Data Trust Privacy Notice
Last Updated: July 1, 2024
Introduction
DT Client Services, LLC (“Data Trust,” “we,” “us,” or “our”) provides high quality data sets to center-right campaigns, political parties, and other political committees; non-profit social welfare organizations and similar groups; and other clients and business partners, including, without limitation, trade associations and corporate entities. Our clients use this data for a variety of activities, including, without limitation, to request information in connection with surveys; to solicit political and other donations; to advocate participation in political, advocacy, or educational activities; and other commercial and non-commercial purposes for which they need to reach a targeted audience.
At Data Trust, protecting your privacy is important. We are committed to transparency about the data we hold and have designed this Privacy Notice (“Notice”) to help you understand the types of information we collect about you, how it is used, with whom it is shared, and the choices you have.
This Notice covers how and why we collect, use, and share your Personal Information including:
- On our website (https://thedatatrust.com) and other digital services where this Notice is posted, and
- When we collect such data from third-party sources in order to develop products and services to help our clients and business partners reach their desired audiences.
Index
- What Personal Information do we collect about you and why?
- How do we collect your Personal Information?
- How do we use your Personal Information?
- How do we share your Personal Information outside of Data Trust?
- What are your choices?
- What are your California privacy rights?
- What are your Nevada privacy rights?
- What are your Colorado, Connecticut, Utah, and Virginia privacy rights?
- How do we secure your Personal Information?
- Third-party websites and services
- International users
- How do we protect the privacy of children online?
- Notice changes
- Who can I contact at Data Trust about this Privacy Notice?
1. What Personal Information do we collect about you and why?
We collect Personal Information about you in order to deliver reliable data sets to our clients and business partners. When we use the term “Personal Information,” also known as “personal data,” we refer to any information relating to an identified or identifiable individual, or as defined under applicable law. We collect the following categories of Personal Information about you, although not all categories or the examples therein may be collected about every individual:
- Identifiers: name, mailing address, e-mail address, telephone number, state voter identification numbers, or other similar information.
- Demographic Information: age, gender, date of birth, marital status, language spoken, veteran or military status, political party, or other similar information.
- Professional Information: occupation, job title, professional memberships, educational background, or other similar information.
- Commercial Information: records of personal property, products or services purchased, obtained, or considered, and other purchasing history.
- Survey Responses: information, feedback, or content you choose to provide when you participate in a survey or research project another organization has conducted.
- Log Details: IP addresses, device information, electronic network activity information, or other similar information.
- Aggregated Data: precinct election returns, census data, or other similar information.
- Inferences: data about you that has been derived from another organization’s use of predictive models. For example, these organizations may provide us inferences about your predicted characteristics and political preferences.
- Sensitive Personal Information: racial or ethnic origin.
To help our clients and business partners reach their desired audiences, we combine the Personal Information we collect about you from other sources. At times, we also use predictive models to draw inferences from this data about your predicted characteristics and political preferences.
2. How do we collect your Personal Information?
In accordance with applicable laws, we collect most of your Personal Information from third-party sources, which include:
- Public records and publicly available databases: we collect Personal Information from publicly available sources, such as government agencies. For example, we collect your Personal Information from state and county voter files. While the Personal Information available in a voter file varies from state to state, your voter file commonly includes Identifiers and Demographic Information, such as your name, address, date and place of birth, gender, political party affiliation, phone number, email address, registration date, and, in some cases, your military or veteran status.
- Consumer data vendors and other data suppliers: we purchase Personal Information from consumer data vendors, voter modeling firms, data analytics companies, and other data suppliers with whom we have contractual agreements. These sources provide Personal Information, collected both online and offline, such as your Identifiers, Demographic Information, Professional Information, Commercial Information, Survey Responses, Log Details, Aggregated Data, and Inferences.
- Our clients and business partners: our clients and business partners also provide us with Personal Information they collect about you, which may include your Identifiers, Demographic Information, Professional Information, Commercial Information, Survey Responses, Log Details, Aggregated Data, and Inferences.
We collect Personal Information directly from you in the following circumstances:
- When you contact us with comments or questions: you may submit questions, comments, and concerns via telephone or through our website via the “Contact” web form (https://thedatatrust.com). To assist you, we will ask for certain Identifiers, which include your name, email address as well as your question or comment and any other information you choose to provide. This information helps us respond to your inquiries and improve our service to you.
