AtData, LLC, together with Xverify, LLC and FreshAddress (collectively, “AtData”), complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. AtData has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Economic Area in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF, and to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this notice and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit dataprivacyframework.gov/list.

This notice applies to the following U.S. entities, each of which adheres to the DPF Principles and is covered by AtData’s DPF certification, as shown on the Data Privacy Framework List:

• AtData, LLC
• Xverify, LLC
• FreshAddress

This notice supplements AtData’s Privacy Policy.

Onward Transfers and Liability

AtData is responsible for the processing of personal data it receives under the DPF and subsequently transfers to a third party acting as an agent on its behalf. AtData complies with the DPF Principles for all onward transfers of personal data from the European Economic Area, the United Kingdom (and Gibraltar), and Switzerland, including the onward transfer liability provisions. Under the Principles, AtData remains liable if an agent it uses processes such personal data in a manner inconsistent with the Principles, unless AtData proves that it is not responsible for the event giving rise to the damage.

Enforcement

AtData is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) with respect to its compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

Complaints and Dispute Resolution

For any complaints or concerns related to AtData’s processing of personal data, please contact AtData at [email protected]. We will respond to your complaint within 45 days of receiving it.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, AtData commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to the Association of National Advertisers (ANA), an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit the ANA’s DPF consumer page for more information or to file a complaint. The services of the ANA are provided at no cost to you.

Binding Arbitration

Under certain conditions, more fully described in Annex I of the DPF Principles on the DPF website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted. AtData is obligated to arbitrate claims and follow the terms set forth in Annex I of the DPF Principles, provided that an individual has invoked binding arbitration by delivering notice to AtData and following the procedures and subject to the conditions set forth in Annex I.

Collection and Use of Personal Data

AtData acts as a data controller for personal data it collects through its own websites and from its own customers, and as a data processor when it handles personal data on behalf of its customers.

We collect the following types of personal data from you directly, for example when you sign up for our mailing list, create an account, complete a survey, request information, place an order, or otherwise communicate with us, and automatically through cookies and similar technologies when you use our websites:

• Personal and contact details: name, email address, telephone number, and mailing address.
• Account and login information: username, email address, and password.
• Commercial or transactions information.
• Information about your interactions with us: browser type, email opens, IP address, pages visited and other activity on our websites, and device type.
• Other information you choose to provide, such as the content of an inquiry, complaint, or survey response.

We use this information to create and manage your account; to respond to you and communicate with you; to send you updates, promotions, and marketing materials; to operate, improve, and personalize our websites and services; for analytics, market research, and product development; to maintain the security of our websites and services, including fraud prevention; and to comply with the law and enforce our terms and conditions.

We also receive personal data indirectly:

• From our customers, for our SafeToSend email validation service: your email address, which we process to confirm whether it is a valid email address.
• From our customers, for our Fraud API service: your email address, and, where the customer provides them, your name, postal address, phone number, and/or IP address. We process this information to generate an overall risk score associated with the email address.
• From third parties, including companies that collect and supply consumer data, public sources, and our marketing partners.

SafeToSend and Fraud API are the only services that involve personal data of individuals in the European Economic Area, the United Kingdom, or Switzerland. AtData’s data enrichment and data licensing services operate only in the United States. AtData does not collect sensitive personal information.

When we obtain personal data from third-party sources, we use it only for the purposes described in this notice.

Disclosures of Personal Data

We may share personal data with our customers in order to provide our services, with advertising providers and platforms that help us market our services, and with members of our corporate group.

We may share personal data with third parties who provide services on our behalf to help with our business activities. These service providers include credit card processors, cloud computing infrastructure companies, data quality service providers, and a partner that provides phone number validation services for our Fraud API service. These companies are authorized to use personal data only as necessary to provide these services to us.

If AtData is involved in a merger, acquisition, or sale of all or a portion of its assets, we may share personal data with potential purchasers, their affiliates, and advisors as part of that transaction or proposed transaction.

In certain situations, AtData may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal data as required by law, such as to comply with a subpoena or other legal process, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Security, Retention and Data Integrity

AtData maintains physical, electronic, and procedural safeguards designed to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We retain the personal data we control for as long as is necessary or appropriate to fulfill the purpose for which it was collected, including to comply with our legal obligations, resolve disputes, and enforce our agreements.

Access

With regard to personal data AtData controls, upon request, we will provide you with information about whether we hold any of your personal data. You may access, correct, or request deletion of your personal data by contacting us at [email protected]. If you request deletion, we will remove you from our marketing lists, but we will continue to maintain certain personal data where we have an important legal, accounting, billing, or auditing reason to do so. This right of access applies only to personal data about the individual making the request and is subject to other limitations as defined by law, or where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual or where the rights of other individuals would be violated.

As a processor, AtData acknowledges that you have the right to access your personal data. In that role, AtData generally has no direct relationship with the individuals whose personal data it processes. An individual who seeks access to, or seeks to correct, amend, or delete, personal data should direct the request to AtData’s customer, the data controller. If you contact us with the name of an AtData customer to whom you provided your personal data, we will refer your request to that customer and support them in responding to it.

Choice

We provide choices and means for individuals to limit the use and disclosure of their personal data. We will give you the opportunity to opt out before your personal data is disclosed to a third party (other than a third party acting as our agent) or used for a purpose that is materially different from the purpose for which it was originally collected or later authorized by you. Upon request, we will remove your name and related information from our direct marketing information products. To exercise a choice, contact us at [email protected].

In certain circumstances, we may be required by law to retain your personal data or may need to retain it to continue providing a service.

Changes to this Notice

We may update this notice to reflect changes to our information practices. If we make any material change, we will notify you by means of a notice on this website. We encourage you to review this page periodically for the latest information on our privacy practices.

Contact Us

If you have questions or concerns about this notice, you may contact AtData by:

Email: [email protected]

Mail:
Chief Privacy Officer
Compliance Department
Experian / AtData
475 Anton Blvd.
Costa Mesa, CA 92626