Services Privacy Policy.
A Cut Above Media, Inc DBA Next Vote Political
Introduction
Welcome to Next Vote Political Privacy Policy (“Privacy Policy”). In this Privacy Policy, we use the terms “NVP “our “, “us” and “we” to refer to Next Vote Political and our affiliates
This Services Privacy Policy below describes our privacy practices for the personal information we collect, use, and share in association with our platform and services. Whenever we refer to “personal information” or “personal data”, we mean either data directly or indirectly related to an individual or pseudonymized data. Pseudonymized data is where the data has been rendered less identifying through technological measures so that it can no longer be attributed to a specific identifiable person without the use of additional information.
How your personal data is collected
Next Vote Political collects data through the following methods:
• Licensed Consumer Data: Next Vote Political obtains licensed pseudonymized consumer data from supply side platforms and third-party data providers. This licensed pseudonymized consumer data is in the form of segments which are lists of pseudonymous IDs that are tied to offline and online attributes about an individual. The attributes in the segments are created from a range of online and offline consumer activity, including IP address, information about a consumer’s web browsing including URLs from a consumer’s website visits, demographics (such as age, gender, and geographic area), and digital identifiers such as cookie IDs, hashed emails, mobile ad id, and other pseudonymous identifiers such as UID 2.0 and Ramp ID.
• Next Vote Political does not collect directly identifiable personal information such as name, address, Social Security number or credit card information as part of this licensed consumer data.
How we may use your personal data
Next Vote Political uses the personal data it collects for various commercial and business purposes, including:
• Consumer Profile-Segments. Next Vote Political uses the licensed pseudonymous consumer data to create inferences about consumers which are then processed to build profiles for Next Vote Political consumer segments.
• Research and development. Next Vote Political uses the licensed pseudonymous data to improve its products and services. For example, Next Vote Political might use data to identify new features that consumers are interested in or to facilitate and improve the accuracy of its clients’ ad targeting.
• Advertising and marketing analytics products and services
• Audience measurement
• User authentication and identity resolution
• Auditing, Legal compliance
• Detecting and protecting against security incidents, fraud, and illegal activity
• Debugging
How we sell & share your personal data
Next Vote Political sells and shares the personal data it collects for various commercial and business purposes, including:
• Sale of segments. We may sell your Personal Data to third party clients who may process your Personal Data linked to the tailored audience segments for purposes of targeted advertising. Note that Next Vote Political does not itself provide the service of targeted advertising (sometimes referred to as “cross-context behavioral advertising”) but, rather, processes and transfers personal data in the form of segments for consumer profiling, to an advertiser’s advertising platform which provides targeted advertising services. You have the right to express a choice regarding Next Vote Poltical using your personal data for the above purposes.
• Data analysis, security, and fraud. We may use personal data and other data for data analysis, security and fraud monitoring and prevention, product development and testing, improving, or modifying our Services, analyzing website traffic patterns and behaviors, and statistical purposes.
• Aggregate Information (De-Identified Data): We may anonymize, de-identify and/or aggregate the personal data that we collect and use such anonymized, de-identified and/or aggregated data for our own business purposes, including but not limited to sharing anonymized and de-identified data with our current and prospective business partners, service providers, affiliates, agents and other third parties for commercial, statistical and market research purposes. We will use and disclose this aggregated or de-identified information for any purpose unless such use is prohibited by applicable law.
Information We Collect
Personal Data we may collect (or have collected in the 12 months preceding the “Effective Date” of this Privacy Policy) about California and other US states residents with applicable privacy laws are listed below by reference to the categories specified. Examples in the list refer to the types of Personal Data described above in this Services Privacy Policy.
CATEGORY
WHAT WE COLLECT
HOW WE COLLECT IT
WHY WE COLLECT IT
WITH WHOM WE SHARE IT
Identifiers
Name, postal address, online identifier, Internet Protocol address, email address, or other similar identifiers, such as LiveRamp’s RampID
Collected online or offline when you directly provide it to us, or licensed and sold to us from third parties such as SSPs and data partners.
We collect this information for the purposes listed in the How Personal Data May Be Used section above.
Shared with our affiliates, partners, sponsors, vendors, and service providers as described in the How We May Sell and Share the Personal Data section above.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Name, address, telephone number, physical characteristics, or descriptions, and or health-related information in the form of segments. (Some personal information included in this category may overlap with other categories.)
Collected online or offline when you directly provide it to us or licensed and sold to us from third parties.
We collect this information for the purposes listed in the How Personal Data May Be Used section above.