- When you request Data Trust updates: our website also allows you to sign up for updates, such as our newsletters or promotional messages. To receive our updates, we require you to provide your email address. You can always stop marketing communications by unsubscribing as instructed in each email, or by contacting us at [email protected].
- When you navigate our website on any device: we may use automatic data collection technologies to collect Personal Information about you, such as Log Details and Location Data. The technologies we use for automatic data collection include cookies and web beacons. These technologies help us maintain our website and improve your experience by remembering the information that you have already provided to us. We also may collect information about you over time and across websites when you visit our website. Please see Section 5 (“What are your choices?”) below for more information about the choices that may be available to you when you visit our website.
3. How do we use your Personal Information?
We use your Personal Information for a variety of purposes, which include:
- To analyze and create data sets by combining the Personal Information we collect about you;
- To provide data sets to our clients and business partners;
- To provide, maintain, and improve our products and services, and to develop new products and services for our clients and business partners;
- To onboard data sets to online platforms on behalf of our clients and business partners for use in digital marketing campaigns;
- To process orders and transactions;
- To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products, and services you request from us;
- To send you the newsletters and promotional content you request;
- To respond to your requests or questions, or to facilitate your requests under applicable law;
- To establish, exercise, and defend legal claims and to monitor and report compliance issues under applicable law;
- To manage and secure our website, network systems, and other assets (for example, security protection and fraud prevention); and
- For purposes otherwise permitted by applicable law or as we may notify you.
4. How do we disclose, share, or sell your Personal Information outside of Data Trust?
We have disclosed, shared, or sold Personal Information that we collect about you with the following categories of third parties:
- Service providers: to contractors, service providers, and other parties we use to support our business or in connection with administration and support activities. These companies are bound by contractual obligations to keep Personal Information confidential and use the data only for the purposes for which it has been disclosed to them (e.g., database hosting providers, managed service providers, developers, payment processing, consultants, etc.). We have disclosed Personal Information to our service providers, including your Identifiers, Demographic Information, Professional Information, Commercial Information, Survey Responses, Log Details, Location Data, Aggregated Data, and Inferences.
- Our clients and business partners: we sell Personal Information to our clients and business partners. The Personal Information we sell to our clients and business partners may include your Identifiers, Demographic Information, Professional Information, Commercial Information, Survey Responses, Log Details, Aggregated Data, and Inferences.
- Social networks and online platforms: we disclose Personal Information with social networks and online platforms in order to onboard data sets to these platforms on behalf of our clients and business partners for use in digital marketing campaigns. The Personal Information we disclose to social networks and online platforms include yourIdentifiers, Demographic Information, Professional Information, Commercial Information, Survey Responses, Log Details, Aggregated Data, and Inferences.
- Data analytics providers: we disclose Personal Information to data analytics providers to ensure the accuracy of our data sets. Data analytics providers may, for example, offer us data “hygiene” services (e.g., aiding our evaluation, validation, and correction of Personal Information), or such entities may help us append Personal Information (e.g., connecting data across multiple data sets). We may provide data analytics providers with your Identifiers, Demographic Information, Professional Information, Commercial Information, Survey Responses, Log Details, Aggregated Data, and Inferences.
- Government and law enforcement: we may disclose your Personal Information if permitted or required by law or in response to a law enforcement or other legal request and/or to comply with a judicial proceeding, court order, or legal process.
- Successors: in the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, Personal Information that you provide, other information concerning your relationship with us, or Personal Information that we otherwise collect about you in accordance with applicable law. We also may disclose this information in connection with the due diligence for any such transaction. Any acquirer or successor of Data Trust may continue to use your data as set forth in this Notice.
- With your consent: to anyone for whom you have authorized disclosure of information.
- Other: we may disclose your Personal Information for any other purpose disclosed by us when you provide the information.
5. What are your choices?
- Newsletter Opt-out: you can opt out of receiving one of our e-mail newsletters by following the instructions for unsubscribing contained in the e-mails or by contacting us at [email protected] and asking to be removed from the mailing list.
- Do Not Track: currently, we do not alter our data collection and use practices in response to Do-Not-Track signals.
- Cookies: you can disable cookies at any time by adjusting your browser settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. Please note that by disabling such technologies, you may not have access to the entire set of features of our website. For more information about cookies, including links to web browser instructions for disabling and managing such technologies, visit https://optout.networkadvertising.org/.
