Faraday Privacy Policy

Last updated: December 30, 2019

Faraday, Inc. (“we,” “us,” “our,” “Faraday”) understands that people who use our services value privacy. This Privacy Policy describes how we collect, use, process, and share information that we collect or that you provide through our website at Faraday.io and all related web sites (collectively, the “Sites”), networks, embeddable widgets, downloadable software, mobile applications (including tablet applications), and other services provided by us and on which a link to this Privacy Policy is displayed (collectively, together with the Sites, our “Services”) as well as from our customers, third parties, and business-to-business lead generation sources. This Privacy Policy also identifies rights consumers may have to control how their information is used and shared.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. By using our Services, you are expressly and voluntarily accepting the terms and conditions of this Privacy Policy and our Terms of Service.

Faraday provides a variety of data marketing and consumer analytics products, technologies, and services designed to provide data intelligence and insights for our clients (“Clients”).

Our Sites are designed for our Clients, prospective clients, and others who want to learn about our Services. We address the information we collect and use from the Sites and business-to-business lead generation sources in Section 4 of this Privacy Policy.

When we handle information on behalf of Client related to their customers and other individuals (“Customers”), we do so as a service provider. We address these practices separately in Section 5 of this Privacy Policy.

1.    Information That We Collect and the Ways We Use It

In order to provide our Services, we obtain information about you through the means discussed below. In addition to the purposes set out below, we may use all or a combination of this information to detect or prevent fraud, and to defend our legal rights and comply with the law. Faraday also receives information through its Sites and from business-to-business lead generation sources. We describe that information in Section 4. We may combine the information that we collect through the Services with information that we collect automatically or receive from other sources. We share and disclose the information we collect as described in Section 2.


Categories of information collected

Purposes of use

(see table below for additional information)

Sources of information

Commercial or transaction information, e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

  • Data marketing services
  • Online targeting
  • Additional marketing services
  • Operate our Services

  • Data compiling companies
  • Public or governmental entities

Demographic and statistical information, e.g., age, date of birth, size for apparel, race, religion, military or veteran status, ancestry, national origin, religion, ethnicity, political opinions, criminal history, medical condition and history, medical products used, marital status, and gender

  • Data marketing services
  • Online targeting
  • Additional marketing services
  • Operate our Services

  • Data compiling companies

Education information, e.g., educational history and academic record

  • Data marketing services
  • Online targeting
  • Additional marketing services
  • Operate our Services

  • Data compiling companies

Geolocation information, e.g., city, state, ZIP code, and precise location

  • Data marketing services
  • Online targeting
  • Additional marketing services
  • Operate our Services

  • Data compiling companies

Inferences, e.g., inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

  • Data marketing services
  • Online targeting
  • Additional marketing services
  • Operate our Services

  • Data compiling companies

Personal identifiers, e.g., name, postal address, telephone number, and email address

  • Data marketing services
  • Online targeting
  • Additional marketing services
  • Operate our Services

  • Data compiling companies
  • Public or governmental entities


The following table provides additional information about the purposes for collecting and using your information

Purposes of Use

Data marketing services, for example:

  • providing marketing information to our Clients (which include companies, government agencies, and political organizations), generally regarding their outreach, marketing, fundraising, customer service and engagement, and outreach activities.
  • helping our Clients identify and understand their Customers better, by providing insights about them.
  • assisting our Clients with our Services to provide their Customers and prospects with better service, improved offerings, and special promotions, for instance, advising on which Customers or prospective customers are most likely to be interested (or disinterested) in certain offers.

Online targeting, for example:

  • creating defined customer segments based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., likely to buy apparel). You may learn more about how to opt out of this and other online ad targeting in Section 3 and Section 10.

Additional marketing services, for example:

  • assisting in targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing.
  • measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases.
  • analyzing and optimizing our Customers’ (or their service providers’) proprietary databases.
  • providing “verification” or data “hygiene” services, which is how companies update and/or “clean” their databases by either verifying or removing or correcting old, incorrect or outdated information.

Operate our Services, for example:  

  • improving, testing, updating and verifying our own database.
  • developing new products.
  • operating, analyzing, improving, and securing our Services.

2.    How We Share Information with Third Parties

We will share the information collected from and about you for the various business purposes described above in Section 1, both with service providers and with third parties including our Clients. The table below shows how and with whom we may share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months. Additional more general disclosure practices are also described below the table. In addition to the following, we may share the information with any other party with your prior consent.


Categories of information collected

Whether We “Sold” This Information in the Last 12 Months

Third Parties To Whom We Disclose Personal Information

Commercial or transaction information, e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

Yes

  • Clients

Demographic and statistical information, e.g., age, date of birth, size for apparel, race, religion, military or veteran status, ancestry, national origin, religion, ethnicity, political opinions, criminal history, medical condition and history, medical products used, marital status, and gender

Yes

  • Clients

Education information, e.g., educational history and academic record

Yes

  • Clients

Geolocation information, e.g., city, state, ZIP code, and precise location

Yes

  • Clients

Inferences, e.g., inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Yes

  • Clients

Personal identifiers, e.g., name, postal address, telephone number, and email address

Yes

  • Clients

We also may share any of the personal information we collect as follows:

Sharing on Behalf of Our Clients: In addition, we may share personal information with third parties at the direction of our Clients. For example, when directed by a Client, we may share personal information with an email marketing service provider who will conduct marketing on behalf of the Client.

Sharing for Legal Purposes:  We may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our clients, our agents and affiliates, its users and/or the public.  We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.  

Sharing In Event of a Corporate Transaction:  We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.

Sharing With Service Providers:  We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.

Aggregate and Deidentified Information:  We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”).   We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

3.    Cookies and Similar Technologies

a. Cookies and How We Use Them

Faraday and its business partners use certain industry-standard technologies, including cookies and similarly functional technologies, which we describe below. (We use these technologies on our website, for instance, and our partners may  use these technologies in their own marketing services.)

We may work with third parties to provide or enhance our Services (e.g. for purposes of tailoring ads, or placing browser cookies), or to offer marketers ways to access or use our Information, often in de-identified form. These partners may set and access their own cookies, pixel tags and similar technologies on your device, which may have cookies with varying expiration periods. Those partners may, likewise, collect various types of information about your browser, device, or browsing activities through use of these cookies.

Cookies, in turn, are small data files that contain a string of characters, such as a  unique browser identifier. Cookies are stored on your computer or other device and act as tags that identify your device. Our (or other companies’) servers send your device a cookie when you visit a website. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access web pages (such as the website of a marketer), pixel tags may generate a generic notice of the visit and permit our partners (or sometimes, us) to read the cookies that a respective company or server has deployed. Pixel tags are used in combination with cookies to track the activity on a site by a particular device. When you turn off cookies, pixel tags simply detect a given  website visit.

We or our service providers, and other online marketing platforms that we or they work with, may use cookies to, among other things, “remember” you, determine visitor patterns and trends, collect information about your activities on our clients’ sites, or interact with the advertising you see. Cookies are used in this way to provide relevant content to you and replace non-relevant communications with ads that better match your interests.

b. Disabling Cookies

Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of our website and other services may be difficult to use or become inoperable.

c. Notice Concerning Do Not Track.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third-party purposes, which is why we describe a variety of opt-out mechanisms in this Privacy Policy. However, we do not currently recognize or respond to browser-initiated DNT signals. Learn more about Do Not Track.

4.    Data Collected Through Our Sites and Business-to-Business Relationships

We will sometimes give you the opportunity to provide information directly to us through our corporate Websites – such as if you are a business interested in a relationship with us. Additionally, as you interact with our Sites, we may use (or engage with business partners and vendors that use) automatic data collection technologies, such as cookies (described above) to collect certain information about your equipment, browsing actions, and patterns. Our data collection practices concerning our Sites are included in the following table:

Categories of information collected

Purposes of collection and use

Sources of information

Business contact information, e.g., email address, name, postal address, phone number, job title

  • Operate our Sites and Services
  • Send you marketing communications
  • Building and managing business-to-business relationships

  • You
  • Business data resellers
  • Conferences/events

Device information and identifiers, e.g., online cookies identifiers, IP addresses, email address

  • Operate our Sites and Services
  • Personalize your experience
  • Secure our Services
  • Fraud prevention and legal purposes

  • You
  • Analytics providers
  • Cookies and tracking technologies

Internet or other electronic network activity information, e.g., browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer's interaction with a website, application, or advertisement.

