Last Modified: 1/30/2020

NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] – CALIFORNIA CONSUMER PRIVACY PROTECTION ACT

The California Consumer Privacy Act of 2018 (“CCPA”) 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 Policy. 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):

  1. Our Collection of Personal Information – the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from, and what our business purposes are for collecting and using it.
  2. Our Disclosure and Sale of Personal Information – the types of recipients to whom we disclose or sell Personal Information.
  3. 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.

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

1. OUR COLLECTION OF PERSONAL INFORMATION

Depending on how you interact with us, [Business] 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.

Category Sources Business / Commercial Purposes for Collection
Identifiers, e.g., name; postal address; email address; Voter
Identification number; or similar identifiers.
  • From The secretary of state or local Board of election, DMV,
    data compilers and consumer data resellers, public records and
    government entities,
  • In addition, data analytics providers, operating systems and
    platforms and social networks.

We collect personal and online identifiers for our business purposes, including: Voter outreach, political speech, internal research, identity verification, internal operations, auditing, debugging, short-term and transient use, fulfilling and improving our services which are described as political and identity verification systems and legal compliance.

We collect personal and online identifiers for additional commercial and product purposes, including: sharing such information with our clients who typically use the information for their political campaign, PAC and association activities as well as marketing, advertising, authentication, identity resolution, fraud prevention, and/or fulfillment purposes.

Categories of personal information described in Cal. Civ. Code § 1798.80(e).
E.g., physical characteristics or description; telephone number;. Information included in this category may be duplicative of information identified in other categories in this Appendix B
  • From The secretary of state or local Board of election, DMV, data compilers and consumer data resellers, public records and government entities,
  • In addition, data analytics providers, operating systems and platforms and social networks.

The personal data is used for our business purposes, including: Voter outreach, political speech, internal research, identity verification, internal operations, auditing, debugging, short-term and transient use, fulfilling and improving our services which are described as political and identity verification systems and legal compliance.

We supply personal and online identifiers for additional commercial and product purposes, including: sharing such information with our clients who typically use the information for their political campaign, PAC and association activities as well as marketing, advertising, authentication, identity resolution, fraud prevention, and/or fulfillment purposes.

Characteristics of protected classifications under California or US law

E.g., race; color; religion; sex/ gender, gender identity; marital status; military or veteran status; national origin; and ancestry; age.
  • From The secretary of state or local Board of election, DMV, data compilers and consumer data resellers, public records and government entities,
  • In addition, data analytics providers, operating systems and platforms and social networks.

The data is used for our business purposes, including: Voter outreach, political speech, internal research, identity verification, internal operations, auditing, debugging, short-term and transient use, fulfilling and improving our services which are described as political and identity verification systems and legal compliance.

We supply such data for additional commercial and product purposes, including: sharing such information with our clients who typically use the information for their political campaign, PAC and association activities as well as marketing, advertising, authentication, identity resolution, fraud prevention, and/or fulfillment purposes.

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
  • From The secretary of state or local Board of election, DMV, data compilers and consumer data resellers, public records and government entities,
  • In addition, data analytics providers, operating systems and platforms and social networks.

The data is used for our business purposes, including: Voter outreach, political speech, internal research, identity verification, internal operations, auditing, debugging, short-term and transient use, fulfilling and improving our services which are described as political and identity verification systems and legal compliance.

We supply such data for additional commercial and product purposes, including: sharing such information with our clients who typically use the information for their political campaign, PAC and association activities as well as marketing, advertising, authentication, identity resolution, fraud prevention, and/or fulfillment purposes.

Professional or employment-related information
E.g., current or past employment, occupation.
  • From The secretary of state or local Board of election, DMV, data compilers and consumer data resellers, public records and government entities,
  • In addition, data analytics providers, operating systems and platforms and social networks.

The data is used for our business purposes, including: Voter outreach, political speech, internal research, identity verification, internal operations, auditing, debugging, short-term and transient use, fulfilling and improving our services which are described as political and identity verification systems and legal compliance.

We supply such data for additional commercial and product purposes, including: sharing such information with our clients who typically use the information for their political campaign, PAC and association activities as well as marketing, advertising, authentication, identity resolution, fraud prevention, and/or fulfillment purposes.

Generally speaking, we use the Personal Information that we collect for three purposes:

  • To create, improve and provide to clients a range of data services and products, that assist them in political and free speech activities as well as marketing or advertising to their own and prospective clients and supporters including to likely and potential voters and campaign donors.
  • To communicate with our customers about our products and services.
  • Additional uses as descried in section 1 of this policy.


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 customers. The chart below 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 Businesses We Share With Whether We Sold This Category of Personal Information in the Last 12 Months
Identifiers, e.g., name; postal address; email address; Voter Identification number; or similar identifiers Political organizations, candidates, organizations which undertake political activities , Government agencies, Advertising firms, analytics service providers, cloud storage providers, marketing service providers or payment processors Yes
Categories of personal information described in Cal. Civ. Code § 1798.80(e).
E.g., physical characteristics or description; telephone number;. Information included in this category may be duplicative of information identified in other categories in this Appendix B
Political organizations, candidates, organizations which undertake political activities , Government agencies, Advertising firms, analytics service providers, cloud storage providers, marketing service providers or payment processors Yes
Characteristics of protected classifications under California or US law.
E.g., race; color; religion; sex/ gender, gender identity; marital status; military or veteran status; national origin; and ancestry; age
Political organizations, candidates, organizations which undertake political activities, Government agencies, Advertising firms, analytics service providers, cloud storage providers, marketing service providers or payment processors 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
Political organizations, candidates, organizations which undertake political activities , Government agencies, Advertising firms, analytics service providers, cloud storage providers, marketing service providers or payment processors Yes
Professional or employment-related information.
E.g., current or past employment, occupation.
Political organizations, candidates, organizations which undertake political activities , Government agencies, Advertising firms, analytics service providers, cloud storage providers, marketing service providers or payment processors 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 customers, 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:

We collect personal and online identifiers for our business purposes, including: Voter outreach, political speech, internal research, identity verification, internal operations, auditing, debugging, short-term and transient use, fulfilling and improving our services which are described as political and identity verification systems and legal compliance.

We collect personal and online identifiers for additional commercial and product purposes, including: sharing such information with our clients who typically use the information for their political campaign, PAC and association activities as well as marketing, advertising, authentication, identity resolution, fraud prevention, and/or fulfillment 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.)

  1. Right to request access to 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. 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.

  2. 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 customer 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.) 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 de-bugging 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.

  3. How to exercise your access and deletion rights

    California residents may exercise their California privacy rights by sending an email to privacy@aristotle.com, submitting your deletion request to the online web form or request categories & personal data by submitting the online form, or by contacting us at 888-217-9600.

    For security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you — when you request to exercise your California privacy 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 multiple identifiers (such as name, email address, voter ID) 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.
    • Where you have requested that we delete personal information that we have collected from you, we will 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. If we are unable to locate a matching record, we will notify you of this fact. In addition, certain information may be exempt from such requests under applicable law.

    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 so long as such information does not compromise the identity of individuals in our databases.

  4. 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.

  5. Right to Opt-out of the sale of your personal information.

    California residents 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 II of this Addendum.

    If you would like to opt out, you may do so as outlined on the following page: Do Not Sell My Personal Information

  6. 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).

  7. Authorized Agents

    You may also designate an agent to make requests to exercise your rights under CCPA as described above. 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 (for example providing us with a notarized written authorization or power of attorney).