Privacy Policy – Updated October 1, 2024

Introduction

1. TargetSmart Communications LLC (“TargetSmart” or “we”) operates this website to specialize in providing data-driven solutions that empower clients to understand, engage, and activate their key stakeholders. Our mission is to empower forward-thinking campaigns, companies, governments, labor unions, and non-profits to harness the full power of data, technology, and strategy to win their battles and build a better future.
2. TargetSmart respects the privacy of every individual about whom we provide information. We offer our clients information management services and information products to help with targeted communications and opinion research. When TargetSmart provides information products to our clients, we adhere to the information practices described in this Privacy Policy (“Privacy Policy”).
3. The Privacy Policy covers the privacy policy of our website(targetsmart.com) and any tools, data, or resources related to, or linked, this website (“Services”)
4. We review this Privacy Policy no less than yearly but reserve the right to update it anytime. Any change in the Privacy Policy will become effective when posted to our website. Your continued use of the TargetSmart website, our products, or our services will act as your acceptance of this Privacy Policy and any update made to the Privacy Policy.
5. Most information gathered by TargetSmart is not done via this or any other TargetSmart website. Most TargetSmart data is collected from outside sources, including but not limited to data service providers, data vendors, publicly available data, and governmental agencies and regulatory bodies. This Privacy Policy addresses information from all outside sources and any information collected from this website.
6. TargetSmart is not responsible for our clients and customers’ data security practices when acting as a processor or service provider. When TargetSmart acts as a processor or service provider, you should reach out directly to the controller of your information to determine their specific privacy policies. TargetSmart is not responsible for any third party’s data security practices or privacy policy provisions.
7. For purposes of this section, the terms “personal information” and “sensitive personal information” encompass the terms “personal data” and “sensitive personal data” and have the meaning provided under U.S. state privacy laws that are inclusive of but not limited to: the California Consumer Privacy Act, the California Privacy Rights Act, the Colorado Privacy Act, the Connecticut Personal Data Privacy and Online Monitoring Act, the Oregon Consumer Privacy Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Privacy Act. The meaning of these terms refers back to terms defined in such state privacy laws and may exclude publicly available, deidentified, and aggregated information; information subject to the Fair Credit Reporting Act, Gramm Leach Bliley Act, Health Insurance Portability and Accountability Act, and Driver’s Privacy Protection Act; or information that is otherwise exempted or excluded by state privacy laws. In accordance with applicable laws, we commit to maintaining and using deidentified data, as that term is defined under applicable law, in accordance with law. Any users of the services linked to this policy will be referred to as “consumers.”

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Personal Information that we collect and hold about you

1. TargetSmart is the sole and exclusive owner of any material or data on this site.
2. TargetSmart’s information products help our clients, a wide variety of public-facing organizations, membership organizations, researchers, data compilers, and suppliers manage, use, and optimize data and assist them in identifying and reaching relevant audiences.
3. TargetSmart brings information products and services to market through Analytics Data Installs, ListBuilder, Digital Voter Files, SmartVAN, Polling services, Communications services, Data Enhancement services, and Strategic Consulting, each containing only the information needed for their intended use. Each of TargetSmart’s information products is designed for specific use by our clients who have a legitimate need for the product. While TargetSmart is a data company, we do not sell data collected from visitors to our website or information their web browsers provide to any of our clients.
4. This Privacy Policy defines personal information, personally identifiable information, or “PII” broadly as information that can be used to distinguish a person, a device, or to trace an individual’s identity, either alone or when combined with other information that is linked or linkable to a specific individual.
5. TargetSmart uses cookies and other tracking technologies and allows our advertising partners to use similar technologies so we can, among other things, show ads promoting our client’s messaging on other sites and services. These activities may be considered “sales,” “sharing,” or “targeted advertising” under applicable laws.
6. We collect and hold your personal information from different sources to fulfill our client’s needs. The outline below defines the categories of personal information we may have collected in the past twelve (12) months, listed by category of services. Please note: The information in the chart below may appear in one or more categories:

