Privacy Policy 

Last Updated: February 6, 2024

This Privacy Policy describes how Luminate Data Holdings, LLC, Luminate Data, LLC, or Quansic SARL, as applicable (collectively, “we,” “us,” and “our”) collect, use, and disclose personal information and business information, on or through our websites, services, products, databases, software, tools and apps where this Privacy Policy is linked or referenced (collectively, the “Services”) and in our offline interactions where this Privacy Policy is referenced. This Privacy Policy also applies to information we collect through third-party marketplaces that supply our data products.

This Privacy Policy applies to website visitors, customers, and users of our Services. It does not apply to personal information we collect from our employees and contractors. This Privacy Policy is not a contract and does not create any legal rights or obligations.

For the purpose of European data protection laws, we act as a controller in connection with certain personal information described in this Privacy Policy.

If you are a California resident, see Section 6 (Your California Privacy Rights) for information provided pursuant to the California Consumer Privacy Act. If you are a data subject in the European Economic Area or United Kingdom, see Section 7 (Your EEA and UK Privacy Rights) for information provided pursuant to the European Union General Data Protection Regulation. Residents of Canada have additional rights under Canadian law and can learn about them under Section 8 (Your Canadian Privacy Rights).

1. Types of information we collect.

a. For our data products (such as Music Connect, Luminate Film & TV, ScreenScore, Luminate Insights, Streaming Viewership (M), and Quansic Data Explorer):

We collect information from and about the music and entertainment industries (including persons involved in those industries) as part of the data products we provide to our customers. Our customers include, but are not limited to, streaming platforms, music labels, publishers and producers, entertainment studios, producers and distributors, and agencies. We collect both business information and certain personal information, including:

Music. We collect sales, analytics, engagement, and other performance metrics associated with content, services, and performances by musicians, entertainers, creators, and other artists. We also collect and license music identifiers relating to songwriters, musicians, artists, musical works and recordings.

Film and TV. We collect information about programming slates, credits, box office ratings, events and awards, client lists, and industry contacts for studios, networks, and talent (e.g., actors’, artists’ or other performers’) representatives. We collect names, photos, titles, project history, and social media handles/links for industry representatives and talent. We also collect talent birthdates, country of origin, and languages spoken; information about talent searches to create screen scores; and demographic information such as ethnicity, gender, and public LGBTQ+ identification for diversity, equity, and inclusion purposes.

Research or Survey Information. We may collect contact information, survey answers, and user-generated content, if you participate in a research study or survey.

b. From our platform (such as our websites, apps, and API tools):

We also collect information from or about you when you interact with us or our Services. The information we collect and the purposes for which we use it depends on the specific Services you use and how you interact with us. For example, we collect information when you register for an account, subscribe to our Services or newsletters, make a purchase, request a quote or demo, register for an event, participate in a survey panel, or send us an email or feedback. We may collect, receive, and develop several different types of personal information, including:

Registration or Contact Information. We may collect your name, email address, phone number, and mailing address.

Financial and Transactional information. We may collect your payment information to process payments and information about your transactions and purchases with us. We may also collect purchase history and billing information.

Demographic Information. We may collect voluntary demographic information in job applications for purposes of equal employment or diversity initiatives, such as your age, age, date of birth, gender, race/ethnicity, and LGBTQ+ status.

Location Information. We may collect information about your location using your IP address and your zip code.

Information You Submit. We collect any information you provide when you contact us or create an account. This may include customer service communications or contact information for others whom you refer to our Services.

Preference Information. We may collect information about your preferences when you use the Services. We may also collect information about your preferences that you share.

Internet and Network Activity Information. We may collect information about the browser you are using and your IP address. We might also collect device identifiers and attributes. We may use tracking tools like cookies to automatically collect information about how you interact with our Services and online content, such as your browsing and search history on our Services, what areas of our Services you visit and for how long, what content (including emails) you click on, what files you download, what site you came from, what site you visit when you leave us, and your views and clicks of our digital ads and content on other sites.

Professional and Business Information. We, or our vendors, collect information about your employment, including your job title or occupation, as well as information you submit as part of your user profile or information that is publicly available about your employment.

Inferences. Using the other pieces of personal information collected about you, we may develop and collect inferences about you, reflecting what we believe to be your preferences, characteristics, experiences, predispositions, and attitudes.