6. What are your California privacy rights?
If you are a resident of California, the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) (Cal. Civ. Code §§ 1798.100 et seq.) (collectively, “California Law”) provides you with certain rights regarding your Personal Information.
Collection, Use, and Disclosure of Your Personal Information
The table below identifies the categories of Personal Information we have collected (as defined by the California Law), the categories of sources of such data, and the purposes for collection in the twelve (12) months preceding the effective date of our Notice:
Categories of Personal Information as defined by California Law | Categories of Sources | Purposes for Collection |
Identifiers (e.g., real name, address, email address, telephone number, state voter identification numbers, Internet Protocol address, or other similar identifiers) |
|
|
Protected Classifications (e.g., age, race, sex, military status, etc.) |
|
|
Commercial Information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing histories or tendencies) |
|
|
Internet or other similar network activity (e.g., browsing history, search history, information on a consumer’s interaction with a website) |
|
|
Sensory data (e.g., audio or electronic information) |
|
|
Employment or other professional information (e.g., current or past job history) |
|
|
Inferences drawn from personal information (e.g., profile reflecting a person’s preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes) |
|
|
In the twelve (12) months preceding the effective date of our Notice, we have disclosed for a business purpose and/or sold your Personal Information as described in the table below:
Categories of Personal Information | Categories of Third Parties to whom Personal Information is Disclosed | Sold? |
Identifiers (e.g., real name, address, email address, telephone number, state voter identification numbers, Internet Protocol address, or other similar identifiers) |
| Yes |
Protected Classifications (e.g., age (40 years or older), race, sex, military status, etc.) |
| Yes |
Commercial Information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing histories or tendencies) |
| Yes |
Internet or other similar network activity (e.g., browsing history, search history, information on a consumer’s interaction with a website) |
| Yes |
Sensory data (e.g., audio, electronic, visual, thermal, olfactory, or similar information) |
| No |
Employment or other professional information (e.g., current or past job history) |
| Yes |
Inferences drawn from personal information (e.g., profile reflecting a person’s preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes) |
| Yes |
We do not sell the Personal Information of minors under the age of sixteen (16) without affirmative authorization. For more detailed information about how your Personal Information is shared, please refer to ‘Section 4 (“How do we disclose, share, or sell your Personal Information outside Data Trust?”)’.
Your Rights Under California Law
You have rights under California Law. Instructions on how to exercise these rights are listed immediately below in the “How to Exercise Your California Law Rights” subsection.
- Right to Know: When you exercise your “right to know,” we will provide you with:
- Individualized Information about Collection, Processing, Sales, Shares or Disclosure: We will disclose the categories of Personal Information that we collect about you, the categories of sources from which the Personal Information was collected, the business or commercial purposes for which the Personal Information is collected, shared, or sold, and the categories of third parties with whom we disclose the Personal Information.
- Access to Specific Information: We will disclose the specific pieces of Personal Information we have collected about you over the twelve (12) months preceding the request.
- Right to Delete: 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 verify your request, we will delete (and, where required, direct our service providers, contractors, and third parties to whom we have sold and shared your Personal Information to delete) your Personal Information from our records unless an exception under California Law applies.
- Right to Correct Inaccurate Personal Information: You have the right to request that we correct any of your Personal Information that we maintain about you.
- Right to Opt-out of Sale or Sharing of Personal Information: You have the right to opt out and request that the Data Trust not sell or share your such information. To exercise the right to opt-out, you (or your authorized agent) may submit a request to us. Once you make a verified opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales or sharing.
- Right to Limit the Use and Disclosure of Sensitive Personal Information: The Data Trust may use and disclose your sensitive personal information for purposes other than those provided for under California Law. In such instances, you have the right, subject to certain exceptions, to limit how the Data Trust uses and discloses your sensitive personal information.
- Right to Non-Discrimination: We do not discriminate against you for exercising any of your privacy rights under California Law or applicable law, including discrimination in the form of: denying you goods or services; charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing you a different level of quality of goods or services; or suggesting that you will receive a different price or rate for goods or services or a different level of quality of goods or services.
How to Exercise Your California Law Rights
To exercise the rights described above, please submit a request to us by:
- Submitting a request form; or
- Calling us toll-free at (855) 695-5575
Before we can process your request, we need to verify your identity. During the verification process, depending on the nature of your request (e.g., whether you are seeking to access specific pieces of Personal Information or requesting a deletion of Personal Information) we will verify your identity against known information in our databases, such as your name, e-mail address, physical address, and telephone number.
