StatSocial, Inc (“we,” “our,” “StatSocial”) provides data licensing and marketing services (the “Services”) designed to assist our clients, who are generally advertisers and marketers and the providers that assist them (“Clients”) to better market to consumers. Our solutions, which are more fully described on this website (“Website” or “Websites”), are used for online and offline marketing purposes. When we say “you” we are referring to consumers, including the person reading this Privacy Policy.

We take consumer privacy seriously. This Privacy Policy (“Privacy Policy”) describes how we use and manage information used in and licensed through Services, and how consumers can control how information about them is used and shared.

We also describe in Section 6 the information we collect through our corporate website (the website this Privacy Policy is on), which is directed to Clients, prospective Clients and others.

When we handle information on behalf of Clients related to their own actual or prospective customers (such as to provide analysis of this information to customers), we act only as a service provider and do not combine their information with the information we collect and maintain for the purposes described below. We address these practices separately in Section 7 of this Privacy Policy.

1. Information That We Collect and From What Sources

In order to provide our Services, we obtain information about you through a variety of means and sources. Much of the information we collect is publicly available, which means it is not “personal information” under state consumer privacy laws. However, we may combine any of the information that we collect in order to perform our Services. We describe below the categories of information that we collect in terms required under the California Consumer Privacy Act, in order to avoid potentially confusing duplication of terms.

The categories of our sources include data compilers and resellers, publicly sourced as well as publicly available information (such as the US Census Bureau and US Postal Service), website and mobile application operators.

Categories of Information we collect, maintain, and/or receive:

a. Personal and online identifiers. E.g., Email addresses (generally in “hashed” or obfuscated form), telephone numbers, name, postal address, social media identifiers or handles.
b. Characteristics of protected classifications under California or federal law. E.g., sex/gender, race, ethnicity, age or religion (which may be inferred). This is “sensitive personal information” under state consumer privacy laws.
c. Professional, alumni or employment-related information. E.g., job title, employer information, schools graduated from.
d. Inferenced Data. E.g. Inferences drawn for the sources above about a consumer’s lifestyle, demographic or other “Interest”-based traits, that we license from other data compilers (in addition to inferences we create and/or describe above).

2. Our Business Purposes for Collecting and Using Personal Information
The following chart provides additional information about our purposes for collecting and using your information – in effect, key aspects of our Services:

Purposes of Use

Data marketing services, for example:● Providing marketing information to our Clients (which include companies, non-profit and other organizations), generally regarding their marketing, fundraising, customer service and engagement, and outreach activities. ● Helping our Clients identify and understand their customers better, by providing insights about them and managing loyalty programs. ● Assisting our Clients with using our Services to provide their customers and prospective customers with better service, improved offerings, and special promotions, for instance, advising on which consumers are most likely to be interested (or disinterested) in certain offers.

Online targeting, for example:● Creating 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 may work with a data partner that “matches” our 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. You may learn more about how to opt out of this and other online ad targeting in Section 5.

Additional marketing and database services, for example:● Assisting in targeting and optimization 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. ● Associating or “graphing” the consumers (and prospective consumers) of our Clients across various websites or platforms, including based on their social media identifiers, e.g., to help Clients analyze or advertise to their Clients based on and across their social media presence.

Operate 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 use the information collected from our own website, from social networks, from other “business to business” interaction (such as at trade shows) or from data compilers for the above, as well as for our own marketing and other internal business purposes.

3. How We Disclose Information to Third Parties
In the course of providing our services as described in Section 2, we typically disclose all categories of personal information collected to third parties in the form of licensing agreements, including to our Clients and their own service providers.

We also may disclose any of the personal information we collect and maintain as follows:

Disclosure for Legal Purposes: We also may disclose personal information to third parties in order to: (a) comply with legal process (civil or criminal) or a government investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or our contracts (or our rights under the law); (c) and/or to protect the rights, property or personal safety of us, our platform, our clients or any other person. We likewise may provide information to other companies and service providers for fraud protection, security and similar purposes.

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

Disclosure With Service Providers: We disclose any personal information we collect to 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.

