Last revised: 11/19/24
Nothing in this Policy may be construed to create any obligations for the Company beyond what is required by applicable law.
California residents click here to access our California Consumer Protection Act (CCPA) Notice.
1. The following Privacy Policy (the “Policy”) describes how Giant Partners, Inc (“Company”), which owns and operates the website(s) GiantPartners.com, ListGiant.com and Via.Tools collects, uses, and shares personally identifiable information and non-personally identifiable information through the website and mobile applications it operates (collectively, the “Sites”) and the services, features, or content we offer (collectively with the Sites, the “Services”). This Policy supplements the Terms of Use posted elsewhere within the Sites. You should read the Policy and the Terms of Use before you use the Sites. If you do not understand and agree with this Policy, please do not use the Services.
2. Changes to this Policy. We may change the Policy at any time by posting revisions to the Policy on the Sites. Therefore, you should review the Policy from time to time. If you do not accept all of the terms, conditions and notices set forth in the Policy, you must exit the Sites immediately.
3. Collection of Information from Children. We do not intentionally collect information from or regarding minors. The Sites are not directed to, or intended for use by, children under the age of 18. Children may not use or submit any information through the Sites or its Services. If you are under the age of 18, you may not use our Sites or Services. If a child under 18 submits information through any part of the Services, and we become aware that the person submitting the information is a child, we will attempt to delete this information as soon as possible.
4. Type of Information Collected. We may collect two general types of information when you use the Sites:
a. Personally Identifiable Information (“PII”), which includes your first and last name, home or other physical address, telephone number, email address, user id, other identifiers that permit physical or online contact with you, or any information about you collected online and maintained in personally identifiable form in combination with any of the preceding categories. When you engage with the Sites and its content through such third-party Sites, plug-ins or applications, we may have access to certain information from your social media profile, such as your name, photo, gender, birthday, location, videos, your list of friends, etc. This information is included in the definition of PII.
b. Non-personally identifiable information (“non-PII”) such as, the type of browser you are using, the type of operating system you are using, the web pages you have visited sites visited before and after you visit the Sites, the type of handheld or mobile device used to access the Sites or other device-specific information.
5. Certain features available within the Sites will require you to submit PII about yourself as a condition of participation. Some of the features may be offered by us, while others may be offered by third parties. (For example, you may be required to submit PII in order to request information and offers from us and our partners.) When you choose to submit PII to a third party in connection with your use of the Sites, the third party’s privacy policy, rather than this Policy, will control the use of your PII. YOU CAN ALWAYS REFUSE TO PROVIDE PII TO US, BUT THIS MAY RESULT IN DECREASED FUNCTIONALITY OF THE SERVICES FOR YOU AND LIMIT YOUR ABILITY TO RECEIVE INFORMATION ABOUT SERVICES THAT MAY BE OF PARTICULAR INTEREST TO YOU.
6. How Information is Collected. We collect information both actively and passively. For example, we will collect information about you that you voluntarily provide while on the Sites. In addition to information provided directly by you, we (and third parties that offer features through the Sites) may collect non-PII through the use of “cookies,” “web beacons,” “Flash cookies” or by other electronic means.
7. Cookies. In general, a cookie is a small amount of data sent to your browser from a web server and stored on your computer’s hard drive, where it can be used to identify your computer. Cookies can be used to measure web Sites usage, improve navigation around web Sites, and personalize a returning visitor’s experience on the web Sites. In most cases, you can set your browser to turn off cookies or to notify you before you receive one so that you can decide whether to accept it or not. Because cookies allow you to take advantage of some of the features on the Sites, we recommend that you leave them turned on. If you block or reject our cookies, some of the features on the Sites may not work for you. You can refer to the instructions for your browser to learn more about these functions.
8. Web Beacons. We, our third-party service providers, advertisers and partners also may use “web beacons” or similar technologies. Web beacons are small strings of code placed on a web page to collect data about how visitors use the Sites. For example, web beacons may be used to count the number of users who visit the Sites or to deliver a cookie to the browser of a visitor to the Sites. If you set your browser to turn off cookies, web beacons and similar technologies will detect your visits to the Sites, but they will not associate your activity on the Sites with information that otherwise would be stored in cookies. We do not control tracking technologies used by third parties on the Sites.
9. Flash Cookies. The Sites uses locally stored objects, also called “Flash cookies,” when it uses Adobe Flash Player (“Flash”) to provide special content such as video streaming, video on demand, video clips or animation. Flash, and similar applications, use Flash cookies to remember visitors’ Sites settings, preferences and usages. Flash cookies are managed directly through Adobe’s websites, rather than through your web browser.
10. Third-Party Advertising and Third-Party Web Sites. These Sites allows advertising by third parties that provide links to third-party web Sites. Internet advertising companies and the third-party websites on whose behalf they advertise (collectively “Third Parties”) may use the technology described above to send (or “serve”) directly to your browser the advertisements that appear on our Sites. When this happens, Third Parties automatically receive non-PII, such as information from your computer and browser, including your cookie information. They also may use cookies, Javascript, Pixel Tags and other technologies to deliver advertisements; collect information about the effectiveness of their advertisements; collect anonymous information about your visits to the Sites, such as the number of times you have viewed an ad; or customize the advertising content you see. Third Parties will not collect your name, address, or other PII, unless you affirmatively provide it to them. We let Third Parties set and access their cookies on your computer. Third Parties’ use of their own cookies is subject to their own privacy policies. For more information about these specialized cookies and other technologies, and to learn more about behavioral advertising or to opt out of this type of advertising for some companies, you can visit http://www.networkadvertising.org or http://networkadvertising.org/optout_nonppii.asp. When using a mobile application, you may receive tailored in-application advertisements. Each operating system provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the instructions and/or the privacy settings for your operating system to find out how to opt out of tailored in-application advertisements.
11. Third Party Links. Please note that this Sites contains links to other web Sites that do not follow this Policy. For instance, clicking on an advertisement, links or other elements on the Sites may take you to an entirely different Sites. Links to other Sites may use our Sites logo or style as a result of a co-branding agreement. These Sites may send their own cookies to you and may collect data and make use of that data in ways that this Sites would not. After you leave our Sites, this Policy will no longer apply to PII or any other data collected from or provided by you. You should check the other web Sites’ applicable privacy policy to determine how it will handle such data.
12. How Information is Used and Shared. We use your PII for the purpose of conducting our business and pursuing our legitimate interests. For example, we use your PII to:
a. Facilitate communication from third parties to you at your request;
b. Create and manage your account;
c. Provide the products and services you request;
d. Enroll you in programs or other offers you request;
e. Tell you about other products and services that may be of interest to you (you can opt out of receiving such communications by following the instructions provided in the communication);
f. Process payment for purchases you have made;
g. Protect against or identify possible fraudulent transactions;
h. Analyze the use of our Sites;
i. Develop new products and services;
j. Understand how you arrived at the Sites;
k. Manage the Sites and Services;
l. Enforce our Terms of Use; and
m. Enforce the terms of this Policy.
13. Advertisements, Marketing Material and Other Offers. Unless you tell us that you do not want to receive these offers and subject to applicable law, the Company or those companies that we have a commercial relationship with, may occasionally send advertisements, marketing material or other offers that we think might be of interest to you. If you do not want to receive these advertisements, marketing material or other offers, please contact us using the contact information found at the end of this Policy. Where required by law, we will seek your consent prior to sending you any marketing materials. To the extent allowed by law, the provision of your email and phone number to us constitutes your prior express written consent, and electronic signature, authorizing us to contact you at that email address and phone number, including through the possible use of an automatic telephone dialing system or artificial or prerecorded voice, live calls and text messages, for both promotional and informational reasons. You agree that this consent may be assigned by us to third parties and affiliates. You are not required to provide such consent in order to make a purchase as you can always contact us directly to arrange an alternate purchase method. By providing your telephone number to us, you certify that this is your own number that you own, and not a line owned or used by another, and that you will immediately notify us if your number changes or is reassigned. You agree to indemnify us if this is not the case and if the future owner or user of the number makes a claim against us for contact at that number. You may opt out of such contact at any time and through any of the reasonable methods outlined herein. A copy of our internal, written No-Not-Call Policy will be provided upon request.
14. In the event that Company is considering a sale of its business, in its entirety or a component thereof, or substantially all of its assets are acquired, or a portion thereof, PII and non-PII, may be one of the transferred assets, and may therefore be used by a third-party acquirer in accordance with this Policy. Such use by a third party may include review of PII, using such PII to contact you either before or after such a transfer or sale, use or transfer of non-PII before or after such a transfer or sale, or for other purposes.
15. WE MAY DISCLOSE PII ABOUT YOU TO A THIRD PARTY FOR COMPENSATION.
16. In addition, we may share your information as described below:
a. Information You Elect to Share: You may choose to share information with Third Parties by clicking on links to those Third Parties from within the Sites. In addition, you may elect to share information, including PII, through the Services offered on the Sites by, for instance, posting comments on comment boards. Some of your activity on the Sites, including content you have posted, is public by default. