California Privacy Notice

AD•SCALE provides B2B services to legal entities and professionals. Many of our interactions are in a business-to-business context. This notice applies to the personal information of California residents that we process, including website visitors, prospective customers, individual representatives of business customers, job applicants and authorized agents acting on behalf of a consumer.

In the past twelve (12) months, we may have collected the following categories of personal information defined under the CCPA:

• Identifiers such as name, business email, business phone, postal address, IP address, account identifiers and online identifiers;
• Customer record information (Cal. Civ. Code § 1798.80(e)) such as billing details and signatory information;
• Commercial information such as records of services purchased, considered or used, and transaction history;
• Internet or other electronic network activity information such as browsing history on our site, interaction with ads or content, and device data;
• Geolocation data approximated from IP address;
• Professional or employment-related information such as company name, role, industry and country of operation;
• Audio, electronic, visual or similar information such as recordings of consented support calls;
• Inferences drawn from the above to create a profile reflecting business preferences and likely interest in our services.

We do not knowingly collect personal information from minors under sixteen (16).

• directly from you, when you contact us, request a quote, sign up, onboard or interact with our services;
• automatically, through cookies, pixels, SDKs and server logs;
• from your devices and browsers;
• from third parties such as advertising platforms, analytics providers, CRM enrichment vendors, identity verification vendors, payment providers and publicly available sources.

• to provide, operate, deliver and improve our services;
• to process transactions, billing and related communications;
• to verify identity, conduct KYC, prevent fraud and protect the security of our systems;
• to respond to inquiries and provide support;
• to send transactional and, where permitted, marketing communications;
• to measure performance, attribution and effectiveness of advertising;
• to comply with law, legal process, audits and enforce our agreements;
• for any other purpose disclosed at the point of collection or with your consent.

In the past 12 months we may have disclosed the categories listed in Section 2 to the following categories of recipients for a business purpose: payment processors, hosting and cloud infrastructure providers, advertising and analytics providers, CRM and email providers, identity verification vendors, professional advisors, and government or law enforcement when legally required.

The CCPA defines “sale” broadly to include certain disclosures for monetary or other valuable consideration, and “sharing” to include disclosures for cross-context behavioral advertising. Like many websites, AD•SCALE uses cookies, pixels and tags from advertising and analytics providers. Some of these activities may qualify as a “sale” or “sharing” under the CCPA, regardless of whether money changes hands.

The categories that may be involved in such sharing are: identifiers, internet activity information, geolocation data and inferences, disclosed to [ADVERTISING PROVIDERS] and [ANALYTICS PROVIDERS].

You may opt out at any time using our Do Not Sell or Share My Personal Information page or by enabling a Global Privacy Control (GPC) signal in a supported browser.

We do not knowingly “sell” or “share” the personal information of California residents under sixteen (16).

We do not knowingly collect or use sensitive personal information for the purpose of inferring characteristics about a consumer. Government identifiers, financial account credentials, precise geolocation, and similar elements that we receive in onboarding are used solely for the limited purposes permitted by the CCPA, including providing the requested services, security, fraud prevention and compliance.

We retain personal information for as long as needed to fulfill the purposes described in our Privacy Policy and as required by law, tax, audit and accounting obligations. Retention periods vary by category and context; see [DATA RETENTION PERIOD] for details.

Subject to verification and applicable exceptions, California residents may:

• request to know the categories and specific pieces of personal information we have collected, sources, business or commercial purposes, and categories of recipients;
• request deletion of personal information we have collected;
• request correction of inaccurate personal information;
• opt out of the sale or sharing of personal information;
• limit the use and disclosure of sensitive personal information (where applicable);
• be free from discrimination for exercising these rights;
• appeal a denied request.

You may submit a verifiable consumer request:

• by using our Do Not Sell or Share request form;
• by emailing [PRIVACY EMAIL];
• by writing to [COMPANY ADDRESS], [CITY, STATE, ZIP CODE].

To protect your information, we will take reasonable steps to verify your identity before fulfilling a request. We may ask for additional information sufficient to match the identifying information you provide to information we maintain. We will not use the information provided for verification for any other purpose.

You may use an authorized agent to submit a request on your behalf. The agent must provide signed written permission demonstrating authority to act on your behalf, and we may require you to verify your identity directly with us or confirm the authorization.

We will not deny services, charge different prices, or provide a different level or quality of services because you exercised any rights under the CCPA, except as permitted by law.

We do not direct our services to minors under sixteen (16) and do not knowingly collect personal information from them. If you believe a minor has provided personal information to us, contact [PRIVACY EMAIL] and we will take appropriate action.

California Civil Code Section 1798.83 permits California residents who have established a business relationship with us to request information about disclosures of personal information to third parties for those third parties’ direct marketing purposes. We do not currently disclose personal information to third parties for their direct marketing purposes.

Where required by the CCPA regulations based on the number of consumers about whom we process personal information, we will publish annual metrics regarding consumer requests received and processed. Current metrics: [METRICS PENDING — TO BE PUBLISHED IF THRESHOLD APPLIES].

We may update this notice from time to time. The “Last updated” date at the top reflects the most recent revision.

For questions about this notice or to exercise your rights, contact [PRIVACY EMAIL] or write to [COMPANY ADDRESS], [CITY, STATE, ZIP CODE].