2. We use information as described here.

We use information to respond to your requests or questions. For example, we may contact you about the feedback you have given us. We will also use certain pieces of information to verify your identity if you make certain requests pursuant to this Privacy Policy.

We use information to provide the Services to you. For example, we may use your information to provide you with access to the Services, provide you with professional or support services in connection with such access, process and fulfill your subscriptions to the Services, and/or maintain and service your account.

We use certain information to provide the Services and information to others. For example, as part of our data products, we provide film and television programming information, talent information, and contact information for industry representatives to clients and subscribers. We also provide music performance and other business information to others about music consumption and sales, analytics, engagement and other performance metrics associated with content, services, and performances by musicians, entertainers, creators and other artists.

We use information to improve and customize our Services. For example, we may use your information or feedback to make our Services (including our websites, apps, and services) better. We might use your information to customize your experience with us or deliver relevant content based on your interests.

We use information to administer our business and services and for internal operations. This might include troubleshooting, data analysis or testing. We may use information from different sources to update, validate or supplement the information that you provide or that we collect automatically. We might also use information for research, statistical and survey purposes.

We use information for security and legal purposes. We may use information to protect our company or other third parties. These third parties may include business partners, customers or other individuals. We also may use information to protect our Services, as well as to detect and investigate activities that may be illegal or prohibited. We may use information to comply with our legal obligations and defend our legal rights.

We use information for marketing and advertising purposes. For example, we might use your information to tailor and send you information about our business, products, or services. Our marketing or advertising might be for our own Services, or for other companies’ offers, products, or services that we think you might find interesting. To learn about your choices for these communications, read Section 5 (You have choices regarding our use of your information) below.

We use information to communicate with you about our relationship. For example, we might contact you about our policies or our terms.

We use aggregate and/or deidentified information. We may aggregate and/or de-identify any information collected so that it can no longer be linked to you or your device. We may use such aggregate and/or de-identified information for any purpose, including research and marketing, and may also share such data with any third parties, including advertisers, promotional partners, and others, in our discretion.

We collect publicly available information.  We collect information from a variety of publicly available information and media. For instance, if a performer discusses their religion or ethnicity in an interview, we may add that information to our databases.  (This information is often not considered “personal information” or “personal data” subject to various state data privacy laws.)

We use information as otherwise required, disclosed or permitted by law or as we may notify you from time to time. 

3. We collect information from different sources, directly and indirectly.

We collect information directly from you. For example, we collect information if you set up an account or sign up for our email list. We also collect information if you submit feedback or otherwise contact us.

We collect information from your devices. We may use tracking tools like browser cookies, pixels/web beacons, and similar technologies (collectively “cookies”) to automatically collect information about you when you interact with our Services and emails that we or our vendors send to you. We may collect information about users over time and across devices when you use our website. We may have third parties collect personal information this way.

We get information from suppliers and marketplaces. For example, vendors that host or maintain our Services for us may give us information. Also, marketplaces that supply our data products may give us information about your account, address, and transactions.

We collect information from studios, networks, and streaming platforms. For example, we may obtain information about programming slates, credits, and industry contacts directly from studios and networks; music performance metrics from streaming platforms, retailers and radio stations; and talent information from agencies or studio representatives. If you are authorized to use the Services by a customer or subscriber (such as your employer), we may receive information from or on behalf of the customer or subscriber.

We get information from other parties and sources. We may obtain information from other data providers (such as to enhance or verify our information). We also work with business and marketing partners that might also include social networks and advertising and analytics providers or content platforms that share information with us. We may also obtain information from public sources, including press releases, interviews, and information released by media companies, including our affiliates. We may also receive other information from our affiliates and subsidiaries.

We may combine any information we collect. For example, we may combine information that we have collected offline with information we collect online. Or we may combine information we get from another party with information we already have.

4. We share information with other parties.

We share information within our family of companies. This includes our subsidiaries, parents, affiliates, and joint venture partners.

We share information with vendors who perform services on our behalf for our business and operational purposes. We may share information with vendors who manage subscriptions or orders, process payments, provide customer support, send emails for us, manage, and operate our Services, assist us in our marketing and advertising, including partners that contribute to our promotional efforts, track advertising impressions, provide analytics services, investigate, and prevent data incidents, audit our records, and provide legal advice. We may also share information with analytics and search engine providers.

