Civic Element LLC Privacy Policy

Effective Date: 10/8/2025

Civic Element LLC (“Civic Element”, “we,” “our,” or “us”) provides this privacy policy to describe how we collect, use, and share the information of individuals through our Civic Element^TM data service (“Services”) or who visit our website at www.civicelement.com (the “Site”).

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Information Collection

When using our Site, you may provide information about yourself, including your name, contact information, log-in information, and any other information you choose to provide. We collect this information when you join our email list, create an account, or interact with us for any other purpose.  

Through our Services, we also process other data that we derive or purchase from third parties. For example, we may purchase voter data from third parties and combine this with data from other sources or derived data. This data may include your and your household’s demographic data, mailing or physical address, employment-related information, voter registration status, voting history, statistical and market area information, area selection data, lifestyle and wealth data, political contribution information, census data, and other voter-related information. We may collect or receive this data from a variety of sources, including consumer data resellers. We may also receive physical address information from our customers or other third parties, or we may derive address information from other location information we receive or collect from devices.

We (and other entities) automatically collect information relating to your interactions with us and our Site, including browser type, IP address, pages visited and other activities on the Site, device type, and time and date of visit, and other information we collect through the use of cookies and similar technology.  See the “Digital Analytics” section of this privacy policy to learn more about the use of this information and the choices available to you.  

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Information Use

We may use your information for any lawful purpose, including the following:

• To respond to your inquiries, including to fulfill orders or contact you about order status;
• To operate and improve our products and Services, including to develop new features and content; 
• To operate, personalize, and improve the Site, including for analytics purposes;
• To promote and market our products and Services, including to send updates, promotions, advertisements and marketing materials that may be of interest to you;
• For internal purposes, including research and analytics related to our Site or Services;
• To comply with the law and to maintain the security of our Site; or 
• With your consent, or as otherwise disclosed at the time information is collected.

We may use information that has been de-identified or aggregated without limitation. 

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Information Sharing 

Through the Services, we may share the various types of information we obtain from third-party partners or infer with our affiliates, customers, agents, or data augmentation providers for a variety of lawful purposes, including improving our products and services, increasing engagement, advertisement targeting, and marketing and advertising purposes.  Information we share may be used by our customers to conduct campaigns or outreach to you, or our data augmentation providers to enhance data they maintain or process such data through machine-learning models to improve its value.  We “sell” “personal data” or “personal information” (collectively, “personal information”) as those terms are defined in state privacy laws.  See the State Privacy Rights section below to learn about how to opt out of our sales of personal information.

We may share the information we collect with other parties, including the following:

• With third-party service providers who process information on our behalf, such as payment processors, data hosting services, and email service providers, or with our legal or business advisors;
• With any affiliates or joint venture partners that we may have in the future;
• As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding;
• Pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, to protect our rights or the rights of third parties, or to protect the safety or security of any person or entity;
• With your consent or as otherwise disclosed at the time of data collection or sharing.

We may share information that has been de-identified or aggregated without limitation.  

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Digital Analytics

We may work with third parties that collect data about your use of the Site and other sites or apps over time for non-advertising purposes.  Civic Element uses Google Analytics and other third-party services to improve the performance of the Site and for analytics and marketing purposes.  For more information about how Google Analytics collects and uses data when you use our Site, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.

Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our Site may not function as intended.

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Third-Party Links and Tools

The Site may provide links to third-party websites or apps.  We do not control the privacy practices of those websites or apps, and they are not covered by this privacy policy.  You should review the privacy policies of other websites or apps that you use to learn about their data practices.

The Site also includes integrated social media tools or “plug-ins,” such as social networking tools offered by third parties.  If you use these tools to share personal information or you otherwise interact with these features on the Site, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public.  

Your interactions with third-party companies and your use of their features are governed by the privacy policies of the companies that provide those features.  We encourage you to carefully read the privacy policies of any accounts you create and use.

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STATE PRIVACY RIGHTS

Some U.S. states—California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia (collectively, “Certain States”)—grant individuals certain rights under state privacy laws with respect to personal information we collect.  If you are subject to the privacy laws of such states, this section of the Privacy Policy contains disclosures required by law and explains rights that may be available to you.

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Personal Information We Collect and Disclose.  In the preceding 12 months, we collected and disclosed the following categories of personal information: 

• Personal and online identifiers (such as first and last name, email address, demographic information, mailing or physical address, voter registration status, voting history, statistical and market area information, area selection data, lifestyle and wealth data, political contribution information, census data, and other voter-related information, or unique online identifiers);
• Characteristics of legally protected classifications (such as gender or age);
• Commercial or transactions information (such as records of personal and real property or products or services purchased, obtained, or considered);
• Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement);
• Geolocation information (such as mailing and physical address but excluding precise geolocation data);
• Professional or employment-related information;
• Education information;
• Inferences drawn from the above information about your predicted characteristics and preferences; and
• Other information about you that is linked to the personal information above.