Aggregate and Deidentified Information. We may aggregate and/or de-identify any information collected so that such information can no longer be reasonably linked to you, your household, or your device. We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

4. Cookies and Similar Technologies

a. Cookies and How We Use Them

Our website ( https://www.statsocial.com/) uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our Website. We use these technologies on our Website, for instance, and our partners may use these technologies in their own marketing services.

We may work with third parties to provide or enhance our Services (e.g. for purposes of tailoring ads, or placing browser cookies), or to offer marketers ways to access or use our Information, often in de-identified form. These partners may set and access their own cookies, pixel tags and similar technologies on your device, which may have cookies with varying expiration periods. Those partners may, likewise, collect various types of information about your browser, device, or browsing activities through use of these cookies.

Cookies, in turn, are small data files that contain a string of characters, such as a unique browser identifier. Cookies are stored on your computer or other device and act as tags that identify your device. Our (or other companies’) servers send your device a cookie when you visit a website. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access web pages (such as the website of a marketer), pixel tags may permit our partners (or sometimes, us) to read the cookies that a respective company or server has deployed. Pixel tags are used in combination with cookies to track the activity on a site by a particular device.

Through such technologies, we gather information about you, such as your browser type, operating system, IP address, mobile device identification number, the sites visited before and after our Site, and about your interactions with our services, such as the time and date when you viewed a page, which advertisements you have clicked on, and whether you filled out an online form.

We use the following cookies:

• “Essential” (Strictly necessary) cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting or Advertisement cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose or allow the third party to collect this information as disclosed below.

Not all our cookies collect personal identifiable information: We use information gathered through cookies to improve the way our Sites work, for example by employing third-party analytics tools which aggregate anonymous user information to help us better design our sites and enhance the functionality of our services for example, by remembering preferences or other choices that you make – such as user names, language preferences, and the like – we can better understand how you use our site(s) over time. In short, these tools allow us to provide you with a better, more relevant online experience. We may also work with third-party advertising companies to suggest advertisements from the services or on third-party sites based on your preferences.

You can find more information about the individual cookies we use and are not “strictly necessary” for the operation of the website, and process personally identifiable information and the purposes for which we use them in the table below. Please note that the mentioned third parties use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies or performance cookies or targeting/ advertisement cookies:

b. Disabling Cookies

You can manage or disable cookies at any time by adjusting your browser settings or by using our cookie management tool.

You may set your browser to block all cookies, including StatSocial’s cookies that are not strictly necessary while using our services, but doing so will prevent some aspects of our services to not function properly). You may also set your browser to block third-party cookies and allow first-party cookies, which would allow us (but not third parties) to collect such information while you are on our sites. In addition, some browsers may allow you to block certain web beacons and similar tracking codes. Please refer to your browser’s documentation if you wish to block some or all cookies, web beacons, and/or similar tools. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. While browsers vary, the following links may be helpful:a)

(a) Cookie settings in Internet Explorer
(b) Cookie settings in Firefox
(c) Cookie settings in Chrome
(d) Cookie settings in Safari on Mac and Safari on iPhone, iPad, or iPod touch.

Google Analytics. Google Analytics is a service provided by Google, Inc. (“Google”). We use Google Analytics to collect anonymized statistics in order to improve the Site. You can learn about Google’s practices by going to Google Analytics and privacy, and opt out of them by downloading the Google Analytics Opt-out Browser Add-on. We have taken the following measures to protect the data collected through Google Analytics:

• We have concluded a data processing agreement with Google about how Google may process the data collected through Google Analytics;
• We have configured Google Analytics settings to mask the last octet of user IP addresses;
• We have configured Google Analytics to not share data with third parties; and
We do not use other Google services in conjunction with Google Analytics.

