contained within input contact records from Users. We compare the input contact records against the FullContact identity graph to provide a risk score to the User.

2.10 Combine Contacts for Contact Enrichment Services (Enrich). Certain categories of Consumer Personal Data may be made available to our Users in connection with providing Enrich. Enrich is often utilized in combination with Resolve so that, for example, a User is able to match an input contact record to the Consumer profile within our identity graph, and receive back a subset of the contact information from the relevant Consumer profile for that individual 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.

3. HOW WE SHARE PERSONAL DATA

In addition to the specific situations discussed elsewhere in this Privacy Policy or at the point of collection, FullContact may share your Personal Data with the entities or persons set forth below.

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 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.

3.2 Professional Advisors. We may share your Personal Data with persons, companies, or professional firms providing FullContact with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.

3.3 Sweepstakes and Joint Marketing Partners. We may provide User Personal Data for commercial purposes to business partners in order to provide you with the content and other features through the Platform, and such partners may send you promotional materials or otherwise contact you regarding products or services that they believe may be of interest to you. These parties may include such companies as software and hardware providers, consumer product providers, and marketing coops.

3.4 Compliance with Law, Responding to Legal Requests, Preventing Harm, and Protection of Your or Our Rights. Regardless of any choices you make regarding your Personal Data (as described below in “YOUR RIGHTS”), FullContact may disclose your Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation or for the purposes described above in “For Compliance, Fraud Prevention, and Safety”; (b) to comply with applicable laws, including laws outside your country of residence; and (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.

3.5 Service Providers. FullContact uses a variety of third-party service providers to help us provide our Platform, such as website hosting, maintenance services, analytics, marketing, customer relationship management and other purposes. For example, to facilitate payments for FullContact Data Services, 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. FullContact may need to share your Personal Data in order to deliver the Platform to you and honor our Terms of Use.

3.6 Corporate Affiliates. To enable or support us in providing the Platform, we may share your Personal Data 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 Platform, 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 affiliates and subsidiaries.

3.7 Advertising Partners. We may also share User Personal Data with third parties who we partner with for advertising campaigns or that collect information about your activity on the Platform for the purposes described in the “Interest-Based Advertising” section.

3.8 Business Transaction Participants. If FullContact undertakes or is involved in any business transaction involving a merger, acquisition, consolidation, divestiture, reorganization, sale or share of assets, bankruptcy, or insolvency event, then we may disclose your Personal Data to third parties in connection with such transaction, or in preparation for or contemplation of such transaction.

3.9 Clients of FullContact Data Services. To enable or support us in providing FullContact Data Services to clients, we disclose certain Consumer Personal Data to clients of our Resolve, Verify, and Enrich services described in the “HOW WE USE PERSONAL DATA” section.

4. PERSONAL DATA RETENTION

We will retain your Personal Data, including sensitive Personal Data, for as long as is necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. Because we maintain backup to protect our Platform 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. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

5. THIRD PARTY WEBSITES AND SERVICES

The Platform may contain links to other websites, online services, or locations operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third-party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

6. PERSONAL DATA PROTECTION

6.1 Security. We have implemented reasonable and appropriate administrative, technical, organizational, and physical measures to help protect your Personal Data. Some of the safeguards we use to protect your Personal Data are firewalls and data encryption, and information access controls. However, no method of transmission over the Internet, or method of electronic storage, is fully secure and we cannot guarantee the security of your Personal Data. If you know or have reason to believe that your Account ID have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Account, please contact us following the instructions in the “CONTACT US” section below.

6.2. Our International Operations and Data Transfers. FullContact is based in the United States, but we operate globally. We may transfer, store, and process your Personal Data within our family of companies or with service providers based in countries or other locations outside of your home country. Privacy laws in locations where we handle your Personal Data may differ from and not be as protective as the laws applicable to your country of residence. By providing your providing your Personal Data, where applicable law permits, you specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein.Users located in Europe can view more information about cross-border transfers in the section below titled “NOTICE TO EUROPEAN RESIDENTS.”

6.3 Data Privacy Frameworks.  FullContact Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), 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 Inc. 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 in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. FullContact Inc. 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. FullContact’s accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the DPF Principles. In particular, FullContact remains responsible and liable under the DPF Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the DPF Principles, unless FullContact proves that it is not responsible for the event giving rise to the damage. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, UK Extension to the EU-U.S. DPF, 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 https://www.dataprivacyframework.gov/.

With respect to personal data received or transferred pursuant to the Data Privacy Frameworks, FullContact is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. FullContact Inc. has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you. If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf

7. YOUR RIGHTS

7.1 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.

