Privacy Policy

1. Information we collect through our Services

We collect the following information from consumers:

• Pseudonymized social media identifiers.
• Public engagements from consumer & media brands on social media platforms.
• Information from our advertising technology partners, which may include cookie or mobile advertising IDs, pseudonymized identifiers such as hashed emails, demographic information, and other custom attributes.

We do not collect sensitive personal information. While mobile advertising IDs are often associated with precise geolocation, we do not maintain precise geolocation or other sensitive personal information. 

2. How we use collected information in our Services

We use collected information to provide our social and other marketing services, including: 

• Create lookalike or ‘act alike’ audiences for display advertising.
• Provide market research insights.
• Enhance customer or prospect databases with new attributes. 
• Assist with media planning.

3. How we  disclose collected information through our Services

We may disclose information in the following ways:

• With our vendors who use your personal information exclusively to support Affinity Answers.
• With our business partners.
• Through the use of proprietary links, pixel tags, and cookies served by marketing partners, social media, or interest-based advertising services that may use collected information from our Services to assist Affinity Answers but also to improve their products and services. Please see your privacy rights and how to exercise them below to opt-out of these potential uses.
• For third-party marketing. We share information with third-party marketing partners, such as Oracle. 
• With any other divisions, subsidiaries, or corporate affiliates of Affinity Answers.
• If we are compelled by law to do so, such as through a subpoena or court order.
• If it is required as part of a business transaction where Affinity Answers or any subsidiary is acquired.

In addition, we may share aggregated information that does not identify any personal information, such as the number of website or app visits, referring partner metrics, or number of account registrations.

4. Your privacy rights and how to exercise them

You have the right to:

• Access. We can provide you with the personal information that we maintain about you.
• Modification. We will correct any mistakes with your personal information.
• Deletion. You can request that we delete any personal information about you, unless we are required by contract or law to retain it.
• Opt-Out. You may request that we cease using your information for marketing or other purposes that are not required to provide the services you’ve requested.You may also choose to opt-out through the following mechanisms:
  • If you have received a commercial email from us, you will have the option to opt-out or unsubscribe provided in the email itself.
  • To opt out of targeted advertising by: 
    • Visiting http://optout.aboutads.info or https://optout.networkadvertising.org/optout/email?c=1 to exercise an industry-wide opt out; and
    • Through your browser settings.

To exercise your rights, please visit our ‘Your Privacy Choices’ webform, or email us at dataprivacy@affinityanswers.com.

Mobile Opt Out: 

In addition to the above, in providing our services, we may collect or receive identifiers for mobile devices. 

You can adjust your advertising preferences multiple ways in iOS: 

• Go to Settings > Privacy & Security > Apple Advertising and toggle the switch for Personalized Ads. This action will prevent Apple from displaying personalized ads, though it will not reduce the volume of ads you see. 
• Go to Settings > Privacy & Security > Tracking. Here, you can prevent apps from tracking your activity across other apps and websites and reduce the risk of seeing personalized ads.
• Go to Settings > Privacy & Security > Location Services and toggle off the switch for Location Services. This will turn off any personalized geo-targeted ads (and otherwise prevent apps from tracking your location).

To adjust your advertising preferences in Android, visit: 

• Go to Settings > Google > All Services > Ads > Ad Topics and toggle the switch for personalized ads.
• Go to Settings > Google > All Services > Ads > App-Suggested Ads and toggle the switch for personalized ads on apps recommended by other apps.
• Go to Settings > Google > All Services > Ads > Reset/Delete Advertising ID

Additionally, visit  https://youradchoices.com/appchoices to download the AppChoices Tool to control interest-based advertising on apps on your mobile device.

Once your information is modeled or matched to other information in our systems, we remove the pseudonymous records that would be considered ‘personal’. The time period from collection to removal of pseudonymous information is approximately thirteen (13) weeks. We may maintain the pseudonymous records and associated signal information for up to eighteen (18) months from the date of collection for purposes of analytics and analyzing trends.  As a result, requests for access, modification or deletion are technically difficult and practically limited.  As an alternative, we can provide a persistent opt-out so that your social identifiers are not ingested into our Services. To opt-out, email us at dataprivacy@affinityanswers.com with your social media handle and a screenshot of your social profile settings page from Facebook, Instagram, Twitter, Reddit and TikTok.

Affinity Answers works with numerous advertising technology providers who offer an opt-out choice. Please visit the following links to learn more about these choices;  Oracle, Eyeota, Liveramp, V12, LiveIntent. In addition, you may also choose to opt-out of other potential ad partners through the Digital Advertising Alliance’s industry-wide opt out.  

5. Security & Retention

Affinity Answers takes all reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of any personal information. All information is stored on secure servers.  We endeavor to protect the privacy of our information, but unfortunately, we cannot guarantee complete security.

