=================================================================== --- 20251206_rev01 +++ 20260203_rev01 @@ -209,13 +209,13 @@ Return to navigation ### 8\. CHILDREN'S PRIVACY. The Service is intended for adults and not directed to individuals that are not at least 18 years of age (or 21 years of age in places where 18 years is not the age of majority). In addition, the Service is not available to anyone who is not at least 18 years of age (or 21 years of age in places where 18 years is not the age of majority). If you are not at least 18 years of age, you are not permitted to become a member, or to directly or indirectly view, possess, or otherwise use the Service. -If you are aware that a child or minor uses the Service, please contact us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#1565677c6374766c55717a60777970797c66613b767a78) or using the information provided below so we can take appropriate actions. +If you are aware that a child or minor uses the Service, please contact us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#6616140f1007051f26020913040a030a0f15124805090b) or using the information provided below so we can take appropriate actions. DL does not intend to collect personal information as defined by the U.S. Children's Online Privacy Protection Act **("COPPA") ("Children's Personal Information")** in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children's Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA. Return to navigation ### 9\. INTERNATIONAL TRANSFER. @@ -277,13 +277,13 @@ ### 12\. YOUR STATE PRIVACY RIGHTS. ##### a. California Residents. 1. **Your California Privacy Rights Regarding Disclosures for Third-Party Marketing **("Shine the Light" Law)**.** -We do not share personal information as defined by California Civil Code Section 1798.83 **("Shine the Light Law")** with third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#4d3d3f243b2c2e340d2922382f212821243e39632e2220) or by sending a letter to Doublelist; ATTN: Legal Department, 2261 Market Street #4626, San Francisco, CA 94114. Any such request must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address. +We do not share personal information as defined by California Civil Code Section 1798.83 **("Shine the Light Law")** with third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#bdcdcfd4cbdcdec4fdd9d2c8dfd1d8d1d4cec993ded2d0) or by sending a letter to Doublelist; ATTN: Legal Department, 2261 Market Street #4626, San Francisco, CA 94114. Any such request must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address. 4. **California Privacy Notice.** **Effective Date of Notice:** January 1, 2022 This California Privacy Notice **("Notice")** applies to **"Consumers"** as defined by the California Consumer Privacy Act (together with its regulations, the **"CCPA")** as a supplement to DL's Privacy Policy and any other privacy policies or notices. In the event of a conflict between any other DL policy, statement or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA. Please see also any the general privacy policy or notice posted or referenced on our websites, apps, products, or services. @@ -293,16 +293,94 @@ Consistent with the CCPA, job applicants, current and former employees and independent contractors **("Personnel")**, and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered "Consumers" for purposes of this California Privacy Notice or the rights described herein. Publicly available information is also not treated as PI under the CCPA, so this notice is not intended to apply to that data and your Consumer privacy rights do not apply to that data. Terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA. ##### (1) Personal Information We Collect. In 2021, we collected, retained, used, and disclosed PI about California Consumers as follows: -

Category of PI

Examples of PI

+| +**Category of PI** -

Identifiers	This may include but is not limited to: a real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Personal Records	This may include information such as: physical characteristics or description, signature, telephone number, zip code, city, billing address, credit card number, debit card number, or any other financial information.
Personal Characteristics or Traits	This may include, but is not limited to: sex, marital status, gender identity, and creed.
Customer Account Details/Commercial Information	This may include, but is not limited to: records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. .
Internet Usage Information	This may include, but is not limited to: browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement.
Geolocation Data	This may include, but is not limited to: precise physical location or movements and travel patterns.
Sensory Data	This may include, but is not limited to: audio recordings of customer care calls.
Inferences from PI Collected	This may include, but is not limited to: creating a profile about a Consumer reflecting the Consumer's preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

