Civis Analytics, Inc. Privacy Policy

This Privacy Policy describes how Civis Analytics, Inc. (“Civis” or “we”) processes, collects, and uses personal information in connection with our products and services (“Civis Products and Services”), our normal course of business, including sales and marketing activities, and your use of our website, except as otherwise set forth herein.

Personal information broadly refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, either alone or when combined with other personal or identifying information.

Because this Privacy Policy describes our privacy practices for Civis Products and Services, our normal course of business, and your use of our website, some parts may not apply to you.

This Privacy Notice does not apply to (i) personal information about consumers (outside of account holders or employees/agents of Customers that use the Civis Products and Services) that our business customers upload, submit or otherwise make available to Civis in connection with their purchase and use of Civis Products and Services, including Civis Platform; (ii) information that is aggregated, anonymous or does not otherwise identify individuals; or (iii) personal information that we collect and process in connection with our recruitment and employment activities, which is covered under our Employee and Applicant Privacy Notice.

Customer Data Shared With Us

We provide Civis Products and Services to business customers (“Customers”). Our processing of data provided by Customers is governed by our agreement with the relevant Customer. Customers’ data is the property of our Customers and the rights we have in their data are the rights that they grant to us when we process their data. Personal information collected by our Customers is subject to the privacy policies of the Customers that collected and shared the personal information with us.

Information We Collect About Individuals

Information that we collect from or about you includes information you provide to us, information we collect automatically, and information we collect from third-party sources.

Information You Provide to Us.

When you interact with Civis, including when you request information about Civis Products and Services, communicate with our team, take part in our sales and marketing activities or events, purchase or use Civis Products and Services on behalf of your organization, including create your account or submit customer support requests or voluntarily participate in our surveys, we may collect the following information:

Contact information (or “identifiers”), such as your name, email address, mailing address or telephone number

Account information we use to identify you and/or to provide or maintain your Civis Products and Services, such as username and password

Demographic information (including “protected classification characteristics”), such as date of birth, age, ancestry, national origin, sex / gender, marital or familial status, political affiliations or activities, veteran or military status or disability

“Sensitive” personal information such as racial or ethnic origin, citizenship or immigration status, sexual orientation, religious or philosophical beliefs or medical condition

Educational and professional information, including your education and employment history, job title, and company name

Commercial information, including purchasing or consuming histories or tendencies

Interest information and your preferences regarding people, places, concepts, products, events, etc.

Any other information you provide to us

Information We Collect Automatically When You Use Civis Products and Services or Visit Our Website.

Through cookies, clear GIFs, pixels, embedded scripts, and other tracking technologies that we or our service providers use to track, manage, and compile statistics and analytics on user activity on Civis Products and Services, our website, linked websites, our social media accounts, and in marketing and sales emails we send, we may collect the following information:

Information about how you use Civis Products and Services, including information about your account (e.g., username, email address), information about your activities within Civis Products and Services, such as the pages, features or content you access or use, time spent on those pages, features or content, commands executed, and other statistical information about your use of Civis Products and Services

Information about how you access or use our website, including the date and time of your access or use, how long you visit our website, links you click on, and the pages, features or content you access or use

The type of web browser you are using (for example, Chrome, Safari, Firefox) and browser language

The type of device you are using (for example, whether you’re on a mobile phone) and its operating system

Your Internet Protocol (IP) address

Other geolocation, internet or other electronic network activity data

General location information, such as city or ZIP Code, that correlates with your use of Civis Products and Services or our website

Except with respect to California consumers who use the Global Privacy Control (GPC, learn more here: https://globalprivacycontrol.org/) in relation to cookies, we do not respond to “Do Not Track” signals or similar signals sent from browsers.

Information We Collect From Third Parties.

Civis obtains information from various third parties, including from:

Government entities that offer public records, including census data, real property records, voter records, court records, assessor information, tax rolls, and telephone and web directories

Consumer data providers that offer demographic, interest, purchase, voter files, and other consumer data and inferences

Social networks, such as Meta, and other publicly available data

Resellers, distributors, and other business partners

Advertising and marketing companies

Telecommunications providers

Security and fraud detection service providers

We may collect the following information from these third parties:

Contact information (or “identifiers”), such as your name, unique personal identifier, email address, mailing address or telephone number

“Sensitive” personal information, such as racial or ethnic origin, citizenship or immigration status, sexual orientation, religious or philosophical beliefs or medical condition

Interest information and your preferences regarding people, places, concepts, products, events, etc.

Educational and professional information, including your education and employment history, job title, and company name

Commercial information, including purchasing or consuming histories or tendencies

Geolocation information

Inferences, including predictions relating to you and/or your household, and predictions about your preferences, characteristics, behaviors, attitudes, intelligence, abilities, and aptitudes

Our Purposes for Collecting the Information

Civis Products and Services and website

To provide, maintain, deliver, operate, and support Civis Products and Services, including inference models and scores, and our website

To develop, enhance, update or improve Civis Products and Services and/or create new products, services or features

To understand how Customers and/or visitors access and use Civis Products and Services, our website, our marketing/sales emails, and/or our social media accounts

For market research, analytics, and development purposes

Account management and customer service

To create and maintain your Civis Platform account, including to authenticate your account credentials

To send you notifications about Civis Products and Services, including technical notices, updates, security alerts, administrative messages, and invoices

To provide customer support, including respond to your questions, comments, and requests, including to keep in contact with you regarding the Civis Products and Services you use

For billing, payment or account management

Marketing

For marketing, advertising, and promotional purposes, including to contact you about Civis Products and Services we think may interest you, as well with special offers, promotions, news, and newsletters