When we receive your request, we also may contact you via e-mail, telephone, and/or other secured communication channels to verify your identity. Where you request access to the specific pieces of Personal Information we hold about you or deletion of your Personal Information, we may ask you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.
In certain instances (e.g., where there is a mismatch against known information in our databases or where you are seeking information on behalf of another person without authorization), we may seek additional verification from you, which may be in the form of a notarized attestation or by asking you additional questions to ensure you are the consumer whose Personal Information is the subject of the request.
Exercising California Law Rights for Someone Else
In order to designate someone to act on your behalf, we must verify your identity and your agent’s identity. We also collect proof that your agent is authorized to make a request on your behalf through a signed written authorization and where appropriate, proof that the agent has power of attorney or is otherwise registered with the California Secretary of State. Absent such documentation, we reserve the right to refuse to comply with third-party requests for information.
Response Timing
Once we have verified a request from a California consumer, where required, we will confirm receipt of the request within 10 days and explain how we will process the request. We aim to respond to a verifiable consumer request within forty-five (45) days of its receipt. When additional time is needed, we may take up to an additional forty-five (45) days (for a maximum total of 90 days) to comply with the request, and we will inform you of the reason(s) why the extension is necessary within the first forty-five (45) days of receiving your request. Our responses will include required information under California Law.
Shine the Light
If you reside in California, you have the right to request from us one time each year the name and addresses of third parties who have received Personal Information and the categories of Personal Information revealed regarding our disclosure of your Personal Information to third parties for those third parties’ direct marketing purposes. To make a request, please send us an email or write to us at the address listed below in Section 14 (“Who can I contact at the Data Trust about this Privacy Notice?”). Indicate in your email or letter that you are a California resident making a “California Shine the Light” inquiry.
Data Retention
We may retain all categories of your Personal Information described above for as long as needed to carry out the purposes described herein or as otherwise required by applicable law. Unless we are required or permitted by law to keep your Personal Information for a longer period of time, when your Personal Information is no longer necessary to carry out the purposes for which we process it, we will delete your Personal Information or keep it in a form that does not permit identifying you. When determining the retention period, we take into account various criteria, such as the nature of the use of our services, your general relationship with us, the impact on our ability to provide you services if we delete your Personal Information, mandatory retention periods provided by law and the statute of limitations, and our use of your Personal Information for aggregated market research.
California Law Consumer Request Metrics
The following metrics are based on requests received from “consumers” as the term is defined by California Law. These are representative of the 2023 calendar year, from January 1, 2023 through December 31, 2023.
| Request Type | Number of Requests | Number of Requests Complied With in Whole or in Part | Number of Requests Denied | Mean Number of Days Within Which We Substantively Responded |
|---|---|---|---|---|
| Right to Know | 7 | 0 | 7 | 20 |
| Right to Delete | 12 | 12 | 0 | 22 |
| Right to Know & Delete | 3 | 3 | 0 | 8 |
| Right to Opt Out | 4,627 | 4,627 | 3,929 | 37 |
Mean number of days within which the Data Trust substantively responded to requests to know, requests to delete, and requests to opt-out: 37
7. What are your Nevada privacy rights?
If you are a resident of Nevada, Nevada provides you with the right to opt out of the sale of certain personally identifiable information (“Covered Information”) maintained by the Data Trust.
Sale of Your Covered Information
In the course of business, the Data Trust collects, maintains and sells the following types of Covered Information to third parties for monetary consideration.
- First and last name;
- Home or other physical address containing the name of a street and the name of a city or town;
- Email address;
- Telephone number; and/or
- Similar identifiers allowing a person to be contacted either physically or online.
Your Rights Under Nevada’s Privacy Law
In Nevada, you have the right to opt-out of the sale of your Covered Information. To exercise your opt-out right, please submit a request to us by:
- Submitting a request form; or
- Calling us toll-free at (855) 695-5575
Before we can process your request, we need to verify your identity. During the verification process, we will verify your identity against known information in our databases, such as your name, email address, physical address, and telephone number. When we receive your request, we may also contact you via email, telephone, and/or other secured communication channels to verify your identity.
In certain instances (e.g., where there is a mismatch against known information in our databases), we may seek additional verification from you, for example by asking you additional questions to ensure you are the consumer whose Covered Information is the subject of the request.