+ | +**Examples of PI** + + | +| --- | --- | +| + +**Identifiers** + + | + +This may include but is not limited to: a real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. + + | +| + +**Personal Records** + + | + +This may include information such as: physical characteristics or description, signature, telephone number, zip code, city, billing address, credit card number, debit card number, or any other financial information. + + | +| + +**Personal Characteristics or Traits** + + | + +This may include, but is not limited to: sex, marital status, gender identity, and creed. + + | +| + +**Customer Account Details/Commercial Information** + + | + +This may include, but is not limited to: records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. . + + | +| + +**Internet Usage Information** + + | + +This may include, but is not limited to: browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement. + + | +| + +**Geolocation Data** + + | + +This may include, but is not limited to: precise physical location or movements and travel patterns. + + | +| + +**Sensory Data** + + | + +This may include, but is not limited to: audio recordings of customer care calls. + + | +| + +**Inferences from PI Collected** + + | + +This may include, but is not limited to: creating a profile about a Consumer reflecting the Consumer's preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. + + | + The chart above reflects that categories of PI required by the CCPA. There may be additional information that we collect that meets the CCPA's definition of PI but is not reflected by a category, in which case we will treat it as PI as required by the CCPA, but will not include it when we are required to describe our practices by category of PI. As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information, and may elect not to treat publicly available information as PI. We have no obligation to re-identify information or keep it longer than we need it to respond to your requests. ##### (a) Sources of Personal Information. @@ -331,33 +409,148 @@ In addition, we may collect, retain, and use PI for the purpose of sharing it as set forth in the next section. ##### (c) Sharing of Personal Information. In 2021, we disclosed PI about California Consumers to our service providers, other vendors, including those that facilitate interest-based and other advertising and marketing and/or other third parties, including without limitation as follows: -

Category of PI

Categories of Recipients

+| +**Category of PI** -

Identifiers	Business Purpose Disclosure: Service Providers (e.g., IT service providers, marketing service providers, security providers) Third Parties (where the disclosure is not a sale, e.g., Other Business Purposes) Sale: Cookie Operators (as defined in the Do Not Sell section below)
Personal Records	Business Purpose Disclosure: Third Parties (where the disclosure is not a sale, e.g., Other Business Purposes) Sale: Not Sold
Personal Characteristics or Traits	Business Purpose Disclosure: Service Providers Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes) Sale: Not Sold
Customer Account Details/Commercial Information	Business Purpose Disclosure: Service Providers Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes) Sale: Not Sold
Internet Usage Information	Business Purpose Disclosure: Service Providers Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes) Sale: Cookie Operators (as defined in the Do Not Sell section below)
Geolocation Data	Business Purpose Disclosure: Service Providers Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes) Sale: Cookie Operators (as defined in the Do Not Sell section below)
Sensory Data	Business Purpose Disclosure: Service Providers Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes) Sale: Not Sold
Inferences from PI Collected	Business Purpose Disclosure: Service Providers Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes) Sale: Not Sold

