=================================================================== --- 20220127_rev01 +++ 20220416_rev01 @@ -1,34 +1,245 @@ -This policy details how data about you is used when you access our websites and services (together, "DL") or interact with us. If we update it, we will revise the date, place notices on DL if changes are material, and/or obtain your consent as required by law. +### 1) Scope of Privacy Policy -## 1.How we protect your privacy +The Doublelist.com ("DL") Privacy Policy may be found below. In this Privacy Policy, we describe the information that we collect about you, that you provide to us and will be processed by us as you use our website and services. Your use of the DL site, and services constitutes your acceptance of the terms and conditions of the DL Privacy Policy, of our [Terms of Use](https://doublelist.com/about/terms/) and of DL's [Community Guidelines](https://doublelist.com//guidelines/). You are responsible for reviewing and becoming familiar with all of these terms. By providing us with your personal data when using the DL site, services, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the DL site, mobile apps and services. -- We take precautions to prevent unauthorized access to or misuse of data about you. -- Certain personal information, such as account passwords, are stored in encrypted formats. Not even DL has access to that information. -- Please review privacy policies of any third party sites linked to from DL. -- Billing information such as Credit Card numbers are never stored with us or on our servers. These are stored at a PCI Compliant gateway. +DL has created this privacy policy because we value our members and recognize their right to keep personal information private. This statement discloses our information gathering and dissemination practices for the World Wide Web site located at www.Doublelist.com (the "DL"), and other services. We believe very strongly that private information should remain private. We'd like to hear your feedback about this statement. If you have comments or questions, please [Contact Us](https://help.doublelist.com/contact/). -## 2\. Data we use to provide / improve our services and combat fraud / abuse: +Except as otherwise expressly discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties, whether they are other members of DL or other sites/apps throughout the Internet, different rules may apply to their use or disclosure of the personal information you disclose to them. -- data you post on or send via DL, and/or send us directly or via other sites -- data you submit or provide (e.g. email, phone, photos, location). -- web log data (e.g. web pages viewed, access times, IP address, HTTP headers). -- data collected via cookies (e.g. search data and "favorites" lists). -- data about your device(s) (e.g. screen size, DOM local storage, plugins). -- data about your unique device fingerprint(s) (e.g. canvas, web GL.). -- data from 3rd parties (e.g. phone type, geo-location via IP address). +### 2) Information we collect and how we use it -#### 3\. Data we store on our server +#### **Cookies** -- We retain data as needed for our business purposes and/or as required by law. -- We make good faith efforts to store data securely, but can make no guarantees. -- You may access and update certain data about you via your account login. +Our Web site and services set cookies to administer our products, to gather broad demographic information, to deliver content requested by you or specific to your interests, to customize our site and services for you, and to save your username and city so that you don't have to enter it each time you visit. -#### 4\. Circumstances in which we may disclose user data: +Some cookies expire after a certain amount of time, or upon logging out (session cookies), others remain on your computer or terminal device for a longer period (persistent cookies). Our site uses first party cookies (cookies set directly by DL) as well as third party cookies, as described below. -- to respond to subpoenas, search warrants, court orders, or other legal process. -- to protect our rights, property, or safety, or that of users of DL or the general public. -- with your consent (e.g. if you authorize us to share data with other users). -- in connection with a merger, bankruptcy, or sale/transfer of assets. -- in aggregate/summary form, where it cannot reasonably be used to identify you. +**Type of Cookies Used**. +The site and apps use the following technologies: -**International Users** - By accessing DL or providing us data, you agree we may use and disclose data we collect as described here or as communicated to you, transmit it outside your resident jurisdiction. +\- Strictly Necessary Cookies: Used to provide Users with the Services available through our Site to use some of their features, such as the ability to log-in and access to secure areas. These cookies are served by DL and are essential for using and navigating the Site. Without these cookies, basic functions of our Site would not work. Because these cookies are strictly necessary to deliver the Site and our Services, you cannot refuse them. + +\- Analytics/Performance: Used to better understand the behavior of the Users on our Site and improve our Site accordingly, for example by making sure Users are finding what they need easily. The Site use Google Analytics, a web analytic services. The information collected by Google (including your IP address) will be transmitted to and stored by Google on their secured servers. Some Google Analytics cookies expire at the end of your browser session, whilst others can remain for up to two years. + +Please note that if you limit the ability of our website and apps to set cookies, you may be unable to access certain parts of our services and you may not be able to benefit from the full functionality of DL. + +If you access our services on your mobile device, you may not be able to control tracking technologies through the settings. + +#### Registration Form + +Membership on the DL Site and services is completely optional. DL's registration form requires users to give their email address. On our join form, required fields are marked. DL will never share e-mail addresses with third party organizations without your express permission. + +Control of Your Password + +Do not disclose your password to any third parties nor share it with any third parties. If you lose control of your password, you may lose control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password. To change your password you can do so at any time through the Settings page then click Password, and the click Change Password. + +#### Email Addresses and The Way Messaging Works + +You should be aware that DL does not currently have an on-site messaging capabilities. All messaging is done between users directly using their email addresses and email providers. When responding to a post that is posted on DL, DL will deliver your message via email to the post's poster. This message will be delivered along with an email address that you want the post Poster to respond to. The default email DL sends along with your message is the email that you originally used to