Last updated: 01/01/2020

Privacy Policy

I. Introduction

TargetSmart Communications, LLC (“TargetSmart” or “we”) respects the privacy of every individual about whom we provide information. We offer both information management services and information products to our clients to help with targeted communications and opinion research. When TargetSmart provides information products to our clients, we adhere to the information practices described in this Privacy Policy.

II. Information That We Collect and Hold About You

TargetSmart’s Information Products help our clients, a wide variety of general public facing organizations, membership organizations, researchers, data compilers, and suppliers in the management, use, and optimization of customer data and assist them in identifying and reaching relevant audiences.

TargetSmart brings to market information products and services through Analytics Data Installs, ListBuilder, Digital Voter File, SmartVAN, Polling services, Communications services, Data Enhancement services and Strategic Consulting, each containing only the information needed for their intended use. Each of TargetSmart’s information products is designed for specific use by our clients with a legitimate need for the product.

To fulfill our client’s needs, we collect and hold the following categories of information:

Information We Collect And Hold From Public Sources

  • Government licensing, courthouses, and campaign compliance disclosures; Telephone directories,
  • Website directories and listings, census data, election administration officials, court or county clerk records, property or legal records, and other public records;
  • Voter information, such as election districts, political party registrations, voter registration, and election participation by voters;

Data We Collect And Hold From Other Service Providers

  • Demographic information about your consumer and political preferences;
  • Certain personal identifying information, such as names, addresses, ages, dates of birth, emails, telephone numbers, lifestyle and social platform profiles, interests, physical descriptions, and employment information;
  • Geolocation data, such as physical location in terms of latitude and longitude;
  • Inferences drawn from that information.

Information We Collect And Hold From You

  • Survey Research From time to time, TargetSmart may engage third parties to reach out to you directly through polling or survey services on our behalf. When you interact with these polling services, we collect information that you provide to us after obtaining your consent, including, but not limited to, Personal Information like your name, phone number, and email address, and your opinions on certain topics.

Data We Collect And Hold From Our Clients

In certain cases, TargetSmart also receives and holds information from our clients about their members or marketing lists necessary for processing that data on our clients’ behalf. In certain cases, TargetSmart may also provide outsourced technical & data infrastructure services to our clients. Client list data may be stored in the infrastructure services we provide.

IV. Use Of Your Information

The information that TargetSmart makes available to our clients is used to enhance customer and constituent files and provide lists for activities such as prospecting, voting, advocacy, marketing and fundraising purposes. Specifically, your information is used for the following business purposes:

  • Targeting, delivering, and optimizing direct outreach campaigns through the mail, phone, in-person and email; and media campaigns through digital, broadcast, print, earned and out-of-home channels;
  • Assisting clients to measure the effectiveness of ad campaigns;
  • Creating data and identity linkages to match common identities across different data sources;
  • Creating inference models about people, households, postal addresses, or unique online identifiers;
  • Categorization of certain audiences based upon common interests or preferences;
  • Cross channel marketing;
  • Population research and analytics.

V. Sharing And Disclosure Of Your Information

TargetSmart may disclose your information for use by qualified companies, non-profit organizations and political organizations in their marketing, fundraising, customer service, and constituent service and outreach programs.

Our client and supplier contracts require that any data sent to us has been legally obtained for the uses to which it will be put. Additionally, we require that our clients’ use of any data received from us will be in compliance with applicable data protection laws and industry best practices. We also agree to comply with restrictions that information providers place on the data we receive. Our clients’ information is the sole property of our clients, and the rights we have with respect to our clients’ information are the rights that they grant to us. We use and share personal information that our clients share with us in the manner requested or authorized by our clients and consistent with the restrictions placed on that information by our clients.

We may share personal data we obtain with the following third parties:

  • Agents and Service Providers who help with our business activities or provide services requested by our clients. These companies are authorized to use your personal data only as necessary to provide these services to us. These services may include data storage services and customer service and business operations.
  • Business and Data Partners and Clients, to help provide more tailored advertising and for analytical purposes.
  • Affiliates, Partners, and Subsidiaries: to provide necessary services.

In certain situations, TargetSmart 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 your personal data as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, respond to a government request or where there have been a change in ownership, merger or acquisition.

VI. Security, Retention and Data Integrity

TargetSmart follows generally accepted standards and maintains physical, technical and administrative safeguards to protect the personal data. TargetSmart continually monitors access to its systems to detect unauthorized attempts to gain access to information. We may retain your information for as long as our client accounts are active or as needed to provide services, comply with our legal obligations, resolve disputes and enforce our agreements.

VII. Access

TargetSmart has no direct relationship with the individuals whose personal data it processes. However, an individual who seeks access, or seeks to correct, amend or delete inaccurate data is welcome to contact us with questions regarding their data.

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

VIII. Children Under The Age Of Eighteen

We do not collect personal information from any person we know to be under the age of 16, and we will delete any personal information collected that we later know to be from a person under the age of 16. Some election officials allow people under the age of 18 to register to vote. We do retain these official voter records of people under 18. Our products and services are not targeted to people under 18 years of age. If you believe a child under the age of 16 has disclosed personal information to us, please contact us at privacy@targetsmart.com and specify the customer and information you believe to be from the child under 16.

Privacy Policy Changes

From time to time TargetSmart may update and revise our privacy policy based on changes in our business environment and changes to applicable law. We urge consumers and clients to periodically visit our webpage at https://privacy.targetsmart.com/privacy-policy to understand any changes that may have occurred. Our privacy policy contains an “effective date” reflecting when the last changes occurred. If there is a material change to our Policy, we will provide you with notice on our website so that you have the ability to review and understand those changes.

IX. Additional Privacy Information For Nevada Users

Notice to Nevada Residents: Nevada Senate Bill 220 provides consumers (Nevada residents) with specific rights regarding their Personal Information. This section describes your Nevada privacy rights and explains how to exercise those rights.

Right To Opt Out

You have the right to direct us to not sell your Personal Information at any time (the “Right to Opt-Out”).

To exercise the Right to Opt-Out, you (or your authorized representative) may submit a request to us using the web form hosted on privacy.targetsmart.com or by calling 888-678-6880.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within sixty days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

X. Additional Privacy Information For California Users

Notice To California Residents: The California Consumer Privacy Act of 2018 (“CCPA”) provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Please make sure you also consult the rest of our general privacy policy above for complete information.

Access to Specific Information and Data Disclosure Rights

You have the right to request that TargetSmart disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Disclosure, and Deletion Rights), we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
  • sales, identifying the Personal Information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that TargetSmart delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request for deletion (see Exercising Access, Data Disclosure, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Disclosure, and Deletion Rights

To exercise the access, data disclosure and deletion rights described above, please submit a verifiable consumer request to of the below methods:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

  • You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
  • Making a verifiable consumer request does not require you to create an account with us.
  • We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

You have the right to direct us to not sell your Personal Information at any time (the “Right to Opt-Out”). Users who opt-in to Personal Information sales may opt-out of future sales at any time.

To exercise the Right to Opt-Out, you (or your authorized representative) may submit a request to us by:

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by contacting TargetSmart at the email address or phone number provided in this notice.

You do not need to create an account with us to exercise your Right to Opt-Out. We will only use Personal Information provided in an opt-out request to review and comply with the request.

Non Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

As referenced in this policy, we may from time to time elect to share certain information about you collected by us on the Service with third parties for those third parties’ direct marketing purposes. California Civil Code Section 1798.83 permits California residents who have supplied personal information, as defined in the statute, to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. To make such a request, please email us at at privacy@targetsmart.com or calling 888-678-6880.