We share information with our clients, subscribers, licensees, and business partners. We license data products to our customers through the Services, including through APIs, dashboards, and downloads, which may include information about individuals such as industry representatives, talent, and artists. We may sometimes share this information with our customers’ service providers (e.g., through their customer relationship management software).

We share information with marketing and data and advertising partners: We may also share your contact or business information with other parties for third party marketing purposes, such as other marketers, participatory databases, event sponsors, and non-profit organizations, including for the other parties’ own marketing purposes.

We may share information with third-party ad platforms and ad networks. We may also share information about your use of the Services with social media platforms, advertising networks, ad tech companies, and analytics providers through third-party technologies integrated into our Services. In addition, we sometimes provide certain information (such as email addresses) to service providers, who may “match” this information in hashed form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and apps. Personal information received by our partners and other parties may also be subject to their privacy policies.

We will share information for safety and security purposes, if we think we have to in order to comply with the law, or to protect ourselves, our customers and others. For example, we may share information to respond to a court order or subpoena. We may also share information if a government agency or investigatory body requests it. We might also share your information in order to enforce our agreements, and to protect the rights and safety of others. We might also share information when we are investigating potential fraud or misuse of the Services.

We may share information with a successor to all or part of our business. For example, if part of our business is sold, we may include user information as part of that transaction. We may also share your information if there is a change to our corporate structure. We may also share your information with others as they conduct diligence of our corporate changes.

We may share information for other reasons we may describe to you from time to time or as permitted or required by law. 

5. You have choices regarding our use of your information.

You can opt out of receiving our promotional emails. To stop receiving our promotional emails, click on the “unsubscribe” link in any promotional email and follow the instructions in any email you receive from us.

You can control cookies and certain tracking tools. We may collect information about users over time and across different websites and devices. To do this, we and our vendors use several tracking tools, such as browser cookies, web beacons, and other technologies. For instance, we may use Google Analytics to better understand how our users interact with our websites.

You can use the methods described below to manage certain cookies. We do not control the third-party or browser- or device-level opt-out mechanisms and settings below or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Analytics: To disable certain analytics cookies, you can use the browser controls discussed below or, for some of our providers, you can use their individual opt-out mechanisms, such as the Google Analytics Opt-Out.

Using Browser Settings. Your browser may give you the ability to control cookies. How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies. Please note that if you use your browser settings to block all cookies you may not be able to access parts of our or others’ services. The following links provide information on how to modify the cookies settings on some popular browsers:

• Apple Safari
• Google Chrome
• Microsoft Internet Explorer
• Mozilla Firefox

Mobile Settings: Your mobile device may also include settings that allow you to manage the use of cookies, such as App Tracking Transparency settings in iOS and Delete Advertising ID in Android.

Interest-Based Advertising: Many third-party advertisers offer a way to opt out of their interest-based advertising. In addition to the steps described above, you may opt out of certain targeted advertising from participating entities by visiting the “opt out” and information web pages hosted by the Network Advertising  Initiative and Digital Advertising Alliance, Digital Advertising Alliance of Canada, and/or European Interactive Digital Advertising Alliance.

If you block cookies, certain features on our Services may not work properly. If you block or reject cookies, not all of the tracking described here will stop. Certain options you select are browser and device specific, which means you need to make the selection for each browser on each device you use. If you change or upgrade your browser or device, or delete your cookies, you may need to use these opt-out tools again. Some cookie-management solutions also rely on cookies, so please adjust your browser cookie settings carefully. Information may still be collected and used for other purposes, such as internal operations and to remember your opt-out preferences.

You can contact us. You can contact us at privacy@luminatedata.com or by writing to us at Luminate Data, LLC, Attn: Data Privacy, 5670 Wilshire Blvd., 11^th Floor, Los Angeles, CA 90036, to request that we not share your name, postal address, email address, phone number, and certain other personal information with third parties for promotional or marketing purposes.

6. Your California Privacy Rights.

The California Consumer Privacy Act of 2018 (“CCPA”), amended by the California Privacy Rights Act (“CPRA”), provides certain rights to California residents regarding their personal information. In the tables and sections below, we describe (as required by the CCPA):

• Our collection of personal information: the types of personal information (as defined by the CCPA) that we collect, and the types of sources we collect it from.
• Our business purposes: our business purposes for (a) collecting and (b) sharing personal information, which are generally the same.
• Our disclosure, “sale,” and “sharing” of personal information: the types of recipients to whom we disclose, “sell,” or “share” personal information.
• 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 data products (also called “do not sell or share” rights), or to request categories and personal information that we may have collected about you.

a. Our collection of personal information and business purposes

Information you and other parties provide to us:

Categories of information collected	Purposes of use	Sources of personal information	Categories of third parties to whom we disclose the information
Registration, Subscription or Contact Informationsuch as name, email address, phone number, and billing information	Provide the ServicesCommunicate with You & Provide Customer ServicePersonalize Your ExperienceImprove the ServicesOur Marketing and Third-Party Marketing and Advertising PurposesBug detection and error reportingAuditing Consumer InteractionsSecurity, Fraud, and Legal Compliance	YouOther users who provide information about youData resellersPublic records databasesMarketersConferences and other eventsOur Affiliates	Service ProvidersOur AffiliatesOther Individuals, Services, and Partners at Your RequestPromotions ProvidersPartners to Provide Co-Branded Products and ServicesMarketersSocial Media NetworksEntities for Legal PurposesEntities For Sales or Transfer of Business or Assets
Customer service informationsuch as content you submit through online forms, by email or over the phone; and summaries or recordings of your interactions with customer service	Provide the ServicesCommunicate with You & Provide Customer ServiceBug detection and error reportingSecurity, Fraud, and Legal ComplianceImprove the Services	YouOur Affiliates	Service ProvidersOur AffiliatesEntities for Legal PurposesEntities For Sales or Transfer of Business or Assets
Financial and transactional informationsuch as credit or debit card number, verification number, and expiration date, to process payments; and information about your transactions and purchases with us	Provide the ServicesCommunicate with You & Provide Customer ServiceSecurity, Fraud, and Legal Compliance	YouThird-party payment processors who collect this information on our behalf and who also have an independent relationship with youThird party partners or co-branded partners	Service ProvidersOur AffiliatesThird Parties for Legal PurposesThird Party For Sales or Transfer of Business or Assets
Professional Informationsuch as industry, job title, company, credits, project history, awards, scores, client lists, business/employee contact information, photos, and social media handles/links	Provide the ServicesCommunicate with You & Provide Customer ServicePersonalize Your ExperienceImprove the ServicesOur Marketing and Third-Party Marketing and Advertising PurposesBug detection and error reportingAuditing Consumer InteractionsSecurity, Fraud, and Legal Compliance	YouOther users who provide information about youData resellersPublic records databasesMarketersConferences and other eventsOur AffiliatesSocial media networks, in accordance with your privacy preferences on such services	Clients and SubscribersService ProvidersOur AffiliatesOther Individuals, Services, and Partners at Your RequestPromotions ProvidersPartners to Provide Co-Branded Products and ServicesMarketersSocial Media NetworksEntities for Legal PurposesEntities For Sales or Transfer of Business or Assets
Background and demographic informationsuch as talent birthdates, country of origin, languages spoken, and demographic information such as race/ethnicity, gender, and LGBTQ+ identification	Provide the ServicesCommunicate with You & Provide Customer ServicePersonalize Your ExperienceImprove the ServicesOur Marketing and Third-Party Marketing and Advertising PurposesBug detection and error reportingAuditing Consumer InteractionsSecurity, Fraud, and Legal Compliance	YouOther users who provide information about youData resellersPublic records databasesMarketersConferences and other eventsOur Affiliates	Clients and SubscribersService ProvidersOur AffiliatesOther Individuals, Services, and Partners at Your RequestPromotions ProvidersPartners to Provide Co-Branded Products and ServicesMarketersSocial Media NetworksEntities for Legal PurposesEntities For Sales or Transfer of Business or Assets
Research or survey information such as personal identifiers and user-submitted content if you participate in a survey or research study	Provide the ServicesCommunicate with You & Provide Customer ServicePersonalize Your ExperienceImprove the ServicesOur Marketing and Third-Party Marketing and Advertising PurposesBug detection and error reportingAuditing Consumer InteractionsSecurity, Fraud, and Legal Compliance	YouSurvey partnersResearchers and analysts	Clients and SubscribersService ProvidersOur AffiliatesOther Individuals, Services, and Partners at Your RequestPromotions ProvidersPartners to Provide Co-Branded Products and ServicesAdvertisersEntities for Legal PurposesEntities For Sales or Transfer of Business or Assets
Job application informationsuch as your education history, employment experience, and demographic information	Provide the ServicesCommunicate with You & Provide Customer ServicePersonalize Your ExperienceImprove the ServicesOur Marketing and Third-Party Marketing and Advertising PurposesSecurity, Fraud, and Legal Compliance	YouOther users who provide information about youData resellersOur AffiliatesPublic records databasesConferences and other eventsMarketersSocial media networks, in accordance with your privacy preferences on such services	Service ProvidersOur AffiliatesOther Individuals, Services, and Partners at Your RequestPromotions ProvidersPartners to Provide Co-Branded Products and ServicesMarketersSocial Media NetworksEntities for Legal PurposesEntities For Sales or Transfer of Business or Assets
Contact Information about otherssuch as name and email address to refer others to us	Provide the ServicesCommunicate with You & Provide Customer ServiceImprove the ServicesAuditing Consumer InteractionsSecurity, Fraud, and Legal ComplianceOur Marketing Purposes	YouOther users (if you are the recipient of a communication)Our Affiliates	Service ProvidersOur AffiliatesOther Individuals, Services, and Partners at Your RequestEntities for Legal PurposesEntities For Sales or Transfer of Business or Assets
Inference Datasuch as your potential preferences that we infer from your activities on the Services, and inference information we receive from other parties	Provide the ServicesCommunicate with You & Provide Customer ServicePersonalize Your ExperienceImprove the ServicesOur Marketing and Third-Party Marketing and Advertising Purposes	Our AffiliatesData resellersAnalytics Providers	Service ProvidersOur AffiliatesAdvertisers, Ad Networks and Advertising PartnersSocial Media NetworksEntities for Legal PurposesEntities For Sales or Transfer of Business or Assets
Other informationany other information you choose to directly provide to us in connection with your use of the Services	Provide the ServicesCommunicate with You & Provide Customer ServicePersonalize Your ExperienceImprove the ServicesOur Marketing and Third-Party Marketing and Advertising PurposesBug detection and error reportingAuditing Consumer InteractionsSecurity, Fraud, and Legal Compliance	You	Service ProvidersOur AffiliatesOther Individuals, Services, and Partners at Your RequestSocial Media NetworksEntities for Legal PurposesEntities For Sales or Transfer of Business or Assets

