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Privacy Policy

Privacy Statement

Last Modified: December 12th, 2024

Introduction

Net60 Inc. (“Net60”, “we”, “us” “our” or the “company”) provides crucial services to companies seeking to reach and connect with identifiable markets. While the Net60 website and our other websites (collectively, the “Sites”) are accessible to anyone, our customers are the companies we work with to provide list management and brokerage services and marketing support (collectively, the “Services”). Data is our business and we committed to respecting the privacy of all persons about whom we collect or process data. This Privacy Statement (the “Statement”) explains how and why Net60 collects, stores, uses, discloses, shares, or otherwise processes personal information. This includes, but is not limited to, consumer information we collect and process to provide the Services and business-to-business information we collect about persons working for companies interested in using our Services. You should read this privacy statement in conjunction with the company website Terms and Conditions, which can be accessed by clicking here.

The section titled “Additional Privacy Information for Certain Jurisdictions” below provides information about our compliance with applicable international and U.S. state privacy laws (“Applicable Privacy Laws”). 

•  If you are a resident of California, the “Additional Information for California Residents” subsection contains further information about our handling of your data and your data subject rights. 

• If you are a non-California resident the subsection below titled, “Additional Information for Residents of Other Covered Jurisdictions” includes information about privacy rights you may have under other privacy laws.

Table of Contents

Personal Information We Collect

In order to provide our Services, we may collect and process personal information from the categories listed below. Our listing of these categories does not mean that all categories or the examples listed in each category are collected about everyone for whom we maintain data to provide our Services or with whom we interact. We are providing a list here in the spirit of transparency.

  • Identifiers: This may include name, email address, telephone number, mailing address, and IP address.
  • Commercial information: This may include records of personal property, goods or services purchased or considered, or other purchasing or consuming histories or tendencies.
  • Demographics Information: This may include your age, gender, marital status, disability status, and religious affiliation. (Note: These data attributes may constitute characteristics of protected classifications under CA or federal law.)
  • Internet or other electronic network activity: This may include information collected via cookies and other tracking technologies, including browsing data and information gathered about interactions with our Site.
  • Professional or employment-related information: This may include business name, job title, or job history.
  • Inferences: This may include data attributes (drawn/created from the other data attributes referenced herein) reflecting preferences, characteristics, predispositions, behavior, attitudes, abilities, and/or aptitudes.
  • Sensitive Personal Information: This may include information about your health, age, gender, and religion.

Sources of Personal Information We Collect

We collect and process the categories of personal information listed above from various sources. This section lists and describes those sources. From third parties. We collect and process Personal Information collected by others from third parties to provide the Services to our customers. These third-party sources vary, but could include the following:

  • Third-party data providers: We receive personal information from third-party businesses that collect and aggregate personal information. These data resellers collect personal data from a variety of sources, including directly from consumers, through devices and browsers, public records, news sources, and from other businesses and data brokers.
  • Business customers: Our business customers provide us with personal information in connection with the provision of our Services to them. For example, customers may provide us mailing lists that we refine and append data onto for subsequent customer marketing campaigns.
  • Technical Service Partners: We work with a variety of third-party service providers to enhance and provide our Services. Our service providers may provide hosting, marketing, analytics, advertising, and maintenance services. In working with our service providers, we may share personal information with them and receive personal information back from them so that we may improve.

Directly from you: We collect personal information directly from you when you provide it to us, for example, when you request information or contact us with inquiries about the Services or via email; subscribe to email updates; or submit content or other material through the Sites.

Indirectly from visitors to the Sites. We may automatically collect personal information from you when you engage with the Sites through the use of tracking technologies or by other passive means. This “passively collected” information helps us to improve our offerings and allows us to ensure our Services work as designed and in a way that meets our customers’ expectations. Some examples include:

  •  Log Information. Through the use of analytics tools, we may automatically record information that a browser or mobile device sends when you access our Site. This information may include information such as the type, browser language, computer operating system, name of an internet service provider/mobile carrier, the date and time of a request, etc.
  • Cookies and Similar Tracking Technologies. When you visit or access our Sites, we may utilize cookies (small text files containing a string of characters sent to your computer) or similar tracking technologies that uniquely identify your browser to track your activity and hold certain information. Cookies can be necessary for site navigation and performance, or used for advertising. We use the following types of cookies:
  • o  Necessary Cookies help you access the Sites and facilitate features on the Sites. For example, these cookies make may be used to assist with Site navigation.

    o  Functional Cookies support additional functionalities on our Sites to provide an even smoother experience.

    o  Performance Cookies help us to understand the behavior of our customers. This enables us to keep improving our Services.

    o  Advertising/Targeting Cookies enable us to target our advertisements. For example, these cookies may facilitate the presentation of our advertisements on other sites or applications.