7.2 Cookies. Most browsers let you remove or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Platform and our Platform may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

7.3 Analytics. The Site uses Google Analytics to help us analyze how the Site is being accessed and used. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on, available here.

7.4 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.

7.5 Do Not Track. Some web browsers and devices permit you to broadcast a ”Do Not Track” signal to the online services that your visit. At this time, we do not modify your experience based upon whether a “Do Not Track” signal is broadcast. 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.

7.6 Access, Correction, Deletion, and Opt-Out Requests. FullContact allows any individual, inclusive of both Users and Consumers and regardless of residency, to exercise the following rights with respect to Personal Data that FullContact holds about them. Please note, these rights are not absolute, and, in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

• Right to Know. You have the right to request that FullContact confirm whether we process Personal Data about you and to disclose certain information to you about our collection and use of your Personal Data, including:
  • • The categories of Personal Data we collected about you;
    • The categories of sources from which that Personal Data was collected;
    • Our business or commercial purpose for collecting, selling, or sharing (as applicable) that Personal Data; and
    • The categories of third parties with whom we disclose that Personal Data (as applicable).
• Right to Access/Data Portability. You have the right to request that FullContact provide you access to your Personal Data, including in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity.
• Right to Delete. You have the right to request that FullContact delete any of your Personal Data that we have retained about you, subject to certain exceptions.
• 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 for monetary or other valuable consideration, or shares your Personal Data for cross-context behavioral advertising, you have the right to opt-out. You may exercise these rights by visiting the “Your Privacy Choices” Portal, or broadcasting the Global Privacy Control (GPC) signal. Note that due to technological limitations, if you visit our Platform from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to this Platform to select your preferences or rebroadcast the GPC signal. Additionally, the GPC signal will only opt-out your Personal Data from cross-context behavioral advertising. To opt-out of sales for monetary or other valuable consideration, we may need to collect some identifying information so please submit your request through the “Your Privacy Choices” 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 “Your Privacy Choices” Portal or emailing 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 have provided your consent to the processing of your Personal Data by FullContact, you may withdraw your consent at any time specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your Personal Data, in particular where (a) you contest the accuracy of your Personal Data; (b) the processing is unlawful and you oppose the deletion of your Personal Data; (c) we no longer need your Personal Data for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (d) you have objected to the processing and pending the verification whether the legitimate grounds of FullContact override your own.
• 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. If you object to such processing we will no longer process your Personal Data for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise, or defense of legal claims. Where your Personal Data is processed either by email or cookies for direct marketing purposes, you may, at any time, ask us to cease processing your Personal Data for these direct marketing purposes by changing your preferences here.
• Right to Nondiscrimination. You will not be subject to discrimination as a result of exercising the rights described herein. In some cases, when you exercise one of your rights, we will be unable to comply with the request due to legal obligations or otherwise, or we will be unable to provide you certain products or services. These responses are not discrimination and our reasons for declining your request or ceasing services will be provided at that time.

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 “Your Privacy Choices” Portal.

Authorized Agents: You may designate an authorized agent to make a request on your behalf. If you do so, we may require your proof of identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify your request, including evidence of valid permission for the authorized agent to act on your behalf.

How We Process Your Request: When exercising your rights, or when otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to, for example, ensure we do not disclose Personal Data to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is unfounded, repetitive, or excessive.

We try to respond to all legitimate requests within 30 days of your request. Occasionally it may take us longer than 30 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.

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 “Your Privacy Choices” Portal. We try to respond to appeals within 45 days of receipt. Occasionally, where permitted by law, it may take us longer than 45 days to response based on, for example, the complexity and number of requests serving as the basis for the appeal. We will notify you within the initial 45 days if we need more time to respond to the appeal, together with the reasons for the delay.

8. NOTICE TO CALIFORNIA RESIDENTS

This section describes how we collect, use, sell, share, and retain personal information of California residents when we act as a “business” as defined under California privacy laws. For purposes of this section, Personal Data means “personal information” as defined under California privacy laws but does not include information exempted from the scope of such laws. Additionally, California law defines “sale” as disclosing a California resident’s personal information to a third party for monetary or other valuable consideration. Where such disclosure is for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, it qualifies as “sharing” under California law.

In some cases, we may provide a different privacy notice to certain categories of California residents, in which case that notice will apply instead of this section.

8.1 Personal Data We Collect, Use, and Share. The categories of Personal Data, including sensitive Personal Data, we may collect or have collected about you in the 12 months preceding the last update date of this Privacy Policy, and the categories of sources from which we collect such personal information is set forth in the section above titled “PERSONAL DATA WE COLLECT.”