Information we collect automatically from you and/or your device:

Categories of information collected	Purposes of use	Sources of personal information	Categories of third parties to whom we disclose the information
Device information and identifierssuch as IP address; browser, device, and operating system information; and unique device, advertising, and app identifiers	Provide the ServicesPersonalize Your ExperienceImprove the ServicesOur Marketing and Third-Party Marketing and Advertising PurposesBug detection and error reportingAuditing Consumer InteractionsSecurity, Fraud, and Legal Compliance	You (through your device)Advertising providersAnalytics providersCookies and tracking technologies	Service ProvidersOur AffiliatesAdvertisers, Ad Networks and Advertising PartnersSocial Media NetworksEntities for Legal PurposesEntities For Sales or Transfer of Business or Assets
Internet network and device activity datasuch as information about files you download, website/app usage and browsing activity, content or ads viewed and clicked, form entries, search terms, websites you visit before and after this website, your interactions with emails, and other similar information	Provide the ServicesPersonalize Your ExperienceImprove the ServicesOur Marketing and Third-Party Marketing and Advertising PurposesBug detection and error reportingAuditing Consumer InteractionsSecurity, Fraud, and Legal Compliance	You (through your device)Advertising providersAnalytics providersCookies and tracking technologiesMarketersOur Affiliates	Service ProvidersOur AffiliatesAdvertisers, Ad Networks and Advertising PartnersSocial Media NetworksEntities for Legal PurposesEntities For Sales or Transfer of Business or Assets
Geolocation informationsuch as city, state, and ZIP code associated with your IP address	Provide the ServicesPersonalize Your ExperienceImprove the ServicesOur Marketing and Third-Party Marketing and Advertising PurposesBug detection and error reportingAuditing Consumer InteractionsSecurity, Fraud, and Legal Compliance	YouAdvertising providersAnalytics providersMarketersOur affiliates	Service ProvidersOur AffiliatesAdvertisers, Ad Networks and Advertising PartnersSocial Media NetworksEntities for Legal PurposesEntities For Sales or Transfer of Business or Assets