Most web browsers accept cookies automatically but can be configured not to do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. Please note that disabling all cookies could impact the performance of our Sites. We may also use software tools to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. We do not install any spyware or adware on our Sites, or distribute any commercial message, or authorize any third party to distribute any commercial message, by means of spyware or adware. “Spyware” or “adware” is any software which has been downloaded to and/or installed on an Internet user’s computer, without the user’s actual consent, and facilitates the distribution of any commercial message to the user. If you feel you may have spyware from another company installed on your machine, there are various anti-spyware / adware software applications available on the Internet to identify if this has occurred.

How We Use Personal Information

We process your personal information for a variety of reasons, including:

  • To provide our Services to our business customers.
  • To respond to requests and inquiries about our Services.
  • To provide information about our Services, including newsletters, and materials related to our marketing initiatives.
  • To ensure internal quality control and safety.
  • To communicate with our business customers, such as to notify them of changes to our Services agreements, to fulfill a request by related to the Services, or to contact them for any other reason deemed necessary by Net60.
  • To improve and further develop our Services.

How We Disclose Personal Information

We may share data with third-party vendors, service providers, contractors, or other third-parties (collectively, “third parties”) who perform services for us on our behalf and require access to such information to do that work. The categories of third parties we may share personal information with for this purpose include, but are not limited to, providers of:

  • Data Analytics Services
  • Cloud Computing Services
  • Advertising Providers
  • Performance Monitoring Tools
  • Hosting Services

We may also disclose or share the information we collect in connection with our Services with the following recipients and/or under the following circumstances:

  • Business Customers. When providing our Services, we disclose personal information to our business customers. Our customers control the processing of the personal information we provide for their own analytical and/or marketing purposes (e.g., marketing campaigns, market research, predictive modeling, and other purposes). These customers are contractually obligated to comply with applicable law when using and/or storing the personal information that we provided.
  • Government and Legal Authorities. We may disclose personal information in response to lawful requests by governmental and other legal authorities, including requests from national security agencies, consumer protection agencies, courts, and similar authorities.
  • Business Transfers/ Transactions. In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties.
  • Safety, Fraud and Government Requests. We reserve the right to use and disclose personal and non-personal information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of these terms and conditions, or as otherwise required by law. Accordingly, to the extent permitted by law, we may disclose your information to third parties if: (a) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect our property or other rights or those of other users of the Services, third parties or the public at large; or (b) we believe that you have abused the Services by using them to attack other systems or to gain unauthorized access to any other system, to engage in spamming, or otherwise to violate applicable laws or in violation of other terms published by Net60. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.

Additional Privacy Information for Certain Jurisdictions

If you are a resident of California, Subsection 1 includes additional information about your privacy rights under applicable California privacy laws. If you are a resident of another jurisdiction that has enacted an applicable privacy law, please review Subsection 2 below for additional information about your privacy rights under those privacy laws.

1. Additional Disclosures for California Residents

This section provides California residents with information about our collection, use, and disclosure of their personal information. Please reference the other sections of the Privacy Statement for more information about our privacy practices. Collection, Use and Disclosure of Personal Information. The chart below describes how and why we collect, use, and disclose personal information and also describes how and why we have collected, used, and disclosed personal information within the past 12 months, to the extent we have done so.

Categories of Personal Information

Category

Examples

Purpose, Use, and/or Disclosure of Personal Information

Identifiers

This may include your name, email address, telephone number, mailing address, and IP address.

  • To provide our Services to our business customers. This may include disclosures of personal information to business customers that have purchased our Services.
  • To provide information about our Services, including newsletters, and materials related to our marketing initiatives.
  • To respond to requests and inquiries.
  • To ensure internal quality control and safety.
  • To communicate with users/customers.

Commercial Information

This may includerecords of personal property, goods or services purchased or considered, or other purchasing or consuming histories or tendencies.

  • To provide our Services to our business customers. This may include disclosures of personal information to business customers that have purchased our Services.

Demographic Information

This may include yourage, gender, marital status, disability status, and religious affiliation. 

(Note: This data attributes may constitute characteristics of protected classifications under CA or federal law)

  • To provide our Services to our business customers. This may include disclosures of personal information to business customers that have purchased our Services.

Internet or other electronic network activity

This may includeinformation collected via tracking technologies, including your browsing data and information gathered about your interactions with our Site.

  • To provide our Services to our business customers. This may include disclosures of personal information to business customers that have purchased our Services.
  • To provide our Site to our customers and other visitors. This may include disclosures to our technical service providers.