sign up for an account on DL. This 'respond-to' email address can be changed by you to a different email address when you are sending a message. This allows you to provide a separate, more private email address users can respond to your message. + +#### IP Addresses + +DL tracks individual IP addresses to help diagnose problems with our service, to administer our site and to gather broad information. User IP address information is used only for our internal purposes. + +#### Information We Receive From Your Use of Our service + +When you use our services, the following information is created and automatically logged in our systems: + +Log data: Information ("log data") that your browser or device automatically sends whenever you visit the site or apps when you use it. Log data includes your Internet Protocol ("IP") address (so we understand which country you are connecting from when you visit the site or app), browser type and settings, the date and time of your request, and how you interacted with our services. + +Device information: Includes type of device you are using, operating system, settings, unique device identifiers, network information and other device-specific information. Information collected may depend on the type of device you use and its settings. + +**How we use information** + +We use your personal data for the following purposes: + +To authenticate our users and provide our services. This processing is necessary to perform the contract with you. As necessary for certain legitimate business interests, which include the following: + +- To respond to your inquiries and fulfill your requests for products and services; +- To send administrative information to you, for example, information regarding the site and changes to our terms, conditions, and policies; +- To provide, maintain and improving the content and functionality of our services. For example, we regularly fix bugs or user experience issues that may be tied to particular user accounts. +- If you ask us to delete your data and we are required to fulfill your request, to keep basic data to identify you and prevent further unwanted processing; +- To prevent fraud or criminal activity, misuses of our products or services, and ensure the security of our IT systems, architecture and networks; +- To (a) comply with legal obligations and legal process, (b) respond to requests from public and government authorities including public and government authorities outside your country of residence; (c) enforce our Terms of Use; (d) protect our operations or those of any of our affiliates; (e) protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain, as required or permitted by the law. +- For individuals in the EU, please see the "European Union (EU) Users" section below for information on what we mean by legitimate interests and your rights. + +#### Publicly posted information + +This Privacy Policy shall not apply to any information you post to the public areas of our services. Posts posted to public areas may be viewed, accessed, and used by third parties subject to those parties' privacy practices and policies. + +### 3) When and why we share information + +Notwithstanding anything else in this policy, DL may also disclose personal and aggregate information when required by a valid legal mechanism such as a search warrant, subpoena, or court order, or when we deem it necessary, in our sole discretion, to protect our rights and the safety of others, or our members, employees, or properties. + +DL believes that members' private communications in e-mail conversations should generally remain confidential. DL does not disclose private communications unless ordered to do so through a valid legal mechanism such as a search warrant, subpoena, or court order, to protect the company's rights and property, or during emergencies when we believe safety is at risk. Please remember that what you write or post in public areas such as posts is available to all DL members, and in many cases other visitors to the DL site. Also keep in mind that DL is not responsible for what other users may do with private communications you've had with them. + +We may share or disclose your information at your direction, such as when you authorize a third-party service to access your account or when you voluntarily share information or content via our services. Other Users may share or disclose information about you, such as when they mention you. + +There are certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, unless required by the law, as set forth below: + +- Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions: providers of hosting, email communication and customer support services, analytics, marketing, advertising. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us. +- Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets. +- Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend our rights or property, (iii) act in urgent circumstances to protect the personal safety of Users of the Site, or the public, or (iv) protect against legal liability. + +### 4) Your rights and choices + +**OFF-SITE LINKS** + +The site and apps may contain links to other websites and apps not operated or controlled by us ("Third Party Sites"). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites or apps. Please contact those sites directly for information on their privacy practices and policies. DL is not responsible for the privacy practices or contents of these other sites. + +### 5) Data retention + +We will keep your Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer. + +To determine the appropriate retention period for your Personal Data, we will 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 use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data. + +### 6) Security + +DL implements security measures to help protect your data from loss, theft, misuse and unauthorized access. We take data privacy and security seriously. However, no physical or electronic security system is impenetrable, but all information you provide to us is stored on secured servers.DL takes steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. + +You use our services at your own risk. We can't guarantee the security of the Service's servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet and any transmission is at your own risk. + +We cannot control the actions of other users with whom you may choose to share information. Therefore, we cannot, and do not, guarantee that information or content posted by a user on or through our Services will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on our Services. We ask you not to share a password with anyone. + +### 7) Changes to Policy + +We may update this policy from time to time. If we make any significant changes to the way in which we treat your personal information, we will inform you of such changes via e-mail or by posting a notice on the DL site. If you have any questions about this privacy policy, please feel free to [Contact Us](https://help.doublelist.com/contact/). + +### 8) How you can access your personal information and update your information + +You can access some of the personal information that we