We collect information deemed “sensitive” under the CCPA, such as race, religion, ethnicity, sexual orientation, and information about specific medical conditions (e.g., neurodivergent status). However, we do so based solely on self-declared, publicly available information (e.g., from interviews with affected individuals) and not for purposes of inferring characteristics about them. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.

b. Our “sale” and “sharing” of personal information

We “sell” and “share” the information collected from and about you with third parties, including our customers, advertising platforms, and marketing partners, for various purposes. Under the CCPA, “sale” and “sharing” are broadly defined such that they may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising or provide analytics on the Services or other websites and apps. We mean the CCPA definitions of “sale” and “sharing” in this Privacy Policy only when these terms appear in quotes.

Depending on what Services you use, we may “sell” or “share” personal information to third parties for these purposes:

• To provide our Services, including creating and licensing our data products, to our clients and subscribers. This includes our provision of datasets and data “appends” (connecting data across datasets).
• For online targeted advertising of our Services and related analytics.
• To send you relevant third-party offers, promotions, and opportunities, including advertisements.

The chart below indicates how and to whom we “sell” or “share” personal information, and whether (based on the CCPA’s definitions) we believe we have “sold” or “shared” a particular category of information in the prior 12 months.

Categories of Information collected	Categories of third parties we may share with	Whether we “sold” or “shared” this category of personal information in the last 12 months
Registration, Subscription or Contact InformationContact information such as name, email address, phone number	Advertisers, Ad Networks and Advertising PartnersPromotions ProvidersMarketersSocial Media Networks	No
Transactional informationsuch as information about your transactions and purchases with us	Promotions ProvidersMarketersSocial Media Networks	No
Professional Informationsuch as industry, job title, company, credits, project history, awards, scores, client lists, business/employee contact information, photos, and social media handles/links	Clients and SubscribersPromotions ProvidersMarketersSocial Media Networks	Yes
Background and demographic informationsuch as talent birthdates, country of origin, languages spoken, and demographic information such as race/ethnicity, gender, and LGBTQ+ identification	Clients and SubscribersPromotions ProvidersMarketersSocial Media Networks	Yes
Research or survey information such as personal identifiers and user-submitted content if you participate in a survey or research study	Clients and SubscribersPromotions ProvidersMarketersSocial Media Networks	Yes
Inference Datasuch as your potential preferences that we infer from your activities on the Services, and inference information we receive from other parties	Advertisers, Ad Networks and Advertising PartnersSocial Media Networks	No
Device information and identifierssuch as IP address; browser, device, and operating system information; and unique device, advertising, and app identifiers	Advertisers, Ad Networks and Advertising PartnersSocial Media Networks	No
Internet network and device activity datasuch as information about files you download, website/app usage and browsing activity, content or ads viewed and clicked, form entries, search terms, websites you visit before and after this website, your interactions with emails, and other similar information	Advertisers, Ad Networks and Advertising PartnersSocial Media Networks	No
Geolocation informationsuch as city, state, and ZIP code associated with your IP address	Advertisers, Ad Networks and Advertising PartnersSocial Media Networks	No

c. Your California privacy rights and choices

Access, correction, and deletion rights. In certain circumstances (subject to various exceptions and limitations under the CCPA, if you are a California resident, you can make the following requests with respect to your personal information:

• Access – You can request that we disclose to you the categories of personal information we collected about you, the categories of sources from which we collected the personal information, the categories of personal information we “sold,” “shared,” or disclosed, our business or commercial purpose for collecting and “selling” or “sharing” your personal information, the categories of third parties to whom we disclosed, “sold,” or “shared” your personal information, and the specific pieces of personal information we collected about you over the past twelve (12) months.
• Correction – You can request that we correct inaccurate personal information that we maintain about you, subject to certain exceptions.
• Deletion – You can request that we delete the personal information that we maintain about you, subject to certain exceptions.

