Data Privacy Framework Notice

Data Axle Inc. and its various affiliates and subsidiaries in the United States (collectively “Data Axle,” “we,” or “us”) comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), and the UK Extension to the EU-U.S. DPF (together, “Data Privacy Framework” or “DPF”) regarding the collection, use, and retention of personal information transferred from the European Union (“EU”), the United Kingdom (“UK”), and Switzerland to the United States (“U.S”) in reliance on the DPF. Data Axle is committed to complying with the Data Privacy Framework as set forth by the U.S. Department of Commerce.

Data Axle 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 EU in reliance on the EU-U.S. DPF and from the UK (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Data Axle has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. DPF Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. Data Privacy Framework. If there is any conflict between the terms in this Notice and the DPF Principles, the DPF Principles shall govern.

To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Data Axle’s U.S. affiliates and subsidiaries that commit to comply with the DPF include Consumer Base LLC dba Exact Data; Data Axle International Holdings, Inc.; DonorBase, Inc.; Lake Group Media, Inc.; infoUSA Inc.; infoUSA Marketing, Inc.; GoTime Corporation; Walter Karl, Inc.; Direct Media, LLC; Yesmail, Inc.; and Yesmail International Holdings, Inc.; Data Axle Solutions Private Limited; B.J. Hunter Information, Inc.; and Alerts.com LLC.

Data Axle’s commitments under the DPF are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

This Notice supplements our Privacy Policy located at http://www.data-axle.com/privacy-policy. For this Notice, “Personal Data” means data about an identified or identifiable individual that are within the scope of Directive 95/46/EC, received by an organization in the U.S. from the EU, the UK, or Switzerland, and recorded in any form. Unless specifically defined in this Notice, any capitalized terms in this Notice have the same meaning given to them in our Privacy Policy.

DPF Principles

Data Axle ensures our collection, use, and retention of Personal Data comply with the DPF Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement, and liability.

I. Notice

If you are located in the EU, the UK, or Switzerland, we will inform you about the purposes for which we collect and use your Personal Data, the types of third parties to which we disclose your Personal Data, the choices and means, if any, we offer you for limiting the use and disclosure of your Personal Data, and how to contact us. Notice will be provided in clear and conspicuous language when you are first asked to provide Personal Data to us, or as soon as practicable thereafter, and in any event before we use or disclose your Personal Data for a purpose other than that for which it was originally collected. Our Privacy Policy and Job Applicant Privacy Statement (https://privacy.adp.com/privacy.html?locale=en) describe the categories of Personal Data we may receive or collect as well as the purposes for using such Personal Data.

II. Choice

Data Axle offers you the opportunity to opt out of whether your Personal Data is to be disclosed to a non-agent third party or to be used for a purpose that is materially different than the purpose for which it was originally collected or subsequently authorized by you. Should we collect any sensitive personal information, we will give you the opportunity to affirmatively and explicitly consent to the disclosure of such information to a non-agent third party or for a purpose that is materially different than the purpose for which it was originally collected or subsequently authorized by you. We will provide you with reasonable mechanisms to exercise your choices.

III. Accountability for Onward Transfer

We may share Personal Data with third parties to provide services to you. We require written agreements with third parties to ensure Personal Data is protected with the same level of protection the DPF Principles require. Those written agreements ensure Personal Data is only processed for limited and specified purposes consistent with the consent provided by you. Third parties must inform us if they can no longer meet the obligations set forth in those written agreements. If we have knowledge that a third party uses or discloses Personal Data in a manner contrary to this Notice, we will take reasonable steps to remediate or cease the use or disclosure of such Personal Data. Data Axle remains responsible and liable under the EU-U.S. DPF Principles, the UK extension to the EU-U.S. DPF, and/or the Swiss-U.S. DPF Principles if third-party agents that it engages to process the Personal Data on its behalf do so in a manner inconsistent with the DPF Principles unless Data Axle proves that it is not responsible for the event giving rise to the damage.