collect about you by logging in to your account. You also have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data. + +If you need to change or correct your Personal Data, or wish to have it deleted from our systems, you may also contact us. Please send all requests for data deletion to privacy@doublelist.com. We will address your request as required by applicable law. You may also update your Personal Data from your user settings. + +### 9) Information about children + +Our services are not available to anyone who is not at least 18 years of age. If you are not at least 18 years of age, you are not permitted to become a Member or use our services. + +If you are aware that a child or minor uses our services please contact us using the information provided below so we can take appropriate actions. + +### 10) European and international users + +DL is based in the USA. If you are accessing our Services from the European Union or other regions with laws governing data collection and use, please note that your Personal Data will be transmitted to our servers in the USA and the data may be transmitted to our service providers supporting our business operations (described above). Canada may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. Where we transfer your Personal Data out of the EU we will take steps to ensure that your Personal Data receives an adequate level of protection where it is processed, and your rights continue to be protected. + +By providing your information to the Services you agree to the transfer of your information to the USA and processing globally in accordance with this Privacy Policy. + +### 11) Contacting Us + +If you have any questions about this privacy statement, the practices of this site, or your dealings with this site, please feel free to [Contact Us](https://help.doublelist.com/contact/). + +### 12) California Privacy Disclosure + +Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent. + +This Privacy Notice for California Residents supplements the information contained in Doublelist.com's (DL) Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California. We adopted this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. + +#### a) Information We Collect + +Our website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, our website have collected the following categories of personal information from its consumers within the last twelve (12) months: + +

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

+ +#### b) Use of Personal Information + +We may use or disclose the personal information we collect for one or more of the following business purposes: + +1. To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns. +2. To process your requests, purchases, transactions, and payments and prevent transactional fraud. +3. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses. +4. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. +5. As described to you when collecting your personal information or as otherwise set forth in the CCPA. +6. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our or our affiliates' assets in which personal information held by us or our affiliates about our website users is among the assets transferred. +7. We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice. +8. Sharing Personal Information + +We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. + +We share your personal information with the following categories of third parties: + +- Service providers. + +#### c) Your Rights and Choices + +The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. + +Access to Specific Information and Data Portability Rights + +You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you: + +- The categories of personal information we've collected about you. +- The categories of sources for the personal information we've collected about you. +- Our business or commercial purpose for collecting or selling that personal information. +- The categories of third parties with whom we share that personal information. +- The specific pieces of personal information we've collected about you (also called a data portability request). + +If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: + +- sales, identifying the personal information categories that each category of recipient purchased; and; +- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. + +**Deletion Request Rights** + +You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. + +We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: + +- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. +- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. +- Debug products to identify and repair errors that impair existing intended functionality. +- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.). +- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. +- Comply with a legal obligation. +- Make other internal and lawful uses of that information that are compatible with the context in which you provided it. +- Exercising Access, Data Portability, and Deletion Rights + +To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: + + Emailing us at [privacy@doublelist.com](mailto:privacy@doublelist.com) + +Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. + +- You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: +- Provide enough information that allows us to reasonably verify you are the person about whom we've collected personal information or an authorized representative. +- Describe your request with enough detail that allows us to properly understand, evaluate, and respond to it. + +We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. + +Making a verifiable consumer request does not require you to create an account with us. + +We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. + +**Response Timing and Format** + +We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. + +We will deliver our written response by mail or electronically, at your option. + +Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. + +We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. + +**Personal Information Sales** + +We will not sell your personal information to any party. If in the future, we anticipate selling your personal information to any party, we will provide you with the opt-out and opt-in rights required by the CCPA. + +#### 4) Non-Discrimination + +- We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: +- Deny you goods or services. +- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. +- Provide you a different level or quality of goods or services. +- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. + +#### 5) Other California Privacy Rights + +California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [privacy@doublelist.com](mailto:privacy@doublelist.com) + +#### 6) Changes to Our Privacy Notice + +We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice's effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes. + +#### 7) Contact Information + +If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: + +[privacy@doublelist.com](mailto:privacy@doublelist.com)

Privacy Policy

Full text changes — 20220127_rev01 to 20220416_rev01