A California resident can make a request to access, correct, or delete their personal information by emailing us at privacy@luminatedata.com, filling out this webform, or calling (877) 365-3500. We will take reasonable steps to verify your identity prior to responding to your requests. 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. The verification steps may vary depending on the sensitivity of the personal information.

Once we have verified your identity, we will respond to your access or deletion 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 or other state laws 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 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.

If we are unable to complete your requests fully, we will provide you additional information about the reasons that we could not comply with your request. Please note that certain information may be exempt from such requests under California law. For example, we may need certain information to provide the Services to you; or certain information you provide to us may also be publicly available information which is not considered personal information under the CCPA. Or “deletion” rights may not apply to much of the information in our databases, because those rights only apply to information that we have collected “from” consumers. We may also deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes and to process transactions and facilitate customer requests.

Opt-out of Targeted Advertising/ “Do Not Sell or Share My Personal Information.”  You can request that we not “sell” your personal information to a third party or “share” your personal information for “cross-context behavioral advertising” (also known as targeted advertising).

If you would like to opt out of our use of your information for purposes that are considered a “sale” or “sharing” under California law, you may do so as outlined on the following page: “Do Not Sell or Share My Personal Information.” You can also submit a “sale” or “sharing” opt-out request by completing our webform. If you opt out in this way, we will also cease sharing your information for purposes of targeted advertising or “sharing” under California law. On that same page, we provide additional information regarding how to opt out of targeted advertising through other ad platforms we partner with. Likewise, we provide information on that page as to how we honor opt-out preference signals.

Please note that we do not knowingly “sell” or “share” the personal information of minors under 16 years of age without legally required affirmative authorization.

Other rights and exceptions. We will not discriminate against you because you made a request. Note that this Privacy Policy does not apply to personal information about employees and other of our personnel; or information we have collected as a service provider to our clients.

Designated agent. You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent and has a signed, written permission or a power of attorney from you to make such requests. We may also follow up with you to verify your identity before processing the authorized agent’s request.

Shine the Light. If you reside in California, you may have the right to ask us one time each year if we have shared certain 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. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.

Retention. We retain information as a “business” under the CCPA in accordance with Section 12 (How long we retain your information).

7. Your EEA and UK Privacy Rights.

As detailed below, where provided under applicable law in the European Economic Area (EEA) and United Kingdom (UK), you may request information about the personal information about you that we hold, and you may ask about all recipients of the information, the purpose of the processing, request the correction of incorrect information, and request the blocking, deletion and portability of such information by contacting us at privacy@luminatedata.com. We may require you to prove your identity with approved identification if you request this information.

Lawful basis for processing your personal data 

We process on the following legal bases:

1. Contract: If it is necessary for our performance of the contract you have agreed to enter with us. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of the contract.
2. Legitimate Interests: We process your personal data if it is based on our legitimate interests. For example, we may process personal data in reliance on a legitimate interest in the effective and lawful operation of our business, the effective delivery and improvement of our products, services, and platforms, information security operations, compliance with laws and regulations, compliance with requests for disclosure to law enforcement, courts, and regulatory bodies, to prevent misuse, to resolve technical issues, and to prevent and detect fraud or suspected fraud. In relation to general inquiry and complaints you send us, our legitimate interest is to provide you with information you have requested and to provide customer support. You can object to the processing that we carry out on the grounds of legitimate interests. See the section “Rights of data subjects” below to find out how.
3. Consent: Where you have given us consent to do so, we provide you, or permit third parties to provide you, with information about goods or services which we feel may interest you. You have the right to withdraw your consent. Please see the section “Rights of data subjects” below to find out how.
4. Legal Claims: We need to process your personal data to defend or establish a legal claim (for example, claims relating to the sale of our goods and services under contract law).