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Use of Your Information

1. The information that TargetSmart makes available to our clients is used for many purposes, including but not limited to enhancing customer and constituent files and providing lists for activities such as prospecting, voting, advocacy, marketing, and fundraising. Examples of the ways your information is used for business purposes:

• Targeting, delivering, and optimizing direct outreach campaigns through the mail, phone, in-person, and e-mail; and media campaigns through digital, broadcast, print, earned and out-of-home channels,
• Assisting clients in measuring the effectiveness of ad campaigns,
• Creating data and identity linkages to match common identities across different data sources,
• Creating inference models about people, households, postal addresses, or unique online identifiers,
• Categorization of specific audiences based on shared interests or preferences,
• Cross-channel marketing,
• Population research and analytics.

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Sharing and Disclosure of Your Information

1. TargetSmart may disclose your information for use by qualified companies, non-profit organizations, and political organizations in their marketing, fundraising, customer service, and constituent service and outreach programs.
2. Our client and supplier contracts require that any data sent to us be legally obtained for the uses to which it will be put. Additionally, we require that our client’s usage of any data received from us comply with applicable data protection laws and industry best practices. We also agree to comply with information providers’ restrictions on the data we receive. Our clients’ information is the sole property of our clients, and the rights we have concerning our clients’ information are the rights they grant to us. We use and share personal information that our clients share with us in the manner requested or authorized by our clients, consistent with the restrictions placed on that information.
3. We may share personal data we obtain with the following third parties:
   1. Agents and Service Providers who help with our business activities or provide services requested by our clients. These companies are authorized to use your personal data only as necessary to provide these services to us. These services may include data storage, customer service, and business operations.
   2. Business and Data Partners and Clients to help provide more tailored advertising and for analytical purposes.
   3. Affiliates, Partners, and Subsidiaries: to provide necessary services.
   4. Change of Control or Ownership when TargetSmart may transfer your personal information as an asset part of a merger, acquisition, bankruptcy, or other transaction with a third party that assumes control of all our part of our business.
4. In certain situations, TargetSmart may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
5. We may also disclose your personal data as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, respond to a government request or where there has been a change in ownership, merger, or acquisition.

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Security, Retention, and Data Integrity

1. TargetSmart follows accepted standards and maintains physical, technical, and administrative safeguards to protect personal data. TargetSmart continually monitors access to its systems to detect unauthorized attempts to gain access to information. We may retain your information for as long as our client accounts are active or as needed to provide services, comply with our legal obligations, resolve disputes, and enforce our agreements.

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Access

1. TargetSmart has no direct relationship with the individuals whose personal data it processes. However, an individual who seeks access to correct, amend, or delete inaccurate data is welcome to contact us with questions regarding their data.
2. In certain circumstances, we may be required by law to retain your personal data or may need to retain your personal data to continue providing a service.

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Children Under the Age of Eighteen

1. We do not collect personal information from any person we know to be under the age of 18, and we will delete any personal information collected that we later know to be from a person under the age of 18. Our products and services are not targeted at people under 18 years of age.
2. If you believe a child under the age of 18 has disclosed personal information to us, please get in touch with us at privacy@targetsmart.com and specify the customer and information you believe to be from a child under 18.

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Opt-Out Preference Signals

In certain states, consumers may opt out of personal information sales, sharing, and targeted advertising by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC), on the browsers and/or extensions supporting such a signal.  TargetSmart currently does not take any action in response to these signals.

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State Consumer Privacy Rights

1. States have differing laws that provide specific rights regarding personal information depending on your state of residence. All state laws will be defined collectively as “Applicable Privacy Laws.” Please reference your state law to determine your precise rights in the following states:
   1. California Privacy Rights Act (inclusive of the California Consumer Privacy Act, “CPRA”)
      California Consumer Privacy Act, as amended by the California Privacy Rights Act (https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?division=3.&part=4.&lawCode=CIV&title=1.81.5)
      California Consumer Privacy Act regulations (https://cppa.ca.gov/regulations/)
   2. Colorado Privacy Act (“CPA”)
      Colorado Privacy Act – (https://leg.colorado.gov/bills/sb21-190)
      Colorado Privacy Act Rules – (https://coag.gov/resources/colorado-privacy-act/)
   3. Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CPDPA”) (https://portal.ct.gov/ag/sections/privacy/the-connecticut-data-privacy-act)
   4. Montana Consumer Data Protection Act (“MCDPA”) – (https://leg.mt.gov/bills/2023/billpdf/SB0384.pdf)
   5. Oregon Consumer Privacy Act (“OCPA”) – (https://www.doj.state.or.us/consumer-protection/id-theft-data-breaches/privacy/)
   6. Texas Data Privacy and Security Act (“TDPSA”) – (https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint/consumer-privacy-rights/texas-data-privacy-and-security-act)
   7. Utah Consumer Privacy Act (“UCPA”) – (https://le.utah.gov/~2022/bills/static/SB0227.html)
   8. Virginia Consumer Data Protection Act (“VCDPA”) – (https://law.lis.virginia.gov/vacodefull/title59.1/chapter53/)
2. When TargetSmart acts as a service provider to a client, any consumer requests for opt-out, deletion, or access to data shall be made through the client. We will forward any such requests to the specific client to the extent feasible.

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Specific Rights

This section describes your state-provided rights and explains how to exercise those rights. Please also consult the rest of our general privacy policy for complete details.

1. The Right to Know/Access:
   1. You have the right to request that TargetSmart disclose certain information about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Disclosure, and Deletion Rights), we will disclose to you:
      1. The categories of personal information we collected about you.
      2. The categories of sources for the personal information we collected about you.
      3. Our business or commercial purpose for collecting or selling that Personal Information.
      4. The categories of third parties with whom we share that Personal Information.
   2. If we provide this information to you electronically, it will be in a portable format. To the extent that it is technically feasible, we will give you the information in a readily usable format that you can easily transfer to another entity.
   3. California residents also have the right to request that we disclose the categories of their personal information that we collect, use, or sell.
   4. Residents of states with Applicable Privacy Laws must prove their residency in their respective state.
2. The Right to Correct:
   1. If you determine that TargetSmart has inaccurate personal information about you that we maintain, you have the right to request a correction to that information.
   2. You must use our “Exercising Access, Data Disclosure, and Deletion Rights” system to verify your identity and provide us with any information you wish to correct.
   3. Requests to correct information will only be made where the information provided and the requester’s identity is verifiable.
3. The Right to Delete:
   1. You have the right to request that TargetSmart delete any of your personal information that we collected from you and retain, subject to certain exceptions.
   2. Once we receive and confirm your verifiable consumer request for deletion (see “Exercising Access, Data Disclosure, and Deletion Rights”), we will delete (and direct our service providers to delete) your personal information from our records unless an exception applies.
   3. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
      1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
      2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such actions.
      3. Debug products to identify and repair errors impairing intended functionality.
      4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
      5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
      6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
      7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
      8. Comply with a legal obligation.
      9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
4. The Right to Opt-Out of Personal Information Sales:
   1. You have the right to direct TargetSmart not to sell your personal information at any time (the “Right to Opt-Out”).
   2. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by contacting TargetSmart at the e-mail address or phone number provided in this notice.
   3. Once we receive and confirm your verifiable consumer request for opt-out of the sale/sharing of personal information (see “Exercising Access, Data Disclosure, and Deletion Rights”), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
5. The Right to Non-Discrimination:
   1. You have the right not to receive discriminatory treatment from TargetSmart for exercising the privacy rights conferred by any Applicable Privacy Law.
   2. Choosing to exercise any right that is part of this privacy policy will not cause:
      1. Denial of any goods or services.
      2. Charges of a different price or rate for goods and services, including the granting of discounts, benefits, or penalties.
      3. Different levels of quality of goods or services that may be provided.
      4. Suggestions that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
6. The Right to Opt-Out of Cross-Content Behavioral Advertising, Automated Decision-Making/Profiling, or Targeted Advertising.
   1. You have the right to direct TargetSmart not to use your personal information at any time for cross-content behavioral advertising, automated decision-making/profiling, or targeted advertising.
   2. Submit your consumer request to opt out of cross-content behavioral advertising, automated decision-making/profiling, or targeted advertising on the TargetSmart “Exercising Access, Data Disclosure, and Deletion Rights section of our Privacy Policy.
7. The Right to Limit the Use of Sensitive Personal Information(“SPI”).
   1. You have the right to limit how TargetSmart may use your sensitive personal information.
   2. For this section, sensitive personal information varies by state law and may include, but is not limited to:
      1. Social Security Number
      2. Driver’s License Number
      3. Biometric Information
      4. Precise geolocation
      5. Racial description
      6. Ethnic origin
8. The Right to Appeal
   1. If TargetSmart denies a request by a consumer regarding a privacy request, the consumer has the right to appeal that decision.