5. Your Marketing and “Opt Out” Choices
There are several ways that you may exercise choices about how information about you is used to market to you. Residents of California, Colorado, Connecticut, and Virginia should review Section 11 below for additional information on their privacy rights.

a. Opting Out of our marketing databases. To “opt out” of our marketing databases, please go to our “Do Not Sell or Share My Personal Information” page here. If you “opt out” in this way, we will maintain certain of your information in our internal “suppression” files.

b. Opting Out of personalized advertising. In addition, any consumers who wish to “opt out” of personalized (sometimes called “interest-based”) online marketing may go to the industry opt-out and educational pages operated by the NAI and DAA, two industry self-regulatory groups, here and here.

c. Direct Mail Opt Outs. If you would like to opt-out of direct mail advertising in general, we recommend that you visit the DMA Choice website, at dmachoice.thedma.org. The DMAChoice service is run by the Direct Marketing Association (part of the Association of National Advertisers) and allows you to follow a few easy steps to ensure that your marketing preferences are honored.

d. Unsubscribing from our corporate email. In addition, we will generally provide an “unsubscribe” link in any marketing emails we send. You may opt out of receiving those “b2b” marketing emails by clicking on that link.

6. Data Collected Through Our Website
We will sometimes give you the opportunity to provide information directly to us through our corporate Website – such as if you are a business interested in a relationship with us or an individual completing one of our surveys. Additionally, as you interact with our Website, we may use (or engage with business partners and vendors that use) automatic data collection technologies such as cookies (described above) to collect certain information about your equipment, browsing actions, and patterns. Our data collection practices concerning our Website are included in the following chart:

Categories of information collected	Purposes of collection and use	Sources of Personal Information
Contact information and identifying information, e.g., email address, name, gender, address, telephone number, job title	Operate our Websites and Services ● Send you marketing communications ● Building and managing business-to-business relationships ● Communicate with you	● You, the consumer/user of our Websites, including chatting online with or otherwise contacting customer service ● Clients and potential clients ● Trade associations ● Conferences ● Business data resellers
Device information and identifiers, e.g., online cookies identifiers, IP addresses, email address, name/address, job title	● Operate our Websites and Services ● Personalize your experience ● Secure our Services ● Fraud prevention and legal purposes	● You, the consumer/user of our Websites, including chatting online with or otherwise contacting customer service ● Analytics providers ● Cookies and tracking technologies ● Our Websites’ interaction with your devices ● Data resellers
Internet or other electronic network activity informationE.g., browsing history; search history; and information on a consumer’s interaction with a website or advertisement (generally our own).	● Operate our Websites and Services ● Personalize your experience ● Secure our Services ● Fraud prevention and legal purposes	● You, the consumer/user of our Websites, including chatting online with or otherwise contacting customer service ● Analytics providers ● Cookies and tracking technologies ● Our Websites’ interaction with your browser, including chatting online with or otherwise contacting customer service
Other information consumers choose to directly to provide to us, including for billing purposes	● Operate the Websites and Services ● Send marketing communications ● Building and managing business-to-business relationships ● Billing and accounting purposes ● Communicate with you ● Secure our Services ● Fraud prevention and legal purposes	● You, the consumer/user of our Websites, including chatting online with or otherwise contacting customer service ● Clients and potential clients As with the information we use within our products and services, we also may share any of the personal information we collect on or through our Website(s) as follows:

7. Information We Receive From Clients as a Service Provider/Processor to Them

StatSocial, as a service provider or processor, provides its Clients with services, such as customer insights and analytics (generally, providing our customers information about their own consumers or prospective consumers). When our Clients provide us with information relating to their own customers or prospective customers, we function as a service provider to those Clients. We do not combine our Clients’ data with our own data when we act as a Service Provider.

Our Clients determine how to engage with their customers and thus act as the business that determines the purposes and means of handling their own customer and transactional information. Under these circumstances, consumers are ultimately subject to the privacy policies of the Clients controlling their data. We are not responsible for the privacy practices of our Clients.

8. Links
This website may provide links to other websites that StatSocial thinks users will find interesting or useful. StatSocial is not responsible for the privacy practices of these other sites or companies.

9. Security and Data Integrity
StatSocial takes steps to help ensure that the data we possess is housed and transmitted securely. This may include physical and electronic security precautions, firewall protections, encryption, hashing or truncation of data, and access controls to personal information. Although neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we employ efforts that are designed to minimize the risk of this occurring.

10. Changes to this Privacy Policy
From time to time, we may update this Privacy Policy. Any changes to it will become effective when it is posted to our website (or at a later date we designate). Please continue to check back to learn of any changes to this Privacy Policy.