To follow up with you after you have communicated with us, including attended an event with us

To display, optimize, and provide personalized advertisements

To measure marketing and advertising effectiveness

Security, legal, and compliance

To implement and maintain security, anti-piracy, and fraud prevention initiatives

To investigate, detect, prevent, monitor or take action relating to actual or potential security issues, potential illegal activities or violations of our policies or agreements, including this Privacy Policy and our Terms and Conditions

To comply with applicable legal or regulatory obligations, including to respond to a subpoena or court order, to cooperate with law enforcement or other governmental investigations, and as part of legal proceedings

Where we believe it is necessary to protect you, us or others

Other

For other legitimate interests and/or lawful business purposes, including to conduct surveys and to provide reports to prospective partners, service providers, and others

For other purposes, where you have given consent

How We Disclose the Information

We may disclose your information described above with the following third parties:

Service providers who assist us in providing and maintaining Civis Products and Services, including through sales and marketing, customer support, data storage, analytics, and billing or operational services, subject to confidentiality and data security obligations

Services providers who assist us in securing and protecting Civis Products and Services and our network, including through detecting and preventing security incidents, fraud or other illegal or malicious behavior

Agents or service providers who aid or support Civis business activities or provide products or services requested by Customers

Business partners, including resellers, distributors, and/or referral partners, who may resell Civis Products and Services to Customers or prospects

Marketing and advertising partners, including those who facilitate, organize or sponsor Civis events

In connection with a merger, sale, financing or reorganization of all or part of our business or in the context of related business negotiations

When we believe in good faith that disclosure is necessary to protect or defend the rights, safety or property of Civis, Customers, you or others

When you instruct us to do so or you have consented to the disclosure of your information with third parties

As required by law, such as to comply with a subpoena or other legal process

Your Privacy Choices and Rights

Opt Out of Promotional Email Communications.

You may opt out of Civis promotional emails by clicking on the unsubscribe link in a Civis email. Please note that even if you opt out of receiving marketing communications from us, we may still send you communications about Civis Products and Services you have purchased from us, and we will still respond to your inquiries and requests for information.

As mentioned above, the Civis website uses cookies to personalize content and ads, provide social media features, and to analyze website usage. You can use the following button to change or revoke your consent to certain cookies.

Change your consent Revoke your consent

Opt Out of Interest-Based Advertising.

We may use third-party service providers such as Google Ads and LinkedIn Ads to help us provide advertisements to you that are tailored to you based on interests that you have expressed on our website or elsewhere (“Interest-Based Ads”). Any advertisements served by these third-party service providers and their affiliated companies may be controlled using cookies and related tracking technologies such as pixels. These cookies and pixels allow these providers to display ads based on your visits to websites. Any tracking done by these providers through cookies and other tracking technologies is subject to their own privacy policies. Some browser settings allow you to limit or remove the Interest-Based Ads delivered to you.

For example, we use Google Analytics to better understand how our users interact with Civis Products and Services and our website and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s website, “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here: https://tools.google.com/dlpage/gaoptout/.

To learn more about interest-based advertising in general and how you may be able to opt-out of some of this advertising through industry self-regulatory programs (to the extent the advertising partner or other entity participates in such industry opt-out pages), you may also wish to visit the Digital Advertising Alliance’s (DAA) resources at https://www.aboutads.info/choices (or https://www.youronlinechoices.eu/ or https://youradchoices.ca/en/tools for the EEA and Canada, respectively) or the Network Advertising Initiative’s (NAI) online resources at https://www.networkadvertising.org/choices/.

Depending upon your place of residence, you may have legal rights relating to your personal information.

Please review the state-specific Supplemental Privacy Notice. Depending on applicable law, those rights may include requesting access, correction, or deletion of your personal information, and opting out of “sales/shares” of your personal information, “targeted advertising,” and certain use/disclosure of your “sensitive” personal information.

Additional Information

Data Retention

We retain the personal information described in this Privacy Policy for different periods of time depending on the purpose(s) for which it was originally collected or as subsequently authorized, as necessary for other legitimate purposes described in this Privacy Policy, as required by law or as otherwise communicated to you.

Data Security

We are committed to protecting your personal information that is maintained and/or processed by Civis. We employ reasonable and appropriate organizational administrative, technical, and physical security measures to protect against unauthorized access, use or disclosure of your personal information. Our third-party service providers are asked to implement comparable data protection and security policies.

But no security measures are infallible, we cannot guarantee the security of your information. Because information security depends, in part, on the security of the computer, device or network used to communicate with us, please take appropriate measures to protect your information.

Minors

Civis Products and Services and our website are for general audiences and are not targeted to individuals under 16 years of age. We do not collect personal information from any person we know to be under the age of 16, and we will delete any personal information collected that we later learn to be from a person under the age of 16. If you believe an individual under the age of 16 has disclosed personal information to us, please contact us at dataprotection@civisanalytics.com and specify the information you believe to be from the individual under 16.

Third-Party Service

Civis Products and Services may contain links to third party websites, applications, services or social networks and/or make available certain features that allow you to sign into our Civis Products and Services using third-party login credentials or access third- party services from our Platform Services. Any information that you choose to submit to third-party services is not covered by this Privacy Policy.

Changes to this Privacy Policy

We may update this Privacy Policy periodically to reflect changes to our privacy practices. If we make any material changes to our privacy practices, we will indicate within this Privacy Policy the date when it was most recently updated and you shall be bound to such changes. We may also provide notice of such material changes in other manners at our discretion. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

If you have questions about this Privacy Policy or about our privacy practices, you may contact us by emailing DataProtection@CivisAnalytics.com.

Last Updated: July 1, 2023