The purposes for which we collect and use your Personal Data is set forth in the section above titled “HOW WE USE PERSONAL DATA.”

The categories of third parties to whom we disclose, sell, or share your Personal Data, including sensitive Personal Data, and the purposes for such disclosure, sale, or sharing, are set forth in the section above titled “HOW WE SHARE PERSONAL DATA.” We do not knowingly sell or share the Personal Data of California residents under 16 years of age. To opt-out of the sale/sharing of your personal information, please submit your request through the “Your Privacy Choices” Portal or review the “YOUR RIGHTS” section above.

The criteria we use to determine the period of time that Personal Data will be retained is described in the section above titled “PERSONAL DATA RETENTION.”

8.2 Personal Data We Disclose, Sell, or Share and to Whom.

The tables below display the categories of third parties to whom we may have disclosed for a business purpose, sold for monetary or other valuable consideration, or shared for interest-based advertising your Personal Data during the 12 months preceding the last update date of this Privacy Policy. For more information on how Personal Data of our Users and Consumers is disclosed (and the business purposes), sold, and shared, please see the section above titled “HOW WE SHARE PERSONAL DATA,” which provides more detail on these third-party partners.

User Personal Data

Consumer Personal Data

8.3 Annual Data Requests. To view our annual (July 1 to June 30) statistics about consumer data requests received from all individuals, please visit this page.

8.4 Notice of Disclosure for Direct Marketing. California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses that share customer personal information with third parties for the third parties’ direct marketing purposes to respond to requests from California customers asking about the businesses’ practices related to such information-sharing. Alternately, such businesses may have in place a policy not to disclose a customer’s personal information to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. You can opt-out of our sharing of your Personal Data with third parties for their direct marketing purposes by submitting your request through the “Your Privacy Choices” Portal. To find out more about your opt-out rights, please contact us provided below. Please note that under California law businesses are only required to respond to a customer making such a request once during any calendar year.

9. NOTICE TO NEVADA RESIDENTS

Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us using the contact information listed at the end of this Privacy Policy.

10. NOTICE TO EUROPEAN RESIDENTS

The information provided in this section applies to individuals in the European Economic Area and the United Kingdom (collectively, “Europe”). The controller of your Personal Data covered by this Privacy Policy for purposes of European data protection legislation is FullContact Inc., 1580 North Logan St., Suite 660, PMB 45057, Denver, Colorado 80203.

Jason Soni
Data Protection Officer
dpo@fullcontact.com
+1-888-330-6943

10.1 Purposes and Legal Basis for Processing.

• Provide, Maintain, and Support the Platform : This use is based on our legitimate interest to deliver the Platform to Users and to improve and market the same, and for the performance of a contract with Users.
• Research and Development: This use is based on our legitimate interest to deliver the Platform to Users and for the performance of a contract with Users.
• Direct Marketing: This use is based on our legitimate interest in marketing our Platform to Users, for the performance of a contract with Users, and is based on Users’ explicit consent.
• Interest-Based Advertising: This use is based on our legitimate interest in marketing our Platform to Users, for the performance of a contract with Users, and is based on Users’ explicit consent.
• Combine Contacts for Identity Resolution Services: This use is based on our legitimate interest to provide FullContact Data Services to Users.
• Combine Contacts for Identity Verification Services: This use is based on our legitimate interest to provide FullContact Data Services to Users.
• Combine Contacts for Contact Enrichment Services: This use is based on our legitimate interest to provide FullContact Data Services to Users.

We may use your Personal Data for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the applicable legal basis.

10.2 Categories of Recipients of Data. Recipients of data are detailed in Section 3 (“HOW WE SHARE PERSONAL DATA “).

10.3 Lodging Complaints. You have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities. If you would like to submit a complaint about our use of your Personal Data or our response to your requests regarding your Personal Data (see Section 7 above), you may contact us or submit a complaint to the data protection regulator in your jurisdiction. In the European Economic Area, you can find your data protection regulator here. In the United Kingdom, you can find your data protection regulator here.

10.4 Cross-Border Data Transfer. If we transfer your Personal Data to a country outside of Europe such that we are required to apply additional safeguards to your Personal Data under European data protection laws, we will do so. Please contact us at privacy@fullcontact.com for further information about any such transfers or the specific safeguards applied.

We may use your Personal Data for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the applicable legal basis.

11. 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.

12. 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.

13. HOW TO CONTACT US

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

Organization:

FullContact Inc. (a Delaware Company)
1580 North Logan St.
Suite 660, PMB 45057
Denver, Colorado 80203
+1-888-330-6943