We generally retain consumer personal information for as long as necessary to provide our Services to our business customers, or for as long as our business customers have an account with us plus one (1) year. With regards to information collected from inquiries that do not result in a subscription to our communications or associated Services, we will delete this information after one (1) year.  We may also retain personal information if required by law, or for our legitimate interests, such as abuse detection and prevention, and defending ourselves from legal claims. Residual copies of personal data may be stored in backup systems for a limited period as a security measure to protect against data loss. For more information, please email us at dataprivacy@affinityanswers.com. 

6. Children's Information

Affinity Answers does not intend for this website or any of our business services to collect personal information (or ‘personal data’ for EU visitors) from children under the age of 16.  If you are under 16, please do not attempt to register for the Services or send any personal information about yourself to us. If you believe that a child under 16 may have provided us with personal information, please contact us via email at dataprivacy@affinityanswers.com.

EU Data Subjects Disclosures

Residents of the United Kingdom (“UK”) and European Economic Area (“EEA”) are afforded certain privacy rights and protections regarding their personal data, including those granted under the UK General Data Protection Regulation and European Union’s General Data Protection Regulation (collectively, the “GDPR”).

Legal Basis:

Affinity Answers processes personal data under the following legal basis: 

AFFINITY ANSWERS PROCESS ACTIVITY	LEGAL BASIS UNDER GDPR
Placement of cookies on our website	Consent
Collection and processing of personal data received from our business customers in order to provide our Services	Contract Fulfillment
Service-related communications	Legitimate Interest
Improving our Services	Legitimate Interest

Your Rights:

• The right to access. You have the right to request Our Company for copies of your personal data. We may charge you a small fee for this service.
• The right to rectification. You have the right to request that Our Company correct any information you believe is inaccurate. You also have the right to request Our Company to complete the information you believe is incomplete.
• The right to erasure. You have the right to request that Our Company erase your personal data, under certain conditions.
• The right to restrict processing. You have the right to request that Our Company restrict the processing of your personal data, under certain conditions.
• The right to object to processing. You have the right to object to Our Company’s processing of your personal data, under certain conditions.
• The right to data portability. You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

In addition to the rights granted above, if you are a UK or EEA resident, the GDPR grants you the right to lodge a complaint against us with your local data protection authority. You can find your data protection authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en. 

Controller/Processor Designation:

Under the GDPR, we are generally designated as a “Controller” in providing our Services. However, we may operate as a Processor acting upon the express instructions of our business customers in certain instances. If you would like a list of our processors (where we are a controller) and subprocessors (where we are a processor) please email us at dataprivacy@affinityanswers.com.  

Cross Border Data Transfers:

Affinity Answers is operated in the United States, and will process personal information exclusively in the U.S.  If you are visiting this website from outside the U.S., then by providing us with your personal information you are consenting to the transfer of that information to the U.S. 

We may transfer to, and store the data we collect about you, in countries other than the country in which the data was originally collected, including the United States or other destinations outside the EEA and UK. Those countries may not have equivalent data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA. We rely on model contracts approved by the European Commission when we transfer personal data to be processed by us or our service providers or partners in the U.S.  

For more information on cross-border transfers of your Personal Data or the appropriate safeguards in place, please contact us at dataprivacy@affinityanswers.com. 

Data Protection Officer:

We have appointed a Data Privacy Officer to oversee compliance with this Privacy Policy. If you have any questions about this Privacy Policy or how we handle your Personal Data, or would like to request access to your Personal Data, please contact our Data Protection Officer at dpo@affinityanswers.com.   

Authorized Representatives:

• UK Authorized Representative:

Pursuant to Article 27 of the UK GDPR, Affinity Answers Corporation has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom.

• EU Authorized Representative:

Pursuant to Article 27 of the EU’s GDPR, Affinity Answers Corporation has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium.

U.S. State-Specific Notices

Some U.S. states have enacted comprehensive privacy laws. The California Consumer Privacy Act, as amended by the California Privacy Rights Act or “CPRA” (collectively, the “CCPA”),the Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), Utah Consumer Privacy Act (“UCPA”), Oregon Consumer Privacy Act (“OCPA”), the Texas Data Privacy and Security Act (“TXDPSA”), and the Montana Consumer Data Privacy Act (“MTCDPA”) create additional privacy obligations for businesses and provide their residents with additional privacy rights.

Controller/Business and Service Provider/Third Party/Processor Designations:

• Under the CCPA, Affinity Answers operates as a (a) Business for all information collected through this Website; (b) Business for the collection and use of our business customers’ administrative representatives personal information to maintain their account and fulfill the Services; and (c) Third Party for the data we match information to via our Services and for all other uses of personal information. 
• Under the VCDPA, CPA, CTDPA, CPA, UCPA, OCPA, TXDPSA, and MTCDPA, Affinity Answers operates as a (1) Controller for all information collected through this Website; (2) Controller for the collection and use of our business customers’ administrative representatives personal information to maintain their account and fulfill the Services; (3) Controller for the data we source; and (4) Processor for the data we receive from our partners to fulfill our Services.    