Shared with our affiliates, partners, sponsors, vendors, and service providers as described in the How We May Sell and Share the Personal Data we collect section above.
Protected classification characteristics under California or federal law
Age, sex, and sexual orientation.
Collected online or offline when you directly provide it to us or licensed and sold to us from third parties.
We collect this information for the purposes listed in the How Personal Data May Be Used section above.
Shared with our affiliates, partners, sponsors, vendors, and service providers as described in the How We May Sell and Share the Personal Data we collect section above.
Sensitive Data characteristics under US state privacy laws
Racial or ethnic origin or national origin, political opinions, religious or philosophical beliefs, or trade union membership; personal data concerning your mental or physical health condition or diagnosis, sex life, or sexual orientation, status as transgender or non-binary; processing of genetic or biometric data; citizenship or immigration status, precise past or present geolocation data and personal data of a child under 13 or older under applicable US state laws
Subject to the section below on Special or Sensitive Categories of Personal Data, collected online, created as inferences or licensed and sold to us from third parties.
We collect this information for the purposes listed in the section below Where personal data is NOT considered sensitive or sensitive personal data processing is permitted.
Shared with our affiliates, partners, sponsors, vendors, and service providers as described in the How We May Sell and Share the Personal Data we collect section above.
Commercial information
Services purchased, obtained, or considered.
Collected online or offline when you directly provide it to us, or licensed and sold to us from third parties.
We collect this information for the purposes listed in the How Personal Data May Be Used section above.
Shared with our affiliates, partners, sponsors, vendors, and service providers as described in the How We May Sell and Share the Personal Data we collect section above.
Biometric information
Not collected.
N/A
N/A
N/A
Internet or other similar network activity advertisement.
Information on a customer’s interaction with our website or an advertisement on our website.
Collected online when you directly provide it to us, through your use of our website, or licensed and sold to us from third parties.
We collect this information for the purposes listed in the How Personal Data May Be Used section above.
Shared with our affiliates, partners, sponsors, vendors, and service providers as described in the How We May Sell and Share the Personal Data we collect section above.
Geolocation data
Physical location via IP addresses.
Collected online when you directly provide it to us, or licensed and sold to us from third parties.
We collect this information for the purposes listed in the How Personal Data May Be Used section above.
Shared with our affiliates, partners, sponsors, vendors, and service providers as described in the How We May Sell and Share the Personal Data we collect section above.
Sensory data
Not collected.
N/A
N/A
N/A
Professional or employment-related information
If you apply for a job with us, we may collect information related to your employment history.
Collected online or offline when you directly provide it to us or licensed and sold to us from third parties.
We collect this information for the purposes listed in the How Personal Data May Be Used section above.
Shared with our affiliates, partners, sponsors, vendors, and service providers as described in the How We May Sell and Share the Personal Data we collect section above.
Non-public education information
If you apply for a job with us, we may collect information related to your educational background.
Collected online or offline when you directly provide it to us or licensed and sold to us from third parties.
We collect this information for the purposes listed in the How Personal Data May Be Used section above.
Shared with our affiliates, partners, sponsors, vendors, processors, and service providers as described in the How We May Sell and Share the Personal Data we collect section above.
Inferences drawn from other personal information
Profile reflecting a person’s preferences and characteristics.
Collected online when you directly provide it to us, through our clients’ use of our services, or licensed and sold to us from third parties.
We collect this information for the purposes listed in the How Personal Data May Be Used section above.
Shared with our affiliates, partners, sponsors, vendors, and service providers as described in the How We May Sell and Share the Personal Data we collect section above.
Sources of Information
We collected this information from a variety of sources, which is information from consumers shared with us via our data providers, exchanges (SSPs) and other consumer data resellers.
Categories of Third Parties
Next Vote Poltical may disclose or sell the categories of information with certain categories of third parties, such as advertising networks, advertising agencies and marketing companies, social networks, analytics providers, service providers such as data hosting providers, optimization vendors, and document hosting and support services providers, and consumer data resellers.
You may access a list of the specific third parties to which Next Vote Political, when it acts as a controller, has disclosed your personal data:
•By email at privacy@nextvotepolitical.com
•This list is accessible and set out here. You must click on "View our Partners" to see the list
We collected this information from a variety of sources, which are from consumers shared with us via our data providers, exchanges (SSPs) and other consumer data resellers.
NVP may disclose or sell the categories of information with certain categories of third parties, such as advertising networks, advertising agencies and marketing companies, social networks, analytics providers, service providers such as data hosting providers, optimization vendors, and document hosting and support services providers, and consumer data resellers.
