1101 14th Street, NW #650 | Washington, DC 20005

Data Trust Privacy Notice

Last Updated: January 31, 2020

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

  1. What Personal Information do we collect about you and why?
  2. How do we collect your Personal Information?
  3. How do we use your Personal Information?
  4. How do we share your Personal Information outside of Data Trust?
  5. What are your choices?
  6. What are your California privacy rights?
  7. How do we secure your Personal Information?
  8. Third-party websites and services
  9. International users
  10. How do we protect the privacy of children online?
  11. Notice changes
  12. 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,” 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, race, 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.
  • Location Data: certain location data may be automatically collected if you access our website  (https://thedatatrust.com) or any digital service that links to this Notice.
  • 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. 

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 info@thedatatrust.com.
  • When you navigate our website on any device: we may collect Personal Information about you, such as Log Details and Location Data, when you visit and navigate our website (https://thedatatrust.com) on any device. 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 share your Personal Information outside of Data Trust?

We have disclosed 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 your  Identifiers, 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.
  • Otherwise with your consent. 

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 info@thedatatrust.com 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.

6. What are your California privacy rights?

If you are a resident of California, the California Consumer Privacy Act (“CCPA”) 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 CCPA), 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 the CCPA

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)

  • Publicly available databases
  • Consumer data vendors
  • Our clients and business partners
  • Directly from you

  • Create, analyze, and provide data sets to our clients and business partners
  • Market our products and services
  • Internal R&D
  • Debugging and security
  • Defend legal claims

Protected Classifications

(e.g., age, race, sex, military status, etc.)

  • Publicly available databases
  • Consumer data vendors
  • Our clients and business partners

  • Create, analyze, and provide data sets to our clients and business partners
  • Market our products and services
  • Internal R&D
  • Defend legal claims

Commercial Information

(e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing histories or tendencies)

  • Publicly available databases
  • Consumer data vendors
  • Our clients and business partners

  • Create, analyze, and provide data sets to our clients and business partners
  • Market our products and services
  • Internal R&D
  • Defend legal claims

Internet or other similar network activity

(e.g., browsing history, search history, information on a consumer’s interaction with a website)

  • Directly from you or your device
  • From our clients and business partners
  • Create, analyze, and provide data sets to our clients and business partners
  • Debugging and security

Sensory data

(e.g., audio or electronic information)

  • Directly from you when you call us or leave a voicemail
  • Market our products and services
  • Provide technical support or respond to requests

Employment or other professional information

(e.g., current or past job history)

  • Publicly available databases
  • Consumer data vendors
  • Our clients and business partners

  • Create, analyze, and provide data sets to our clients and business partners
  • Market our products and services
  • Internal R&D
  • Defend legal claims

Inferences drawn from personal information

(e.g., profile reflecting a person’s preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes)

  • Consumer data vendors
  • Our clients and business partners

  • Create, analyze, and provide data sets to our clients and business partners
  • Market our products and services
  • Internal R&D
  • Defend legal claims

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)

  • Service providers
  • Our clients and business partners
  • Social networks and online platforms
  • Data analytics providers

Yes

Protected Classifications

(e.g., age (40 years or older), race, sex, military status, etc.)

  • Service providers
  • Our clients and business partners
  • Social networks and online platforms
  • Data analytics providers

Yes

Commercial Information

(e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing histories or tendencies)

  • Service providers
  • Our clients and business partners
  • Social networks and online platforms
  • Data analytics providers

Yes

Internet or other similar network activity

(e.g., browsing history, search history, information on a consumer’s interaction with a website)

  • Service providers
  • Our clients and business partners
  • Data analytics providers
  • Social networks and online platforms

Yes

Sensory data

(e.g., audio, electronic, visual, thermal, olfactory, or similar information)

  • None

No

Employment or other professional information

(e.g., current or past job history)

  • Service providers
  • Our clients and business partners
  • Social networks and online platforms
  • Data analytics providers

Yes

Inferences drawn from personal information

(e.g., profile reflecting a person’s preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes)

  • Service providers
  • Our clients and business partners
  • Social networks and online platforms
  • Data analytics providers

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 share your Personal Information outside Data Trust?”)’.

Your Rights Under the CCPA

You have rights under the CCPA. Instructions on how to exercise these rights are listed immediately below in the “How to Exercise Your CCPA Rights” subsection. 

  • Right to Know: When you exercise your “right to know,” we will provide you with:
    • Individualized Information about Collection, Sales, 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 used, disclosed, or sold, and the categories of third parties with whom we share the Personal Information. Our response to your request “to know” will only cover the twelve (12) month period preceding the request.    
    • 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.  
  • Right to Opt-out of Sales:  You have the right to opt-out of the sale of your Personal Information.  
  • Right to Non-Discrimination: We do not discriminate against you for exercising any of your privacy rights under CCPA 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 CCPA Rights 

To exercise the rights described above, please submit a request to us by:

  • Following this link to our online request form if you would like to exercise your Right to Know or Right to Delete.
  • Following this link to our opt-out form if you would like to exercise your Right to Opt-out of Sales.
  • Submitting a request to exercise any of your CCPA rights to us at info@thedatatrust.com or by calling us at 202-733-5235. 

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, 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 CCPA 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 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 

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.

Shine the Light

If you reside in California, you have the right to ask us one time each year if we have shared Personal Information with third parties for their direct marketing purposes. To make a request, please send us an email or write to us at the address listed below in Section 12 (“Who can I contact at 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.

7. 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. To the extent permitted by law, we are be liable for disclosures of your Personal Information due to errors in transmission or unauthorized acts of third parties. 

8. 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.

9. 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.   

10. 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.

11. 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. 

12. 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

1101 14th Street NW
#650
Washington, DC 20005

Or 

info@thedatatrust.com