  • Operate our Sites and Services
  • Personalize your experience
  • Secure our Services
  • Fraud prevention and legal purposes

  • You
  • Analytics providers
  • Cookies and tracking technologies

Customer service information

  • Operate our Sites and Services
  • Communicate with you
  • Secure our Services
  • Fraud prevention and legal purposes

  • You

Other information consumers choose to directly provide to us, including for billing purposes

  • Operate the Sites and Services
  • Send marketing communications
  • Building and managing business-to-business relationships
  • Billing and accounting purposes
  • Communicate with you
  • Secure our Services
  • Fraud prevention and legal purposes
  • You
  • Visitors to the Sites

As with the information we use within our products and services, we also may share any of the personal information we collect on or through our Website(s) as follows:

Sharing for Legal Purposes:  In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our Clients, our agents and affiliates, its users and/or the public.  We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.  

Sharing In Event of a Corporate Transaction:  We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.

Sharing With Service Providers:  We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.

Aggregate and Deidentified Information: We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

5.    Client Information

Faraday, as a service provider, provides its Clients with data modeling and customer insight software and services. For instance, Clients leverage Faraday to recommend specific products to their Customers or determine who to market to through online or offline channel. When our Clients provide us with information relating their Customers or other individuals, we handle it on behalf of our Clients as a service provider.

Our Clients determine how to engage with Customers and thus act as the business that determines the purposes and means of handling Customer data. Customers are ultimately subject to the privacy policy(ies) of the Clients controlling their data, and they should read those policy(ies) carefully. We are not responsible for the privacy practices of our Clients. Accordingly, this Privacy Policy and the rights granted herein (for instance in Section 10) do not apply to data that Faraday handles on behalf of its Clients.

As a service provider, Faraday may only process Client’s data upon instruction from the respective Client. Accordingly, Faraday only shares or discloses Customer data to service providers, Clients, and Client’s service providers per the Client’s instructions. Faraday may also share Customer data (1) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information received by us, whether or not a response is required by applicable law; (2) to enforce our terms of use and other agreements or to protect our rights; and (3) to protect the safety of members of the public and users of the Services.

While Faraday strongly encourages its Clients to adopt responsible approaches to its marketing practices, Faraday is not responsible for the information practices of such Clients.

6.    Third Party Links and Features

The Services may contain links to third-party services, and you may also be able to integrate our Services with third-party services. If you choose to use these third-party services or features, you may disclose your information not just to those third parties but also to their users and the public more generally, depending on how their services function. Faraday is not responsible for the content or practices of such third-party services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

7.    Children’s Privacy

The Services are not intended for children under 13 years of age and we do not knowingly collect, maintain, or use personal information from children under 13 years of age. We will take reasonable steps to delete personal information (as defined by the United States Children’s Online Privacy Protection Act) as soon as reasonably possible if we learn that we have inadvertently collected it from children under the age of 13 without parental consent.

If you learn that your child has provided us with personal information without your consent, you may alert us at optout@faraday.io. If we learn that we have collected any personal information from children under 13, we will promptly take steps to delete such information and terminate the child’s information.

8.    Security and Data Integrity

Faraday takes steps to help ensure that the data we possess is housed and transmitted securely. This may include various types of physical and electronic security, including firewall protections, encryption, hashing or truncation of data, and access controls to personal information. While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we employ efforts that are designed to ensure that this does not occur. By using our Services, you acknowledge and accept that we cannot guarantee the security of your information and that use of our Services is at your own risk.

You are responsible for keeping your login information confidential. We ask you not to share your login credentials with anyone.