Professional or employment-related information

This may includeyour business name, job title, or job history.

  • To provide our Services to our business customers. This may include disclosures of personal information to business customers that have purchased our Services.
  • To provide information about our Services.
  • To communicate with users/customers.

Inferences

This may includedata attributes (drawn/created from the other data attributes referenced herein) reflecting the consumer’s preferences, characteristics, predispositions, behavior, attitudes, abilities, and aptitudes.

  • To provide our Services to our business customers. This may include disclosures of personal information to business customers that have purchased our Services.

Sensitive Personal Information

This may include information about your health, age, gender, and religion.

  • To provide our Services to our business customers. This may include disclosures of personal information to business customers that have purchased our Services.

Selling and Sharing of Personal Information .As described above, Net60 does engage in disclosures of personal information to our business customers. Under the CCPA, some of these disclosures qualify as “sales.” We do not have actual knowledge of any “sale” of personal information of minors under 16 years of age. We may “sell” all of the categories of personal information listed above when providing our Services. Furthermore, we may “share” Internet or other Electronic Network Activity” information with our advertising partners for our own advertising purposes. You may limit our sale/sharing of your personal information by clicking on this link or following the instructions found below in the section titled “Exercising Your Rights.” Please note that as a data broker, in some instances we lease and manage data lists that we do not own or control. In those instances, you will have to make requests to limit the sale/sharing of your personal information directly to the companies that own or control those lists. Retention of Personal Information. We maintain the categories of personal information described above for as long as is necessary for the purposes described in this Statement or as otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

  • Your personal information is reasonably necessary to manage and provide the Services, to manage your relationship with us, or to satisfy another purpose for which we collected the information.
  • Your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected.
  • Your personal information is reasonably required to protect or defend our rights or property, which will generally relate to applicable laws that limit actions in a particular case.
  • We are otherwise required or permitted to keep your personal information by applicable laws or regulations.

Where personal information is used for more than one purpose, we will retain it until the purpose with the latest period expires. The categories of and the sources from which we collect personal information vary based on our relationship or interaction with a specific California resident and the business purpose for which the personal information is collected. Please reference the “Personal Information We Collect” and “Sources of Personal Information We Collect” sections for more information about these practices. Details regarding how we may share personal information are available in the “How We Disclose Personal Information” section above.

California Consumer Rights. Subject to certain exceptions, as a California resident, you have the following rights to your personal information:

Right to Know and Access: Request access to your personal information that we have collected, used, disclosed, or sold about you, including:

  • The categories of personal information we have collected about you, including:
  • o  The categories of sources from which the personal information was collected;

    o  Our business or commercial purposes for collecting or disclosing personal information;

    o  The categories of recipients to which we disclose personal information; and

    o  The categories of personal information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of personal information; or

  • The specific pieces of Personal Information we have collected about you.

Right to Deletion: Request deletion of your personal information that we collected from you and retained, subject to certain limitations. If you ask to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as but not limited to:

  • 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 an ongoing business relationship with you, or otherwise perform our contract with you.
  •  Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Exercise free speech to ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code 1546 seq.).
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which data was collected. Right to Correction: You have the right to request that we correct personal information we maintain about you that you believe is inaccurate.

Right to Opt-out of Sales and Sharing: As described above, you have the right to opt-out of your personal information being shared for purposes of targeted advertising. Right to Limit Use and Disclosure of Sensitive Personal information: You have the right to instruct us to limit the use of your Sensitive Personal Information for purposes not specifically authorized by the CCPA. We currently do not use Sensitive Personal Information for such purposes. Right to Non-Discrimination for the Exercise of Rights: You have the right to be free from unlawful discrimination for exercising your rights under the CCPA. We will not discriminate against you based upon your exercising your rights with respect to your personal information.

Exercising Your Rights.

If you are a California resident and wish to exercise any of these rights, please use the webform available at here or call us at 833-460-6860.

When submitting your request, you must provide sufficient information that allows us to verify you are the person about whom we collected personal information or their authorized agent. This information includes your first and last name, email address, and address (if applicable). When submitting your request, please provide sufficient detail that allows us to properly understand, evaluate and respond to the request. We will only use personal information provided in your request to verify your identity or authority to make the request. If we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud prevention purposes. 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 that the personal information relates to you. Authorized Agents. You have the right to designate an authorized agent to act on your behalf to exercise your rights under the CCPA. In order to do so, Net60 must verify your identity, and your authorized agent must have written permission from you. We reserve the right to deny a request from an agent that does not submit proof that they are authorized to act on your behalf. Response TimingWe will attempt to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and the necessary extension period in writing. Data Subject Request Metrics. As of July 1, 2024, under the Delete Act of 2023 (SB 362) and in compliance with Cal. Civ. Code section 1798.99.85, we are required to publicly disclose certain metrics related to data broker activities. In adherence to these requirements, we are providing you with the following information for the year 2024:

