LAST UPDATED: 01-29-2021

Opt-In Strategies is a company dedicated to assisting our clients, which include political campaigns and nonprofit entities, optimize their communications with voters and potential donors. To do so, we collect and sell or share information that is reasonably capable of being associated with a consumer, device, or household. This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of Opt-In Strategies and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). The purpose of this policy is to provide you a comprehensive description of our practices regarding the collection, use, disclosure, and sale of personal information, and your rights as a consumers regarding your personal information. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information about consumers within the last twelve (12) months:

  1. Identifiers: A real name, city, state, zip code, email address.
  2. Personal information categories listed in the California Customer Records statute: A name and address. Some personal information included in this category may overlap with other categories.
  3. Internet or other similar network activity: information on a consumer’s interaction with an email advertisement, including click and open rates.
  4. Inferences drawn from other personal information: Information derived from other Personal Information about you, which may include your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, abilities, and aptitudes.

We have NOT collected the following categories of personal information about consumers within the last twelve (12) months:

  1. Protected classification characteristics under California or federal law.
  2. Commercial information.
  3. Biometric information.
  4. Geolocation data.
  5. Sensory data.
  6. Professional or employment-related information.
  7. Non-public education information (per the Family Educational Rights and Privacy Act.

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
  • From third parties with whom we contract to obtain such data, including our clients and other data brokers.

Opt-In Strategies’ Use of Personal Information

We use or disclose the personal information we collect for one or more of the following business purposes:

  • By licensing data lists comprised of personal information to permit our clients and customers to provide you with emails or communications containing information such as alerts, event registrations that may be of interest to you.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you by third parties when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
  • To carry out our obligations and enforce our rights arising from any contracts we have with our customers or clients.

Disclosing Personal Information

As explained above, Opt-In Strategies is a company that collects and sells or shares information that is reasonably capable of being associated with a consumer, device, or household. Accordingly, we may disclose your personal information to third parties for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

  1. Identifiers: A real name, city, state, zip code, email address.
  2. Personal information categories listed in the California Customer Records statute: A name and address. Some personal information included in this category may overlap with other categories.
  3. Internet or other similar network activity: information on a consumer’s interaction with an email advertisement, including click and open rates.
  4. Inferences drawn from other personal information: Information derived from other Personal Information about you, which may include your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, abilities, and aptitudes.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates
  • Service providers

Sale of Personal Information

As explained above, Opt-In Strategies is dedicated to assisting our clients, which include political campaigns and nonprofit entities, optimize their communications with voters and potential donors. To do so, we collect and sell or share information that is reasonably capable of being associated with a consumer, device, or household, which our customers and clients may then use to provide you information. In the preceding 12 months, we have sold the following categories of personal information to our customers and clients:

  1. Identifiers: A real name, city, state, zip code, email address.
  2. Personal information categories listed in the California Customer Records statute: A name and address. Some personal information included in this category may overlap with other categories.
  3. Internet or other similar network activity: information on a consumer’s interaction with an email advertisement, including click and open rates.
  4. Inferences drawn from other personal information: Information derived from other Personal Information about you, which may include your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, abilities, and aptitudes.

We have sold these categories of personal information to the following categories of third parties:

  • Our clients and customers, which include political campaigns and non-profit entities.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. To our knowledge, none of the data we have collected, disclosed, sold or will sell includes personal information of consumers under 16 years of age.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights, including the (1) the Right to Know; (2) Right to Request Deletion; (3) Right to Opt-Out of the Sale of Personal Information; and (4) Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights, and how you can exercise those rights.

Access to Specific Information and Data Portability Rights.

You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, 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 sold or shared that personal information
  • The specific pieces of personal information we collected about you (also called a data portability request)
  • 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 also have the right to request that we 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, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Please note that we may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. 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
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
  3. Debug products to identify and repair errors that impair existing intended functionality
  4. Exercise free speech ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us
  8. Comply with a legal obligation
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it

Right to Opt-Out of the Sale of Personal Information.

We sell consumer data to our customers for their strategic communications purposes. As a consumer, you have the right to opt-out of the sale of your personal information. We respect California residents’ right to opt-out of any database we maintain. You may opt-out of our sale or sharing of your personal information by submitting a verifiable consumer request as provided below using either our interactive form online, or by one of the other methods such as email or telephone. You may also visit our website at www.optinstrategies.org and click on the link titled “Do Not Sell My Personal Information,” or click here: https://optinstrategies.org/ccpa.

Right to 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.

Exercising CCPA Rights

To exercise the access, data portability, opt-out, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at: (916) 542-0759
  • Web Intake Form Access: optinstrategies.org/ccpa

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 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. We will deliver our written response by mail or electronically. 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.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information.

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (916) 542-0759

Website: optinstrategies.org

Postal Address: 4641 Hillview Way, Sacramento, CA 95822

Attn: Opt-In Strategies C/O CCPA