9.    Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy at any time. We will make the revised Privacy Policy accessible through the Services, so you should review the Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” at the beginning of this Privacy Policy. If we make a material change to this Privacy Policy, we will provide you with notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

10.    Your Rights and Marketing Choices

a.   Legal Rights and Opt-Out Choices

You may have certain legal rights in relation to your personal information that we maintain.

If we market to you by email, in our corporate capacity – such as if you are a Client or prospective client and we send information about our Services – you may “unsubscribe” from our marketing emails through a link placed in your emails. You may also request to be removed from future email messages by emailing us at privacy@faraday.io or by writing to us at the address given at the end of this policy. Removing your name from the email list may take a reasonable amount of time. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

If you wish to opt out of online targeted ads (sometimes referred to as “interest-based” or “personalized” advertising), you can also visit the opt-out portals operated the industry groups the National Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA), and you can learn more about how those opt-outs work on those linked web pages. Please note that these online opt-outs are cookie-based (unlike Faraday’s direct opt-out). Thus, if you browse the web from multiple browsers or devices, you will need to opt out from each browser and/or device, and for the same reason, if you change browsers or clear your browser cookie cache, you will need to perform this opt-out function again. Opting-out in this way will not prevent you from seeing all types of online ads; it generally will prevent targeted ads customized to what advertisers think may be most likely to be relevant and of interest to you.

b.   Privacy Rights for California Residents

If you are a California resident, California law requires us to provide you with some additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).  Please do not rely on the below information and disclosures in this Section 10(b) or otherwise directed to California residents if you are not a resident of California.

i. Your California Privacy Rights

CCPA Rights Disclosure.  If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

Please note that certain information may be exempt from such requests under California law.  For example, we need certain information in order to provide the Services.  We also will take reasonable steps to verify your identity before responding to a request. In doing so, we may ask you for verification information so that we can match at least two verification points with information we maintain in our files about you. If we are unable to verify you through this method, we shall have the right, but not the obligation, to request additional information from you. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney.  We may also follow up with you to verify your identity before processing the authorized agent’s request. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at faraday.io/ccpa, ccparequests@faraday.io, or by toll-free number at 1-888-252-3169.  

ii. Notice of Right to Opt Out of Sale of Personal Information

California residents may opt out of the “sale” of their personal information. As a California resident, you are permitted to designate an authorized agent to submit an opt out on your behalf. We may have sold the following categories of information about you: commercial or transaction information, demographic and statistical information, geolocation information, inferences, personal identifiers.  

If you would like to opt out of our use of your information for such purposes that are considered a “sale” under California law, you may do so as outlined on the following page: faraday.io/privacyoptions. You can also submit a sale opt-out request by emailing us at ccpadonotsell@faraday.io.  Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.

iii. California “Shine the Light” Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. See the “Contact Us” section below for where to send such requests.

California law also gives residents the right to: (1) request that we provide you with information about the financial incentives that we offer to you and (2) not be discriminated against (as provided for in applicable law) for exercising certain of your rights.

c.   Privacy Rights for Nevada Residents

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.

We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by emailing nevadarequests@faraday.io.  Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

d.   Privacy Rights and Choices With Regard to Information Provided by a Client

As further explained in Section 5, with regard to personal information provided to us by one of our Clients, we act as a service provider, and consumers should direct requests to exercise applicable rights to the Client on whose behalf we handle the data. If we receive a request from a consumer directly in relation to information provided by a Client, we will refer that

11.    International Visitors

Our Sites and Services are hosted in the United States and generally are intended for United States visitors. If you visit from the European Union or other regions with laws governing data collection and use that may differ from United States law, please be aware that you are transferring personal information to the United States. The United States does not have the same data protection laws as the European Union and other jurisdictions. By providing personal information to us, You consent to the transfer of it to the United States and the use of it in accordance with this Privacy Policy and applicable law.


12.     Contact Us

Please contact us with any questions or comments about this Privacy Policy, your personal information, our use and disclosure practices, or your rights by email at privacy@faraday.io.

Faraday, Inc.

431 Pine St

Burlington, VT 05401