Request Type

Total Received

Total Complied With

Total Denied

Average Days to Complete

Median Days to Complete

Right to Know/Access

0

0

0

0

0

Right to Correct

0

0

0

0

0

Right to Delete

0

0

0

0

0

Right to Opt-out

0

0

0

0

0

Right to Limit Use

0

0

0

0

0

2. Additional Information for Residents of Other Covered Jurisdictions

Residents of certain international jurisdictions and U.S. states (other than California) may also have the right to receive disclosures regarding a business’ processing of “personal data”, as defined under Applicable Privacy Law. Residents of these jurisdictions may have unique rights with respect to our processing of such personal data. To the extent you are a resident of a jurisdiction with such a privacy law, and we collect, use or disclose personal data subject to your jurisdiction’s privacy law, this section of our Statement applies. For more information about the personal data we collect, use and disclose, please see “Personal Information We Collect,” “How We Use Personal Information,” and “How We Disclose Personal Information” sections in this Statement. DATA BROKER NOTICE. 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. Consumer RightsUnder Applicable Privacy Law, you may have the following rights:

  • Right to Access: You may have the right to confirm whether or not we are processing your personal data and to access such personal data.
  • Right of Portability: You may have the right to obtain a copy of the personal data in an accessible and machine-readable format.
  • Right to Delete: You may have the right to ask us to delete certain personal data we have collected about you. 
  • Right to Correction: You may have the right to ask us to correct inaccuracies in the personal data we have collected. 
  • Right to Opt-out of Sale: For purposes of this subsection, a “sale” includes disclosing or making available personal data to a third party in exchange for money. You may have the right to opt-out of such sales.
  • Right to Opt-out of Targeted Advertising: You have the right to opt out of the processing of your personal data if it is used for targeted advertising. Applicable Privacy Laws may provide the right to opt out of the processing of personal data for decisions that produce legal or similarly significant effects concerning you.

Exercising Your Rights. If you are a resident of a jurisdiction that has enacted an applicable privacy law and wish to exercise any of these rights, please use the web form available here or call us at 833-460-6860. Verification Process. We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identify before processing your request. If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf. Response Timing. Upon receiving your request, we will attempt to respond within 45 days. The response period may be extended when reasonably necessary. We will inform you of any such extension within 45 days of receiving your request, together with the reason for the extension. Right to Appeal. If we decline to take action regarding your request, we will inform you of our decision and the reasoning behind it. If you wish to appeal our decision, please contact us using the information provided here. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason(s) for the decision. If your appeal is denied, residents of certain U.S. states may contact their Attorney General to submit a complaint related to the denial.

Non-US Residents

Our Services are not directed at or intended for users outside the United States. Please be advised that if you are located in the European Union or another region with laws related to data collection and use that may differ from United States law, your personal information submitted through the Services and transferred to the United States may not have the same legal data protection as in your jurisdiction.

Privacy Information of Children

Because of applicable state and federal law, we cannot collect any personal information from a child under the age of thirteen without the consent of that child’s parent. Although our Website is not designed for or marketed to children, the provisions in this Privacy Statement generally about our collection and use of personal information also apply to our treatment of personal information from children under the age of thirteen, with the added protection of the special rules that follow. We strongly encourage parents and guardians to spend time online with their children and be aware of the sites which their children are frequenting on a regular basis.

Security

We work hard and have implemented certain industry-standard security policies, measures, procedures and rules to safeguard and protect your personal information from improper use and disclosure, unauthorized modification, unlawful destruction or accidental loss. The security of your personal information is of utmost importance to us, and we strive to ensure its security through encryption and other measures implemented on our systems. However, no data transmission over the Internet can be guaranteed to be completely secure, and we cannot guarantee the security of the personal information you transmit to us. You transmit such information at your own risk. We will continue to assess, update and improve our systems to provide you with additional protection for your personal information.

Changes to this Privacy Statement

If we decide to make a change to our Privacy Statement, we will post a notification and link on our homepage so that you can review the updated Statement. If at any point we wish to use your personal information in a manner different from that stated at the time it was collected, we will notify you by means of an e-mail and give you the opportunity to indicate whether you consent to the proposed use. Keep in mind, however, that we reserve the right to amend or modify this Privacy Statement at any time and without prior notice.

Modification to this Privacy Statement shall be posted on this webpage and will be effective immediately upon posting.

Contact Us

If you have questions or concerns about this Privacy Statement, please Contact Us.