CCPA Disclosure:

Category	Collected by	Example	Purpose of Processing	Category of Recipient
Identifiers	Affinity Answers	Our Website visitor’s cookie IDs	Analytics, advertising including cross-context behavioral advertising	Our Service Providers such as website analytics providers, storage and hosting vendors; Advertising and marketing partners
	Affinity Answers	Pseudonymized social media identifiers	Performing services on behalf of our business customers	Our Service Providers such as storage and hosting vendors
	Our customers	Cookie IDs, Mobile Advertising IDs (MAIDs) when you visit other companies’ websites and apps	Auditing including counting and verifying quality of ad impressions;  advertising including cross-context behavioral advertising; Performing services on behalf of our business customers	Our Service Providers such as storage and hosting vendors; DSPs; Data Marketplaces; Data Brokers
Demographic Information	Our customers	Age and gender	Performing services on behalf of our business customers; Advertising including cross-context behavioral advertising	Our Service Providers such as storage and hosting vendors; DSPs; Data Marketplaces; Data Brokers
Internet or other similar network activity	Affinity Answers	Your public engagement with media brands on social media such as you the time you liked, commented or otherwise interacted with a brand on social media	Performing services on behalf of our business customers; Advertising including cross-context behavioral advertising	Our Service Providers such as storage and hosting vendors
Inferences drawn from other personal information	Affinity Answers, Our Customers	Your interests at a category level such as ‘likes to travel’	Performing services on behalf of our business customers; Advertising including cross-context behavioral advertising,	Brands

2023 CCPA Request Metrics:

• Number of CCPA requests received: 16,755
• Median number of days to respond to CCPA requests: 40
• Mean number of days to respond to CCPA requests: 31.8
• Number of denied CCPA requests: 0
• Number of unfulfilled requests because Affinity Answers does not maintain the individual’s data: 15,044.

Additional privacy rights:

In addition to the rights granted above, if you are a California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, or Montana resident, you have the following rights: 

• To opt out of the “sale or share” of your personal information for advertising purposes. Affinity Answers does not ‘sell’ your personal information for monetary gain, however, some third party cookies placed on our website may be considered a ‘sale or share’ as used for our ‘targeted’ or ‘cross-contextual’ advertising campaigns.  You may opt-out of each vendor’s cookies by visiting their opt out pages provided above.
• Sensitive personal information. Californians and Utahns have the right to limit the use and disclosure of your sensitive information. Residents of Virginia, Colorado, Connecticut, Oregon, Texas, and Montana have the right to opt in to the use of their sensitive personal information. Affinity Answers does not collect, process, or disclose your sensitive information. 
• Opt out of profiling. Residents of California, Virginia, Colorado, Connecticut, Oregon, Texas, and Montana have the right to opt out of profiling based upon personal data. We do not profile as defined by these laws.

To exercise your rights, please visit our ‘Your Privacy Choices’ webform or email us at dataprivacy@affinityanswers.com.

Appeals:

If we deny your privacy request, you may appeal that decision by emailing us at dataprivacy@affinityanswers.com. If you are still unsatisfied with our response, you have the right to file a complaint with your state attorney general.

Changes to this policy

Changes to this policy shall be announced by posting the updated Affinity Answers Website & Business Privacy Policy on the Affinity Answers website.  Changes to this notice will be reflected in the “Last Updated” date above.

What’s new :

1. Amended May 2024 to include Texas and Montana consumers’ privacy rights and information on individual rights and appeals processes; and UK and EU authorized representative information. 
2. Amended December, 2023 to include Colorado, Connecticut, Utah, and Oregon consumers privacy rights and other required disclosures under the Colorado Privacy Act, the Connecticut Data Privacy Act, Utah Consumer Privacy Act, and the Oregon Consumer Privacy Act.
3. Amended December 19, 2022 to include consumers’ new privacy rights and required disclosures under the California Privacy Act and the Virginia Consumer Data Protection Act.
4. Amended October 13, 2022, to clarify rights available to individuals and to incorporate new requirements under the California Privacy Rights Act and Virginia Consumer Data Protection Act. 
5. Amended October 18, 2021, to add the Rights Available to individuals in respect of the processing under EU Data Subjects Disclosures & Rights.
6. Amended September 23, 2020, to clarify the Subject Access Request Process, to add details of other partners not included in the Privacy Notice, and to add a link to the EU Ad Choices website.
7. Amended Apr 20, 2020, to reflect the changes to this policy procedures and clarifications to retention periods for modeled and unmodeled pseudonymized data in the Services.

Contact Us

If you have any questions about this privacy policy or Affinity Answers’ treatment of your personal information, please write:

by email: dataprivacy@affinityanswers.com

by mail to 12708 Riata Vista Cir, Suite A-113, Austin, TX 78727