We engage in "sales" of personal information as defined by state laws.  However, we do not knowingly sell or share personal information of individuals under 16.  Specifically, in the past 12 months, we have sold the above-listed categories of personal information to our customers so they may conduct campaigns or outreach to you, and our data augmentation providers to enhance the data maintained and process such data through machine-learning models to improve its value.  

We do not sell or share sensitive personal information.  

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Categories of Sources. We collect personal information from the following categories of sources: 

• You;
• Our affiliates and joint venture partners;
• Our business partners, including consumer data resellers and third parties that collect or augment voter files; 
• Government entities;
• Our service providers; and
• Advertising companies and networks. 

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Our Purposes for Processing Personal Information.  We use and disclose the personal information we collect for our commercial and business purposes, as further described above in the “Information Use” section of this Privacy Policy.

We may use and share de-identified information to the extent permitted by applicable law.  When we use de-identified information, we maintain and use the information in de-identified form and do not attempt to re-identify it, except to check whether our deidentification processes satisfy the requirements of applicable law.

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Recipients of Personal Information.  We disclose the categories of personal information designated above to the categories of third parties listed above in the “Information Sharing” section of this Privacy Policy for commercial and business purposes. 

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Your Rights.  Residents of Certain States have rights with respect to the personal information collected by Civic Element.  You may be able exercise the following rights regarding personal information, subject to certain exceptions and limitations:

• The right to confirm whether we are processing personal information about you.
• The right to know or access the categories and specific pieces of personal information we collect, use, disclose, and sell about you; the categories of sources from which we collected personal information about you; our purposes for collecting or selling personal information about you; the categories of personal information about you that we have sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal information.
• For Connecticut, Minnesota, and Oregon residents, the right to obtain a list of the specific third parties to which we have disclosed personal information;
• Depending on your state law, the right to receive a portable and readily usable copy of the personal information we have collected about you, to the extent feasible. 
• The right to correct inaccuracies in the personal information we have collected about you. 
• The right to request that we delete the personal information we have collected about you.
• The right to opt out of the sale of personal information.  
• The right not to receive discriminatory treatment for the exercise of the above privacy rights.

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

• Online at www.civicelement.com/privacy-policy-request.  
• By phone at (888) 417-6553.

Additionally, for individuals subject to state laws in Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, and Virginia, if you have submitted a request that we have not reasonably fulfilled, you may contact us to appeal our decision by completing this form at www.civicelement.com/privacy-policy-request.

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Verification Process and Required Information:  Note that we may need to request additional information from you to verify your identity or understand the scope of your request to confirm/know/access, port, correct, or delete.  You will not be required to create an account with us to submit a request or have it fulfilled.  We will require you to provide, at a minimum, basic contact information like your name and phone number. 

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Authorized Agent:  Depending on your state law, you may also designate an authorized agent to make requests on your behalf by designating such an agent in writing or through a power of attorney.  We will require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests to confirm/know/access, port, correct, or delete from the agent.

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Opt-out Preference Signals:  Under some state privacy laws, certain mechanisms or technologies may be used to signal your opt-out preferences to entities that process personal information.  You may select and install a mechanism or technology to send opt-out preference signals of your choice per the provider’s instructions.  To the extent that we are able to recognize these signals and they are legally sufficient, we receive these signals as requests to opt out of sales of personal information.  We respond to the opt-out preference signals we receive in accordance with requirements under applicable law.  Depending on the signal you select, the opt-out preference signal may apply to only certain interactions, such as interactions on a specific browser or device.  To opt out of our sale of identifiable personal information about you, such as your name and physical address, use one of the rights request methods listed in this section above.

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Retention

We retain personal information in identifiable form only for as long as necessary to fulfill the purposes for which the personal information was provided to us or, if longer, to comply with legal obligations, to resolve disputes, to enforce agreements, or to satisfy any similar essential purposes.  To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we process personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.  Once the retention period expires and if not otherwise required to retain information by law, we will delete or de-identify personal information.     

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Your Choices

To opt out of our email marketing, you can use the link provided at the bottom of each marketing message.  If you opt out of our email marketing, we will still send you messages related to our transactions and relationship with you, such as order confirmations.

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Texas Data Distribution

‍The entity maintaining this website is a data broker under Texas law. To conduct business in Texas, a data broker must register with the Texas Secretary of State (Texas SOS). Information about data broker registrants is available on the Texas SOS website.

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Changes to Our Privacy Policy

If our information practices change, we will post these changes on this page.  We encourage you to visit this page periodically to learn of any updates.

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Contact

If you have questions, comments, or concerns about this privacy policy, please submit your inquiry at www.civicelement.com/privacy-policy-request.

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