IV. Security

Data Axle maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction in accordance with the DPF.

V. Data Integrity and Purpose Limitation

We use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. We take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete, and current.

VI. Access

You have the right to access the Personal Data we hold about you and to request that we correct, amend, or delete your Personal Data if it is inaccurate or has been processed in violation of the DPF. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of Personal Data, you can submit written requests to the contact information provided below. We may request specific information from you to confirm your identity.

VII. Recourse, Enforcement, and Liability

We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint. In compliance with the Data Privacy Framework, Data Axle commits to refer unresolved complaints concerning our handling of Personal Data received in reliance on the Data Privacy Framework to the Association of National Advertisers (ANA) DPF Dispute Resolution, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your complaint from us or you are unsatisfied with the resolution of your complaint, you can contact and submit a complaint to ANA DPF Dispute Resolution by visiting https://www.ana.net/content/show/id/accountability-dpf-consumers. These services are provided at no cost to you. If neither we nor ANA DPF Dispute Resolution resolve your complaint, you may have the possibility to engage binding arbitration through the Data Privacy Framework Panel. For more information on binding arbitration, please visit https://www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf.

Data Axle will cooperate and comply with the EU data protection authorities (“DPAs”), the UK Information Commissioner’s Office (“ICO”), and the Swiss Federal Data Protection and Information Commissioner (“FDPIC”) with respect to human resources data transferred from the EU, the UK, and Switzerland in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint regarding human resources data or you are unsatisfied with the resolution involving human resources data, you should contact the EU DPAs, the UK ICO, or the FDPIC, as applicable, for more information.

Third Party Disclosures

Data Axle may share Personal Data as follows:

a. Agents and Service Providers: We may share Personal Data with agents, business partners and service providers who work on our behalf, or to help us provide services requested by our customers. We may do so, for instance, to help send or target advertising on behalf of our customers (or ourselves), for analytical purposes, to measure campaigns, or inform future campaigns. We may do so to facilitate the sending of display media, email, or other requested services.
b. Business Partners and Customers: We may share Personal Data with and to business and data partners (such as business partners who provide to marketers their own applications or data services) or with customers, to help provide more tailored advertising and for analytical purposes.
c. Corporate transfers: If Data Axle or its significant assets are purchased by another entity, Personal Data will likely be transferred to that entity, including for due diligence prior to any such potential purchase.
d. Affiliates, Parents and Subsidiaries: We may share some or all of the Personal Data in our possession with affiliated or subsidiary companies to help us provide services requested by our customers. Our affiliates and subsidiaries include (but are not limited to Consumer Base LLC dba Exact Data; Data Axle International Holdings, Inc.; DonorBase, Inc.; Lake Group Media, Inc.; infoUSA Inc.; infoUSA Marketing, Inc.; GoTime Corporation; Infogroup Canada Corp.; Walter Karl, Inc.; Yesmail Interactive London Limited (UK); Yesmail, Inc.; and Yesmail International Holdings, Inc.; Data Axle Solutions Private Limited; B.J. Hunter Information, Inc.; and Alerts.com LLC.
e. As Required by Law or to Protect Any Party: Data Axle may disclose Personal Data if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or safety of Data Axle or any other party.

Required Disclosure

Under certain circumstances, we may be required to disclose your Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Contact Us

In compliance with the Data Privacy Framework, Data Axle commits to resolve DPF Principles-related complaints about our collection and use of your Personal Data. EU, UK and Swiss individuals with inquiries or complaints regarding our handling of Personal Data received in reliance on the DPF should first contact Data Axle at:

Data Axle Inc.
Chief Privacy Officer
13155 Noel Rd #1750
Dallas, TX 75240
[email protected]

You may also contact our Data Protection Officer in the United Kingdom at:

Fieldfisher, Riverbank House
Hazel Grant
2 Swan Lane
London EC4R 3TT

Changes to This Policy

We reserve the right to amend this Notice from time to time consistent with the DPF’s requirements. This Notice was last updated on November 25, 2024.