+ | +**Categories of Recipients** + + | +| --- | --- | +| + +**Identifiers** + + | + +**Business Purpose Disclosure:** + +- Service Providers (e.g., IT service providers, marketing service providers, security providers) +- Third Parties (where the disclosure is not a sale, e.g., Other Business Purposes) + +**Sale:** Cookie Operators (as defined in the Do Not Sell section below) + + | +| + +**Personal Records** + + | + +**Business Purpose Disclosure:** Third Parties (where the disclosure is not a sale, e.g., Other Business Purposes) + +**Sale:** Not Sold + + | +| + +**Personal Characteristics or Traits** + + | + +**Business Purpose Disclosure:** + +- Service Providers +- Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes) + +**Sale:** Not Sold + + | +| + +**Customer Account Details/Commercial Information** + + | + +**Business Purpose Disclosure:** + +- Service Providers +- Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes) + +**Sale:** Not Sold + + | +| + +**Internet Usage Information** + + | + +**Business Purpose Disclosure:** + +- Service Providers +- Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes) + +**Sale:** Cookie Operators (as defined in the Do Not Sell section below) + + | +| + +**Geolocation Data** + + | + +**Business Purpose Disclosure:** + +- Service Providers +- Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes) + +**Sale:** Cookie Operators (as defined in the Do Not Sell section below) + + | +| + +**Sensory Data** + + | + +**Business Purpose Disclosure:** + +- Service Providers +- Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes) + +**Sale:** Not Sold + + | +| + +**Inferences from PI Collected** + + | + +**Business Purpose Disclosure:** + +- Service Providers +- Third Parties (where the disclosures is not a sale, e.g., Other Business Purposes) + +**Sale:** Not Sold + + | + For more information on your do not sell rights, see the Do Not Sell subsection below. ##### (2)California Consumer Privacy Rights. -We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any request you submit to us is subject to an identification and residency verification process **("Verifiable Consumer Request")** as more fully explained in the Right to Know and Right to Delete sections below. We will not fulfill your Right to Know or Right to Delete request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. To make a request, email us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#601012091601031920040f15020c050c0913144e030f0d) or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquires we may make. +We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any request you submit to us is subject to an identification and residency verification process **("Verifiable Consumer Request")** as more fully explained in the Right to Know and Right to Delete sections below. We will not fulfill your Right to Know or Right to Delete request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. To make a request, email us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#2656544f5047455f66424953444a434a4f55520845494b) or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquires we may make. Some PI we maintain about Consumers is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer's PI when a Consumer request that requires verification pursuant to the CCPA's verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA we do not include that PI in response to those requests. If we cannot comply with a request, we will explain the reasons in our response. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose. We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose and otherwise use and to respond to your California Consumer privacy rights requests. In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest that you receive the most recent or a summary of your PI and give you the opportunity to elect whether you want the rest or not. We reserve the right to direct you to where you may access and copy responsive PI yourself. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request. Consistent with the CCPA and our interest in the security of your PI, we will not deliver to you financial account number, or an account password in response to a CCPA request; however, you may be able to access some of this information yourself through your account if you have an active account with us. Your California Consumer privacy rights are as follows: ##### (a) Right to Know. -To make a Right to Know (Categories) or Right to Know (Specific Pieces) request, email us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#1565677c6374766c55717a60777970797c66613b767a78) or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquiries we make. We will respond to your request as outlined in the How to Submit a Request Under the CCPA section below. Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request. +To make a Right to Know (Categories) or Right to Know (Specific Pieces) request, email us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#6212100b1403011b22060d17000e070e0b11164c010d0f) or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquiries we make. We will respond to your request as outlined in the How to Submit a Request Under the CCPA section below. Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request. ##### **(i) Categories** You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date: - The categories of PI we have collected about you. @@ -378,13 +571,13 @@ ##### **(b) The Right to Delete.** You may request that we delete your PI that we have collected directly from you and are maintaining. However, we may have a basis for retention under CCPA.. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. Note also that we are not required to delete your PI that we did not collect directly from you. For Delete requests, as required by the CCPA, we will apply the verification standards set forth in the How to Submit a Request Under the CCPA section below. -To make a Right to Delete request, email us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#8cfcfee5faedeff5cce8e3f9eee0e9e0e5fff8a2efe3e1) or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquiries we make. +To make a Right to Delete request, email us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#a6d6d4cfd0c7c5dfe6c2c9d3c4cac3cacfd5d288c5c9cb) or follow the instructions at our Consumer Rights Request page here and respond to any follow up inquiries we make. Deletion of your personal information will not deactivate your account. As a result, we cannot delete personal information necessary to maintain the account. If you would like to deactivate your account, please follow the instructions in your account settings or email us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection). ##### (c) Do Not Sell. As noted in our Privacy Policy above, there may be cookies and other Tracking Technologies on our Service that may provide data, which may be treated as PI under the CCPA, to other parties that may use it for their own purposes, which in turn may provide that data to other parties for their own purposes. We do not believe that we sell PI collected by third-parties that operate their own cookies in association with our Services **("Cookie Operators")**. Cookie Operators collect PI that falls under the other identifiers (e.g., cookie ID, IP address, and other online IDs) and internet or other electronic activity information categories. However, we will treat PI collected by Cookie Operators, where not limited to acting as our service provider, as a sale and subject to a Do Not Sell opt-out request. We offer a cookie management tool that enables you to exercise your Do Not Sell opt-out request and enable certain cookie preferences on your device here. You must exercise your preferences on each of our websites you visit and from each browser and on each device that you use. Since your opt-out is designated by a cookie, if you clear or block cookies, your preferences will not be effective and you will need to enable them again via our cookie management tool. For additional information on cookies and alternative choices regarding them, including how to opt-out of certain interest-based advertising, see the Cookies and Tracking Technologies sections of our Privacy Policy above. @@ -413,13 +606,13 @@ - **Right to Know (Specific Pieces):** We are required to verify a Consumer's request to know specific pieces of PI to a reasonably high degree of certainty, which may include matching at least three data points provided by the Consumer with data points maintained by us, which we have determined to be reliable for the purpose of verifying the Consumer together with a signed declaration under penalty of perjury that the requestor is the Consumer whose PI is the subject of the request. If you fail to provide the data points we will be unable to verify you sufficiently to honor your request, but we will then treat it as a Right to Know (Categories) request. - **Do Not Sell:** No additional verification required. - **Right to Delete:** We are required to verify a Consumer's request to delete to a reasonable degree of certainty, which may include matching at least two data points provided by the Consumer with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by the Consumer with data points maintained by us, depending on the sensitivity of the PI and the risk of harm to the consumer posed by unauthorized deletion. If you fail to provide the data points specified above, we will be unable to verify you sufficiently to honor your request. ##### (b)Authorized Agents. -Authorized agents may exercise rights on behalf of California Consumers, but we reserve the right to also verify the Consumer's identity directly as described above. Authorized agents must contact us to submit a request by emailing us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#ea9a98839c8b8993aa8e859f88868f8683999ec4898587) or follow the instructions at our Consumer Rights Request page here and indicating that they are submitting a request as an agent. We will require the agent to demonstrate authority to act on behalf of the Consumer by providing, for example, evidence of the agent's identity, proof of registration with the California Secretary of State (if the agent is a business), and at least one of the following evidencing proof of the agent's legal authority to act on behalf of the individual Consumer: +Authorized agents may exercise rights on behalf of California Consumers, but we reserve the right to also verify the Consumer's identity directly as described above. Authorized agents must contact us to submit a request by emailing us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#2353514a5542405a63474c56414f464f4a50570d404c4e) or follow the instructions at our Consumer Rights Request page here and indicating that they are submitting a request as an agent. We will require the agent to demonstrate authority to act on behalf of the Consumer by providing, for example, evidence of the agent's identity, proof of registration with the California Secretary of State (if the agent is a business), and at least one of the following evidencing proof of the agent's legal authority to act on behalf of the individual Consumer: - presenting a Power of Attorney granted under the Probate Code that we can reasonably verify; or - signed permission by the Consumer. We may also require the Consumer to verify their own identity directly with us and to directly confirm with us that they provided the authorized agent permission to submit the request. @@ -428,21 +621,21 @@ ##### (4)Limitation of Rights. Notwithstanding anything to the contrary, we may collect, use, and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party's rights or conflict with applicable law. ##### (b) Nevada Residents. -Although we do not "sell" "covered information" of Nevada "consumers" as those terms are defined by Chapter 603A of the Nevada Revised Statutes, you may contact us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#e494968d9285879da4808b91868881888d9790ca878b89) and register an e-mail contact address for us to provide you notice in the event we should do so in the future, at which point you will have an opportunity to be verified and exercise your opt-out rights under that law. Contact us in the same manner to update your contact email for notices. Changing your email elsewhere (e.g., informational requests, account information, etc.) will not update your Nevada notice contact information. It is your responsibility to keep your notice contact information current. +Although we do not "sell" "covered information" of Nevada "consumers" as those terms are defined by Chapter 603A of the Nevada Revised Statutes, you may contact us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#0d7d7f647b6c6e744d6962786f616861647e79236e6260) and register an e-mail contact address for us to provide you notice in the event we should do so in the future, at which point you will have an opportunity to be verified and exercise your opt-out rights under that law. Contact us in the same manner to update your contact email for notices. Changing your email elsewhere (e.g., informational requests, account information, etc.) will not update your Nevada notice contact information. It is your responsibility to keep your notice contact information current. Return to navigation ### 13\. CHANGES TO THIS PRIVACY POLICY. We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not treat your previously collected DL-Collected PII, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent. If you have a subscription to a Service, material changes to the Privacy Policy will only become effective with respect to the aspect of that subscription Service at the end of the then current term unless you otherwise consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable. Return to navigation ### CONTACT US. -If you have any questions about this Privacy Policy, please contact us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#3a4a48534c5b59437a5e554f58565f5653494e14595557) or [here](https://doublelist.com/contact/). +If you have any questions about this Privacy Policy, please contact us at [\[email protected\]](https://doublelist.com/cdn-cgi/l/email-protection#2b5b59425d4a48526b4f445e49474e4742585f05484446) or [here](https://doublelist.com/contact/). Return to navigation

Privacy Policy

Full text changes — 20251206_rev01 to 20260203_rev01