How long we keep your personal data
As a data controller, to operate the services for our clients, NVP retains data segments in an aggregate form for up to two years. After that time, the data is automatically deleted. As a data processor, where clients are providing data to NVP for reporting, that data is retained for up to two years at which time it is automatically deleted.
Special or Sensitive Categories of Personal Data:
We do not knowingly collect, or receive any special categories of personal data about individuals in applicable US States where sensitive personal data processing requires an affirmative opt-in or where sensitive data is subject to an opt-out process and an individual has exercised their right to opt-out including: personal data revealing your racial or ethnic origin or national origin, political opinions, religious or philosophical beliefs, or trade union membership; personal data concerning your mental or physical health condition or diagnosis, sex life, or sexual orientation, status as transgender or non-binary; processing of genetic or biometric data; citizenship or immigration status, precise past or present geolocation data and personal data of a child under 13 or older under applicable state laws. NVP also does not knowingly collect any data about other sensitive categories such as personal data about financial account numbers, insurance plan numbers, and criminal convictions or offenses.
Where personal data is NOT considered sensitive or sensitive personal data processing is permitted
We use personal data to create segments (“Segments”) for our clients to use in the following ways:
• Our clients may use health-related Segments about general health and wellness conditions such as an inferred interest in general health and wellness or non-prescription over the counter cough medicine and allergy medications.
• Our clients may use Segments based on political information or interests based on non-sensitive demographic information as further explained below.
NVPP may process Segments based on demographic information such as race, gender, and income range where such is information is not considered sensitive or is permitted pursuant to applicable law. We take steps designed to ensure that this is done in compliance with applicable laws and self-regulatory guidelines, including through our contracts and policies with our clients and partners.
CONSUMER CHOICE
This section details how you can control the collection and use of data by NVP
You can control the data NVP collects about you by:
• Opting out of NVP data collection and interest-based advertising you may choose to opt-out by either clicking opt-out in the footer of this page.
• Opting out of interest-based advertising across companies participating in the Digital Advertising Alliance's self-regulatory program by visiting www.aboutads.info/choices. You can also download the AppChoices app at www.youradchoices.com/appchoices to opt-out of interest-based advertising in mobile apps.
• Managing your cookies. You can do this by changing your browser settings.
Identity Codes
For more information about identity partner LiveRamp and to opt out of the use of your data used for identity code known as RampID, visit https://liveramp.com/opt_out/. To opt out of the use of your data used for identity code known as UID2.0, please visit https://transparentadvertising.org/
Do Not Track
Except for the methods for managing your Personal Data described in this policy, NVP does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser, “Do Not Track” settings and/or signals.
Global Privacy Control (“GPC”)
GPC is a technical specification for transmitting universal opt-out signals, also sometimes referred to as a universal opt-out mechanism, designed to allow you to notify businesses of your privacy preferences, such as whether or not you want your personal information to be sold or shared. It consists of a setting or extension in your browser or mobile device and acts as a mechanism that websites can use to indicate they support the specification. We are aware that various parties are developing GPC signals, and we recognize such GPC signals in accordance with the requirements of applicable US Privacy laws. GPC is a feature that you can enable on a number of internet browsers, including Mozilla Firefox, DuckDuckGo and Brave, or download as a browser extension. For information on how to enable GPC see https://globalprivacycontrol.org/faq
Notice to California Residents: Your Privacy Choices
This section applies only to California residents and supplements the practices described in this Privacy Policy. It describes how we collect, use, sell, share, and retain the Personal Information of California residents, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California privacy laws but does not include information exempted from the scope of those laws.
Your California Privacy Rights
As a California resident, in addition to the rights described elsewhere in this Privacy Policy, you have the privacy rights listed below. However, these rights are not absolute, and in certain cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.
• Know/Access. You can request the following information about how we have collected and used your Personal Information:
The categories of Personal Information that we have collected.
The categories of sources from which we collected Personal Information.
The business or commercial purpose for collecting, “selling,” or “sharing” Personal Information.
The categories of third parties with whom we disclose Personal Information.
A copy of the Personal Information that we have collected about you.
• Delete. You can ask us to delete the Personal Information that we have collected from you.
• Correct. You can ask us to correct inaccurate Personal Information that we maintain about you.
• Opt-out of sales/sharing. If we “sell” or “share” your Personal Information, you can opt-out.
• Limit the Use of Your Sensitive Personal Information. You are entitled to request we limit the use of your sensitive personal information including inferences.
• Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment.