Rights of data subjects 

You have the following rights, where provided under applicable law, regarding your information (each of which are subject to various exceptions and limitations):

1. The right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Privacy Policy.
2. The right of access: You have the right to obtain access to your information (if we are processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you are aware and can check that we are using your information in accordance with data protection law.
3. The right to rectification: You are entitled to have your information corrected if it is inaccurate or incomplete.
4. The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. The right to restrict processing: You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability: You have rights to obtain and reuse your personal data for your own purposes across different services and platforms. 7. The right to object: You have the right to object to certain types of processing, in particular processing based on our legitimate interests. You also can object at any time to your information being used for direct marketing purposes (including profiling related to such direct marketing). Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

We may request you provide us with information necessary to confirm your identity or your authorization to represent a data subject before responding to your request.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to your data protection authority.

Please note your rights in relation to your personal data are not absolute. We may, for example, deny you access to your personal data when required or authorized by law, or if granting access would have an unreasonable impact on another individual’s privacy.

We will retain and use your personal information as described in this Privacy Policy, including as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

For purposes of European data protection laws, the controller responsible for the described data collection and processing is Luminate Data, LLC, Attn: Data Privacy, 5670 Wilshire Blvd., 11^th Floor, Los Angeles, California 90036.

8. Your Canadian Privacy Rights.

Residents of Canada may access, review, and request correction of their personal information held by us.

We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.

We reserve the right not to change personal information if we disagree that it is incorrect, but we will append your requested alternative information. We may not provide access to personal information where permitted or required to deny access by the applicable law, for example, where the information requested would disclose the personal information, including opinions, of another individual or if it is subject to solicitor-client or litigation privilege.

You have the right to refuse to provide or to withdraw your consent to processing of your personal information at any time with effect for future processing. This would not affect processing where the applicable law allows us to process personal information without consent.

9. Our Services are not intended for children.

We do not knowingly collect personal information from children under 18. If you are a parent or legal guardian and think your child has given us information, you can contact us at privacy@luminatedata.com. You can also write to us at the address listed at the end of this Privacy Policy. Please mark your inquiries “Children’s Information Request.”

10. Information transfer and storage.

Our Services may be operated in the United States and other countries located outside of the EEA and UK. Please be aware that information you provide to us may be transferred to or processed in the United States or other countries located outside of the EEA and UK. The standard of data protection in the United States and in certain other countries where we may process your information is considered by the European Commission to be not adequate when compared to the data protection standards of the EEA and UK. Please also be aware that by using our Services or giving us your information, you consent to such transfer.

11. We use certain standard security measures.

We cannot promise that your use of our Services will be completely safe. Any transmission of your data to our Services is at your own risk, and your use of the Services indicates your agreement to assume this risk. We encourage you to use caution when using the Services. This includes not sharing your passwords.

12. How long we retain your information.

We keep personal information as long as it is necessary or relevant for the practices described in this Privacy Policy, including, for example, use for the Services, for legal compliance, dispute resolution, contract enforcement, backup, archival, and other internal operations purposes, and to the extent we have not received a “deletion” request (subject to any need to retain the information for legal purposes).  We also keep information as otherwise required or permitted by law.

13. We may link to third party sites or services we do not control.

If you click on a link to a third-party site, you will be taken to a website we do not control. This Privacy Policy does not apply to the privacy practices of that website, which may collect information from you. Read the privacy policy of other websites carefully. We are not responsible for these third-party websites or their policies. If you access a third-party website from the Services, you do so at your own risk.

14. No rights of third parties.

This Privacy Policy does not create rights enforceable by third parties.

15. Feel free to contact us if you have more questions.

If you have any questions about this Privacy Policy or want to ask us to correct, update, provide access to, delete, or take any other action with respect to your information, please email us at privacy@luminatedata.com. Please do not include your credit card number or other sensitive information in your email. You can also write to us at:

Luminate Data, LLC

Attn: Data Privacy

5670 Wilshire Blvd., 11^th Floor

Los Angeles, California 90036

In addition, pursuant to Article 27 of the General Data Protection Regulation (GDPR), we have appointed European Data Protection Office (EDPO) as our GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

• by using EDPO’s online request form: https://edpo.com/gdpr-data-request/; or
• by writing to EDPO at Block 1, Blanchardstown Corporate Park, Ballycoolin Rd, Dublin D15 AKK1, Ireland.

16. We may update this Privacy Policy.

From time to time, we may change our privacy policies. We will post an updated copy of our Privacy Policy on our website. Please check our site periodically for updates. Your continued use of our sites or services means that you consent to the collection, use and disclosure of your information as set out in the updated Privacy Policy.