Privacy Policy

TDTM is a United States data and advertising technology company. We license consumer information from data partners, combine and organize it, and make it available to our business customers so they can reach relevant audiences and contact people who have expressed interest in products like theirs.

This policy covers talkdatatome.online, our platform, our APIs, and the consumer information we hold in our databases. It does not cover our customers’ own websites, products or privacy practices. Once a customer receives information from us, their own privacy policy governs what they do with it, and they are contractually required to have one.

Almost every privacy question about our business turns on which of these two groups you belong to, so it is worth separating them up front.

Consumers. Adults in the United States whose information appears in the databases we license and maintain. Most people in this group have never visited our website and have no account with us. Sections 3 through 14 are mostly about you.

Customers and visitors. Businesses that buy from us, the people at those businesses who hold accounts, and anyone who visits talkdatatome.online. Sections 3, 5, 14 and 15 are mostly about you.

About consumers, we may hold:

• Identifiers such as name, postal address, email address, telephone number, and IP address.
• Hashed and pseudonymous identifiers derived from the above, including SHA-256 and MD5 digests of email addresses, and advertising identifiers.
• Demographic and household characteristics such as age range, homeowner status, household composition, and estimated income band.
• Commercial and interest information, including indications that a person has been researching or shopping for a category of product or service, and the recency of that activity.
• Where a person has submitted an inquiry or placed a call to one of our partners, the details of that inquiry and the consent record associated with it.

About customers and visitors, we collect:

• Account information: name, business name, email address, and login credentials.
• Billing information. Payments are processed by Stripe, and we do not store full card numbers.
• Usage information: pages viewed, features used, queries run, and support correspondence.
• Device and connection information such as IP address, browser type, and approximate location derived from IP.

We generally do not collect consumer information directly from the consumer. We obtain it from third-party sources, including licensed data providers and compilers, publishers and lead generators who collect information directly from consumers under their own notices and consent, publicly available records, and our business customers who provide their own customer lists for matching.

We require our sources to have the rights necessary to provide the information to us and to have given consumers the notice their own collection required.

• To build, maintain and improve our databases and identity graph, including matching records that refer to the same person or household.
• To create audience segments and marketing lists for our business customers.
• To deliver information to our customers and to the advertising platforms they direct us to.
• To append or verify attributes on a customer’s own records at their request.
• To measure whether advertising worked, in aggregate.
• To operate, secure and support the platform, to bill customers, and to detect and prevent fraud and misuse.
• To comply with law and to enforce our agreements.

We do not use consumer information to make decisions about credit, insurance eligibility, employment, housing, or any other purpose governed by the Fair Credit Reporting Act. Our services are not consumer reports and must not be used as one. That restriction is in our customer contracts.

• Our business customers, who license audiences and records from us for their own marketing.
• Advertising platforms, at a customer’s direction, so an audience can be targeted in that customer’s own advertising account. What we send to advertising platforms is hashed identifiers, not names, postal addresses or telephone numbers. See section 8.
• Service providers who process information on our behalf under contract, such as cloud hosting, data warehousing, email delivery and payment processing.
• Data partners, where we exchange or license information under agreements that restrict its use.
• Legal and corporate recipients, when required by law or legal process, and in connection with a merger, financing or sale of assets.

We want to be direct about this, because it is the heart of what we do. Under the California Consumer Privacy Act and similar state laws, we sell personal information and we share it for cross-context behavioral advertising. Licensing audience data to a customer for their marketing, and delivering an audience into an advertising platform on their behalf, both fall within those definitions.

The categories we sell or share are the consumer categories listed in section 3: identifiers, hashed identifiers, demographic and household characteristics, and commercial and interest information. We sell or share them with our business customers, advertising platforms, and data partners, for marketing and advertising purposes.

You have the right to tell us to stop. See section 12.

We do not sell or share the personal information of consumers we know to be under 16.

When we deliver an audience into an advertising platform, we send a one-way SHA-256 hash of the person’s email address and nothing else. The raw email address is not transmitted. The platform compares those hashes against its own logged-in users and can only act on people it already knows.