11. Your Rights and Marketing Choices (and Notice of Your Right to Opt Out)

If you are a resident of California, Colorado, Connecticut, or Virginia, the law in your state provides you with the following rights with respect to your Personal Information:

Your California, Colorado, Connecticut, and Virginia Privacy Rights

• The right to know what Personal Information we have collected, used, disclosed, and sold about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom StatSocial discloses Personal Information, and the specific pieces of Personal Information StatSocial has collected about you, which you can exercise on our website.
• The right to obtain a copy of Personal Information we have obtained about you in a portable and, to the extent technically feasible, readily usable format.
• The right to correct inaccurate personal information about you, taking into account the nature of the Personal Information and the purposes of the processing.
• The right to request that we delete any Personal Information we have about you.
• The right to opt-out of the selling your Personal Information, which you can exercise on our website here.
• The right to limit the use of your Sensitive Personal Information, which you can exercise through the contact form available on our website.
• If we deny your request, the right to appeal our decision.

Pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”), you have privacy rights with respect to your Personal Information. And California law requires us to identify, for the 12-month period prior to the date of this Privacy Policy, what information we may have “sold” or “shared” about you. For the 12-month period prior to the date of this Privacy Policy, StatSocial has only sold Personal Information as described above. For the 12-month period prior to the date of this Privacy Policy, StatSocial has not shared any Personal Information. StatSocial has only used or disclosed Sensitive Personal Information, as defined in applicable laws, as described above, and you can limit our use and disclosure of such information by exercising your privacy rights as explained below.

This Privacy Policy describes how we may share your information for marketing purposes, as described above. If you are a California resident, the Shine the Light law permits you to request and obtain from us once per calendar year information about any of your Personal Information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information and for any other questions about our privacy practices and compliance with California law, please contact us through the contact form on our website.

California Business Contact Information

If you are a California resident and we receive your Personal Information in the form of contact details from business events, for example as part of a business appointment (e.g., by exchanging business cards) or as part of any other form of collaboration, we may use your contact and business details to maintain our business contacts. For this purpose, we may transfer your contact details to our internal database. Pursuant to the CCPA, you have the same privacy rights described above with respect to your business contact Personal Information.

We do not sell or share any of our business contacts’ Personal Information, as defined by the CCPA. California law requires us to identify, for the 12-month period prior to the date of this Privacy Policy, what information we may have “sold” or “shared” about you. For the 12-month period prior to the date of this Privacy Policy, we have not sold or shared any personal information about our business contacts.

Submitting Requests

If you are a resident of California, Colorado, Connecticut or Virginia, you may submit any of the above requests by call us at [TOLL FREE PHONE NUMBER] or use the contact form available on our website. We will respond to your request in compliance with the requirements of your state’s applicable laws. Please note that we are only required to honor California requests to know twice in a 12-month period.

Verification of Your Identity

When you exercise your rights correct, delete, and/or to know/obtain Personal Information we have about you and submit a request to us, we will verify your identity by asking you to provide us with additional information such as your email address, a partial driver’s license number, or other information that would help us ensure the right person is making the request. We also may use a third-party verification provider to verify your identity.

Appeal

Residents of Colorado, Connecticut, and Virginia may appeal a decision we have made regarding their requests by using the form available on our website. We will respond to appeals from Virginia and Connecticut residents within 60 days. We will respond to appeals from Colorado residents within 45 days.

Non–Discrimination

If you make a request under your state privacy laws, we will not discriminate against you in any way.

Authorized Agents

You may permit an authorized agent to submit a request to know or to delete your Personal Information. If we receive a request on your behalf, we will ask that person to give us proof that you gave that person written permission to make a request for you. If that person does not provide us with written proof, we will deny their request so that we can protect your Personal Information.

Automated Decision-Making

We generally do not use automated decision-making technology, as that term is defined by State Privacy Laws. If we make use of automated decision-making technology, you will be informed through a separate privacy notice.