California “Shine the Light Law”
Residents of California have the right to obtain certain information about the types of Personal Information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. However, NVP does not share the Personal Information collected in connection with this policy for its direct marketing purposes. If you wish to submit a request pursuant to Section 1798.83, please contact NVP via email at privacy@nextvotepolitical.com
HOW TO EXERCISE YOUR 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:
• By email at privacy@nextvotepoltical.com
Verification
NVP may require additional information from you to verify your identity before responding to your request. That verification process requires that you visit the online webform at the web address specified above and provide the requested information.
Authorized Agent
You may designate an authorized agent to make a request on your behalf. To do so you must identify your initial online webform entry as originating with a designated agent, at which time we may contact you to further verify the validity of the request. If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and attest to your Californian residency in order to obtain the information.
Time to process your request
We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.
OTHER STATES CONSUMER RIGHTS
Notice to Residents of Other US States
This section applies only to residents of other US States that have comprehensive state privacy laws in force being that of Colorado, Connecticut, Delaware, Florida, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Virginia, and Utah (“Other US States”) and supplements the practices described in this Privacy Policy. It describes how we collect, use, and share Personal Information of such residents, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” means “personal data” as such term is defined under applicable privacy laws of such states but does not include information exempted from the scope of such laws.
Under applicable privacy laws of such states, you may request the rights listed below.
• Access. You can request that we confirm whether we process your Personal Information and to access that Personal Information.
• Correct. You can ask us to correct inaccurate Personal Information that we maintain about you.
• Delete. You can ask us to delete Personal Information provided by or obtained about you.
• Port. You can request to obtain a copy of Personal Information that you have previously provided to us in a portable and, to the extent technically feasible, readily usable format.
• Opt-out of sales, targeted advertising, or profiling. You can opt-out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
To exercise any of the above rights, you or your authorized agent may contact us using the following information and submit the required verifying information, as further described below:
• By email to privacy@nextvotepolitical.com
Verification
NVP may require additional information from you to verify your identity before responding to your request. That verification process requires that you visit the online webform at the web address specified above and provide the requested information. You may designate an authorized agent to make a request on your behalf. To do so you must identify your initial online webform entry as originating with a designated agent, at which time we may contact you to further verify the validity of the request.
Authorized Agent
If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and attest to your residency of the applicable Other US States to obtain the information.
Time to process your request
We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.
Appeals of Our Decisions
In some states, you may appeal to us if we refuse to take action on your exercise of certain choices described above. To appeal such a refusal, please contact us using the information in the Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email. If your appeal is denied, residents of certain states can contact their attorney general.
The applicable US States attorney general and respective privacy divisions are linked below:
• California Privacy Protection Agency
• Connecticut Attorney General
• New Hampshire Attorney General
NOTICE TO INDIVIDUALS RESIDING IN THE EUROPEAN ECONOMIC AREA, SWITZERLAND, OR THE UNITED KINGDOM.
NVP as Data Controller or Data Processor
NVP may act as (1) a “controller” when processing your personal data, and (2) as a “processor” to the extent that it processes your personal data on behalf of and at the instruction of another party, for example a client.
Lawful Basis
We will use your personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable laws for your territories in the following circumstances:
Where we need to perform the contract, we are about to enter or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where you have consented to a certain use of your personal data.
Where we need to comply with a legal or regulatory obligation.
Withdrawing your consent
Where we rely on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us at privacy@nextvotepolitical.com
International transfers of personal data
For individuals in the EEA, UK, and Switzerland
NVP has its headquarters in the United States and many of our partners or vendors are based outside of the EEA, UK, and Switzerland. We may transfer personal data from the EEA, Switzerland, and the UK to the USA and other countries, some of which have not been determined by the European Commission or the UK Secretary of State to have an adequate level of data protection. Whenever we transfer your personal data out of or receive it from the EEA, UK and/or Switzerland, we ensure that it receives a similar degree of protection by entering into the Standard Contractual Clauses approved by the European Commission (and/or the applicable UK and/or Swiss authority) with our applicable partners or vendors.
HOW TO CONTACT US.
If you have any questions about this Privacy Policy, including any request to exercise your legal rights, and/or you have a disability which prevents you from electronically accessing this Privacy Policy and require it to be provided in alternative format, please contact us as follows.
If you are located in the United States or any other country outside of the EEA or UK:
By email to privacy@nextvotepolitcal.com
If you are located in the EEA or the UK, you can contact our data protection officer who is responsible for overseeing questions in relation to this Policy:
By email to privacy@nextvotepolitical.com
Complaints
You have the right to lodge any complaints you have regarding our processing of your personal data with a regulatory authority. We care about your privacy, and we appreciate the chance to address your concerns before you do so.