Our business customers who use audience delivery do not receive names, postal addresses or telephone numbers through that product. They see counts and match statistics. Other products we offer do deliver contact information to customers, and where they do, that is a sale as described in section 7.

Hashing is a safeguard, not anonymization. We treat hashed identifiers as personal information and this policy applies to them.

We do not seek to collect sensitive personal information as that term is defined by California law, and we do not use or disclose it for purposes that would require us to offer a right to limit its use. We do not knowingly collect information about health conditions, precise geolocation, racial or ethnic origin, religious beliefs, union membership, genetic or biometric data, or the contents of private communications.

Some categories our customers advertise in, such as insurance, may be sensitive in ordinary language. An indication that someone has been researching a type of insurance is commercial interest information, not a health record, and we do not infer health conditions from it.

Depending on where you live, you may have some or all of the following rights. California residents have all of them under the CCPA as amended by the CPRA, and residents of other states with comprehensive privacy laws, including Virginia, Colorado, Connecticut, Utah, Texas and Oregon, have closely similar rights.

• Know and access. Ask what personal information we hold about you, where we got it, why we have it, and who we have disclosed it to, and receive a copy.
• Delete. Ask us to delete personal information we hold about you.
• Correct. Ask us to fix personal information about you that is inaccurate.
• Opt out of sale and sharing. Tell us to stop selling or sharing your personal information. See section 12.
• Non-discrimination. We will not treat you differently for exercising any of these rights.
• Appeal. If we decline a request, you may ask us to reconsider, and we will respond with our reasoning.

An authorized agent may make a request on your behalf. We will ask for proof that you authorized them.

Email support@talkdatatome.online with the subject line “Privacy request” and tell us which right you are exercising.

Because most people in our databases have no account with us, we need enough information to find you and to be confident the request is really yours. Please include the name, postal address, email addresses and telephone numbers you believe we may hold. We use what you send us only to process the request.

We confirm receipt within 10 business days and respond within 45 calendar days. If we need longer, we will tell you why and may extend by a further 45 days, as the law allows.

You can tell us to stop selling and sharing your personal information, and you do not need to give a reason.

Email support@talkdatatome.online with the subject line “Do Not Sell or Share My Personal Information”. Include the name, postal address, email addresses and telephone numbers you want suppressed, so we can match you across our records.

We process opt-outs within 15 business days. Once processed, we add your identifiers to a permanent suppression list so that you stay opted out as our databases are refreshed, and we notify the parties we sold or shared your information to in the 90 days before your request.

Keeping you suppressed is the one thing we need to retain your identifiers for. We hold them for that purpose only, and we do not use a suppression record for marketing.

We do not keep personal information longer than it remains useful for the purposes in section 5. Rather than a single fixed period, we apply these criteria:

• Interest and shopping signals are short-lived by nature and are used and refreshed on a rolling basis measured in days and weeks.
• Identity and household records are kept while they remain accurate and commercially useful, and are refreshed or removed as our sources update them.
• Customer account and billing records are kept for the life of the account and afterwards for as long as we need them for tax, accounting and legal purposes.
• Suppression and opt-out records are kept indefinitely, because deleting them would undo the opt-out.

We protect personal information with access controls, encryption in transit and at rest, credential separation between environments, and internal policies restricting who can access production data. Access to our platform requires authentication, and customer data is separated by account.

No system is perfectly secure, and we do not claim otherwise. If a breach affects your personal information, we will notify you as required by law.

talkdatatome.online uses cookies and similar technologies that are necessary to sign you in and keep the site working, and analytics that help us understand how the site is used, including session replay of activity on our own site.

We also provide a pixel that our customers install on their own websites to recognize visitors. Where that pixel runs, it runs on our customer’s site under our customer’s notice and consent obligations, not ours, and the customer is responsible for disclosing it in their own privacy policy. Our contracts require that.

Our services are for businesses and are not directed to children. We do not knowingly collect personal information from anyone under 16. If you believe we hold information about a child, contact us and we will delete it.

We may update this policy. When we do, we change the effective date at the top. If a change materially affects how we handle personal information, we will make that clear rather than relying on a silent edit.

Top of Funnel, LLC d/b/a Talk Data to Me
support@talkdatatome.online

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