12. Record Retention
We may retain your personal information for as long as necessary to fulfill the purpose for which it was collected or to comply with legal or regulatory requirements. We strive to retain your personal information no longer than is reasonably necessary to carry out the purposes listed in this Notice or as required by law. The criteria used to determine our retention periods include: (a) the length of time we have an ongoing relationship with our Customers and provide services, (b) whether there is a legal obligation to which we are subject, and (c) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

13. Storage of Information in the United States
If you are accessing our Website from a location outside of the United States, your connection will be through and to servers located in the United States and the Information you provide will likely be processed and securely maintained in our web servers and internal systems located within the United States. (We likewise generally store the Information used in our Services in the United States.) Thus, you should be aware that in accessing this website or otherwise communicating with us, the information we collect or receive from you may be subject to laws with lesser or different privacy standards than those in your own country (such as if you are in a country located in the European Union).

14. Personal Information of Minors
You must be at least 16 years old (depending on the state of residence) in order to provide us with personal information, and at least 18 years old to request any of the Services. We do not have actual knowledge about selling or sharing personal information of consumers under the age of 16. If you become aware of any selling or sharing information from children under 16, please email us at privacy@StatSocial.com.

Under Age 13
StatSocial complies with the Children’s Online Privacy Protection Act of 1998, which prohibits collecting personal information from children under the age of 13 without verifiable parental consent. If it comes to our attention that we have unknowingly collected information from a child under the age of 13, we will take all reasonable measures to delete it as soon as possible and will not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personally identifiable information we have collected from children under 13, please email us at privacy@StatSocial.com.

Under Age 18
Minors under 18 years of age may have the personal information that they provide to us deleted by sending an email to privacy@StatSocial.com requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.

15. Your Rights Under the GDPR and the Swiss/ UK Data Protection Acts

NOTE: Our Services are hosted and operated in the United States. If you are visiting the Application from outside the United States, your information may be transferred to, stored and processed in the United States in accordance with this Privacy Policy. The data privacy and other applicable laws of the United States may not be as comprehensive as those laws or regulations in your country or may differ from the data protection or consumer protection laws in your country. In some cases, your information may be available to government authorities under lawful orders and law applicable in such jurisdictions. We are not at this time offering our Services to data subjects in Europe. However, we may receive European personal data for data subjects in Europe through our agreements with our European partners.

The General Data Privacy Regulation (the “GDPR”) as well as the Swiss and UK Data Protection Acts provide data subjects in the EEA, Switzerland and the United Kingdom with certain rights, regarding how their “personal data” (as defined by these laws) is processed.All data subjects in the EEA, Switzerland and the United Kingdom should note that the GDPR and Swiss/U.K. data protection laws make a distinction between organizations that process personal data for their own purposes (“data controllers”) and organizations that process personal data on behalf of other organizations (“data processors”). In these jurisdictions, StatSocial currently only acts as a data processor with respect to your personal data on behalf of our clients and partners. If you have a question or complaint about how your personal data is processed, or if you want to exert your data protection rights, you should always contact the relevant data controller(s) (our clients and partners) who are primarily responsible for your personal data. Please contact us if you need further information.

16. Consumer Request Statistics Pursuant to California Delete Act

The California Consumer Privacy Act (CCPA) mandates that certain businesses compile and disclose annual metrics related to their compliance with the CCPA and consumer rights requests. These metrics must be made publicly available by July 1 each year. From January 1, 2023 to December 31, 2023, we maintained processes to facilitate requests pursuant to the California Consumer Privacy Act. We received the following requests, and responded as follows:

1. As to requests to know
   • We received 5.
   • We complied in whole or in part with 5.
   • We denied 0.
   • Our median response time was 7 days. Our mean response time was 7 days.
2. As to requests to delete
   • We received 5,219.
   • We complied in whole or in part with 5,219.
   • We denied 0.
   • Our median response time was 7 days. Our mean response time was 7 days.
3. As to requests to opt out of sale
   • We received 5,219.
   • We complied in whole or in part with 5,219.
   • We denied 0.
   • Our median response time was 7 days. Our mean response time was 7 days.

17. Contact Us

StatSocial has a designated privacy contact. If you have questions related to this Privacy Policy, or regarding our products or services, please contact us:

privacy@StatSocial.com

or

31 Hudson Yards, 11th Floor, Office 54
New York, NY 10001

We appreciate your comments and questions regarding StatSocial’s privacy practices.