Response Timing
We aim to respond to a verified request within sixty (60) days of its receipt. When additional time is needed, we may take up to thirty (30) additional days (for a maximum total of 90 days) to comply with the request, and we will notify you of any such extension.
8. Additional State Privacy Rights
If you are a resident of Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia, your state’s privacy law provides you with certain rights regarding your Personal Information, also known as “personal data.” This “Additional State Privacy Rights” section supplements this Notice and applies solely to residents of Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia. Any terms not defined in this section have the same meaning as defined under applicable Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia privacy law, including the Colorado Privacy Act, Connecticut Data Privacy Act, Montana Consumer Data Privacy Act, Oregon Consumer Privacy Act, Texas Data Privacy and Security Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act. Subject to certain exceptions, if you are a resident of one of these states, you have certain privacy rights which may include, depending on your state of residency:
- Right to Access: You have the right to confirm whether we process your Personal Information and the right to access such Personal Information. You also have the right to obtain your Personal Information in a portable, and to the extent reasonably feasible, readily usable format that you can transmit without hindrance. In addition, Oregon residents have the right to receive a list of specific third parties to which Data Trust has disclosed Personal Information.
- Right to Delete: You have the right to request that we delete any of your Personal Information that you have provided to us or that we have otherwise obtained about you.
- Right to Correct Inaccurate Personal Information: Except for the residents of Utah, you have the right to request that we correct any of your Personal Information that we maintain about you, taking into account the nature of the Personal Information and the purposes of the processing of your Personal Information.
- Right to Opt Out: You have the right to opt out of the processing of your Personal Information for the purposes of (i) targeted advertising, (ii) the sale of your Personal Information and (iii) except for residents of Utah, profiling in furtherance of decisions, including, for residents of Connecticut and Montana, solely automated decisions, that produce legal or similarly significant effects. Please note that we do not currently engage in such profiling as defined under applicable law.
NOTICE: We may sell your sensitive personal data. This notice is required pursuant to certain state privacy laws. Data Trust does not sell sensitive personal data collected from website visitors; however, it may disclose your sensitive personal data that it collects from the third-party sources identified in Section 2 “How do we collect your Personal Information?” to the parties identified in Section 4 “How do we disclose, share, or sell your Personal Information outside of Data Trust?” - Right to Appeal: Except for residents of Utah, you have the right to appeal our decision with regard to your request to exercise any rights described herein.
To exercise any of your rights under applicable law (including the right to appeal), please submit a request to us by:
- Submitting a request form; or
- Ccalling us toll-free at (855) 695-5575.
9. How do we secure your Personal Information?
We take reasonable precautions and implement appropriate technical and organizational measures to protect the security of your information. However, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to us or any information provided by our on-line products or services, and you do so at your own risk.
10. Third-Party Websites and Services
Our website contains links to other websites. When you enter these other websites using links from our website, you are entering a website for which Data Trust has no responsibility. Data Trust does not control these other websites and cannot guarantee the safety and security of their practices. If you provide any information to these third parties, different rules may govern the collection and use of your Personal Information by such third parties. We recommend that you read those websites’ privacy policies, as they may differ from the policies set forth in this Notice.
11. International Users
Data Trust provides the website (https://thedatatrust.com) for use only by persons located in the United States. If you live outside of the United States, and you use the website or otherwise provide us with Personal Information, you do so on your own initiative and are responsible for compliance with United States federal, state, and local laws. Your information will be handled in accordance with this Notice and subject to U.S. law. By using the website or giving us your information, you are consenting to the transfer of your Personal Information to the United States.
12. How do we protect the privacy of children online?
We do not knowingly collect or disclose Personal Information of children under the age of 18. By accessing our website or initiating any communication with us, you represent that you are at least 18 years old.
If you are aware of any instance in which we have collected data from a minor, please notify us using the contact information provided in Section 12 below.
13. Notice Changes
We may change this Notice from time to time. Please check the “Last Updated” legend at the top of this page to see when this Notice was last revised. Any changes to this Notice will become effective when we post the revised Notice on the website.
14. Who can I contact at Data Trust about this Privacy Notice?
If you would like to contact us for any reason regarding this Notice, you may call us at (855) 695-5575 or send your message to:
Data Trust
1310 N Courthouse Rd
Suite 840
Arlington, VA 22201
Or