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Exercising Your Rights

1. To exercise the privacy right described by this Privacy Policy, please submit a verifiable consumer request to one of the below methods:
   1. Fill out the web form found at https://privacy.targetsmart.com.
   2. Phoning us at 888-678-6880.
2. TARGETSMART ONLY ACCEPTS REQUESTS FOR ACTION ON CONSUMER PRIVACY INFORMATION VIA THE METHODS NOTED IN THIS SECTION.  TARGETSMART DOES NOT ACCEPT ANY PRIVACY RIGHTS REQUESTS VIA ANY E-MAIL SUBMISSION.

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Verification Process and Required Information

1. Only you, your legally authorized agent, or a person registered with the California Secretary of State or your states designated regulatory authority can act on your behalf to make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request for your minor child.
2. You may only make a verifiable consumer request for access or data portability twice within 12 months. The verifiable consumer request must:
   1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information; and,
   2. Describe your request with enough detail to understand, evaluate, and respond to it appropriately.
3. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
4. Making a verifiable consumer request does not require creating an account with us.
5. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

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Verifiable Consumer Request Response Timing and Format

1. TargetSmart endeavors to respond to a verifiable consumer request within forty-five (45) days of receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will provide our written response by mail or electronically at your option.
2. Any disclosures we provide will only cover the 12 months preceding the verifiable consumer request’s receipt.
3. Our response will also explain why we cannot comply with a request, if applicable.
4. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
5. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide a cost estimate before completing your request.

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 Authorized Agents

1. Some state laws allow consumers to use authorized agents to submit requests to TargetSmart on their behalf (“Authorized Agent”). If you have elected to use an Authorized Agent, or if you are an Authorized Agent who would like to submit requests on behalf of a consumer, the following minimum procedures will be required before acceptance of any requests by an Authorized Agent on behalf of a consumer.
   1. Authorized Agents must use the TargetSmart Privacy web form(https://privacy.targetsmart.com/) or our toll-free number (1-888-678-6880) to submit any request on behalf of a consumer.
   2. Authorized Agents are required to:
      1. identify themselves as agents and;
      2. submit proof of their agency relationship in the form of a valid power of attorney in compliance with their agent’s state law or reliable evidence of signed permission to act on behalf of a consumer.
2. For the safety and security of the consumer’s information, requests submitted to TargetSmart by an Authorized Agent will require TargetSmart to verify the consumer’s identity by establishing a direct method of communication, either via a valid mailing address or e-mail address, with the consumer and the Authorized Agent.

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CCPA Annual Consumer Privacy Reporting (2023)

1. From January 1, 2023, to December 31, 2023, TargetSmart facilitated requests made by Californian consumers pursuant to CCPA who requested to access information (“requests to know”), delete information (“requests to delete”), and Do Not Sell requests (“requests to opt-out”). Below are the metrics from the previous calendar year on the totals for each type of request.

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Contacts for More Information

1. For questions or concerns about TargetSmart’s privacy policy or practices, please get in touch with us at:
   1. TargetSmart Communications LLC
      Compliance Department
      1-888-678-6880
      privacy@targetsmart.com

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