ADDENDUM FOR CALIFORNIA RESIDENTS CALIFORNIA PRIVACY RIGHTS

CPRA PRIVACY NOTICE TO CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018 (“CCPA”) and related regulations provides certain rights to residents of California. This section of the Privacy Policy applies if you are a natural person who is a resident of California (“California Consumer”) and uses our Services. This Addendum supplements the information in the Privacy Notice. However, this Addendum is intended solely for, and is applicable only as to, California Consumers: if you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it.

In the below tables and sections, we describe (as required by the CCPA):

Our Collection of Personal Information – the types of Personal Information (which the CCPA defines broadly) that we collect, and the types of sources we collect it from.
Our Disclosure and Sale of Personal Information – the types of recipients to whom we share or sell Personal Information.
Our Business Purposes – our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.
Your California Privacy Rights and Choices – what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.
Retention of Personal Information – how long we retain information.
Consumer Request Statistics – consumer request statistics pursuant to the California Delete Act.

1. OUR COLLECTION OF PERSONAL INFORMATION

The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information.

Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information. Our descriptions of “Identifiers” follow statutory, categorical examples: we do not necessarily collect all example types of all identifiers shown.

Category	Categories of Sources
Identifiers E.g., name; alias; postal address; online identifiers; IP address; telephone number; email address, mobile ad identifiers.	Data compilers and consumer data resellers, informational and retail websites, public records, government entities and other publicly available sources (such as the US Census Bureau).
Characteristics of protected classifications under California or U.S. law E.g., race; color; religion; sex/gender, marital status; military or veteran status; national origin; ancestry.	Data compilers and consumer data resellers; informational and retail websites.
Commercial or transactions information E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Data compilers and consumer data resellers; informational and retail websites.
Internet or other electronic network activity information E.g., information on a consumer’s interaction with a website.	Data compilers and consumer data resellers; informational and retail websites.
Geolocation data	US Postal Service.
Professional or employment-related information E.g., job titles or categories.	Data compilers and consumer data resellers, informational and retail websites.

2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION

We will share the Information collected from and about you as discussed above for various business purposes, with service providers and with third parties including our Clients. The chart below explains how and with whom we share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.

Category	Categories of Third Parties We Share With	Whether We “Sold” This Category of Personal Information in the Last 12 Months and to Whom	Whether We “Shared” This Category of Personal Information in the Last 12 Months and to Whom
Identifiers E.g., name; alias; postal address; online identifiers; IP address; telephone number; email address, mobile ad identifiers.	Data compilers and consumer data resellers, consumer goods retailers, informational and retail websites, public records and other publicly available sources, content publishers, non-profit organizations, business-to-business companies, advertising networks, internet service providers, data analytics providers, operating systems and platforms, and social networks (referred to below together as “Client Categories”).	Yes	Yes
Characteristics of protected classifications under California or U.S. law including Sensitive Personal Information E.g., race; color; religion; sex/gender, marital status; military or veteran status; national origin; ancestry.	Client Categories	Yes	Yes
Commercial or transactions information E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Client Categories	Yes	Yes
Internet or other electronic network activity information E.g., information on a consumer’s interaction with a website.	Client Categories	Yes	Yes
Geolocation data	Client Categories	Yes	Yes
Inferenced data E.g. inferences about consumer engagement.	Client Categories	Yes	Yes

We also may share any of the personal information we collect as follows:

Sharing for Legal Purposes: In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our Clients, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.

Sharing In Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.

Sharing With Service Providers: We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.

Sharing of Aggregate Information: We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION

Generally speaking, we collect and share the Personal Information that we collect for the following purposes:

Our purposes for collecting, using and sharing Personal Information

Data marketing services, for example:

Generally, creating data marketing tools and products for our marketer clients, as more fully described in our Privacy Policy (and on our websites). This includes our provision of datasets, data “appends” (connecting data across datasets), data “scoring” (providing inferences about potential consumer behavior), data hygiene services (helping Clients to evaluate, validate and correct personal information they hold), and security and anti-fraud services (helping Clients to identify potentially fraudulent activity).
Helping our Clients identify and understand their consumers better, by providing insights about them and managing loyalty programs, as well as providing financial and other scoring products.
Assisting our Clients with use our Services to provide their consumers and prospects with better service, improved offerings, and special promotions, for instance, advising on which consumers or prospective consumers are most likely to be interested (or disinterested) in certain offers.

Online targeting, for example:

Creating or helping to create defined audience segments based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., households with prospective students). When we do this, we work with a data partner that “matches” our or other Information through de-identification techniques (such as through coded data “hashing”) with online cookies and other identifiers, in order to target and measure ad campaigns online across various display, mobile and other media channels.
Assisting Clients in creating “identity” graphs, to help locate users across various channels, such as based on common personal, device-based, or network-based identifiers (e.g., IP address, email address).

Additional marketing services, for example (which may overlap with “data marketing services” above):

Assisting in targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing.
Measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases.
Analyzing and optimizing our Clients’ (or their service providers’) proprietary databases, or helping Clients to identify and mitigate potential fraud.
Providing “verification” or data “hygiene” services, which is how companies update and/or “clean” their databases by either verifying or removing or correcting old, incorrect or outdated information.

Operating our Services, for example:

Improving, testing, updating and verifying our own database.
Developing new products.
Operating, analyzing, improving, and securing our Services.

Other internal purposes, for example: For internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance. We sometimes use the Information collected from our own website, from social networks, from other “business to business” interactions (such as at trade shows), or from data compilers for the above, as well as for our own marketing purposes.

4. YOUR CALIFORNIA RIGHTS AND CHOICES

Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)

a. Right to Opt-out of the Sale of Your Personal Information

California residents (and residents of any state) may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale,” including in the definition making available a wide variety of information in exchange for “valuable consideration.”

Depending what information we have about you, and whether we have included any of it in our marketing products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in the above table in Section 2 of this Addendum.

If you would like to opt out, you may do so by contacting us at 800-533-5853 or as outlined on the following page: Do Not Sell My Personal Information.

b. Right to Correct Your Personal Information

California residents have the right to request that we correct inaccuracies about your personal information that we collect, use, or sell. As set forth below, you may also request the correction of specific pieces of personal information that we have collected from you. However, we may withhold the correction of some personal information where the risk to you or our business is too great to correct the Information.

If you would like to request correction of your personal information, you may do so by contacting us at 800-533-5853 or as outlined at https://webbula.com/ca-eu-data-request/.

c. Right to Request Deletion of Your Personal Information

You may also request that we delete any personal information that we collected from you, such as if you have been a Client of ours. (Note that this is different from your right to “opt out” of us selling your personal information, which is described below; also note that we do not generally collect personal information directly from consumers.)

Where you request that we delete personal information that we have collected from you, we may seek to confirm whether your request is for an “opt out” or a “deletion” because “opt out” or “do not sell” rights enable us to maintain your information for “suppression” purposes, i.e., to prevent us from selling information about you in the future, which is what many consumers requesting “deletion” actually desire to occur. We try to explain this in order to ensure we are meeting consumers’ preferences. In addition, “deletion” rights only apply to information that we have collected “from” consumers, which does not apply to much of the Information in our databases.

Upon completion of the above process, we will send you a notice that explains the categories of personal information we were able to locate about you, whether we (1) deleted, (2) deidentified, or (3) retained the Information we collected from you. Certain information may be exempt from such requests under applicable law.

However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as debugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. Additionally, we need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.

If you would like to request deletion of your personal information, you may do so by contacting us at 800-533-5853 or, if you are seeking deletion from our “Services,” as outlined on the following page: Opt Out.

d. Right to Access Your Personal Information

California residents have the right to request that we disclose what categories of your personal information that we collect, use, or sell. As set forth below, you may also request the specific pieces of personal information that we have collected from you. However, we may withhold some personal information where the risk to you or our business is too great to disclose the Information, or as otherwise reasonable and appropriate under law.

If you would like to request access to your personal information, you may do so by contacting us at 888-993-2285 ext 4 or as outlined on the following page.

For security purposes (and in accordance with applicable laws), we will verify your identity, in part by requesting certain information from you, when you seek to exercise these “access” rights. For instance, if you request categories or specific pieces of personal information we have received about you, you may need to confirm your possession of an identifier (such as an email address) or to provide a piece of identification that confirms you are the person you claim to be.

Once we have verified your identity, we will respond to your request as appropriate:

Where you have requested the categories of personal information that we have collected about you, we will provide a list of those categories.
Where you have requested specific pieces of personal information, we will provide the information you have requested, to the extent required under the CCPA and provided we do not believe there is an overriding privacy or security concern to doing so.

If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.

e. Right to Nondiscrimination

We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.

f. Information About Persons Under 16 Years of Age

We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).

g. Authorized Agents

You may also designate an agent to make requests to exercise your rights under CCPA as described above. As appropriate, we will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or, if required by law, a copy of a power of attorney.

5. RETENTION OF PERSONAL INFORMATION

We will keep Information for as long as it is necessary to fulfill the purposes described above, unless a longer retention is required or permitted by law. For purposes of our Services, we retain Information so long as it is potentially useful to effectuate features, functions, intelligence, inferences or analysis within our database, for instance, to establish whether an email address is current or no longer in use, or whether other information is outdated or incorrect. We will delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable law.

6. CONSUMER REQUEST STATISTICS PURSUANT TO CALIFORNIA DELETE ACT

From January 1, 2025 to December 31, 2025, we maintained processes to facilitate requests pursuant to the California Consumer Privacy Act. We received the following requests, and responded as follows:

Request Type	Total Requests Received	Complied in Whole	Denied	Mean (Days)	Median (Days)
Requests to Delete	203.00	203.00	0.00	1.00	1.00
Requests to know what personal information is being collected	10.00	3.00	7.00	7.00	5.00
Requests to know what personal is sold or shared	10.00	3.00	7.00	7.00	5.00
Requests to opt out of sale or sharing	43,542.00	43,542.00	0.00	1.00	1.00
Requests to limit the use and disclosure of sensitive personal information	0.00	0.00	0.00	0.00	0.00

Any denials of Requests to Know were based on consumers abandoning their request by not verifying their identity as required by CCPA. Any unfulfilled Requests to Opt Out or Requests to Delete were based on consumers abandoning their request by not completing an opt out or delete form.

You may view these statistics on a dedicated page by clicking here

Last Modified: March 26, 2026

New Look. Same Data You Trust.

New Look. Same Data You Trust.

New Look. Same Data You Trust.

New Look. Same Data You Trust.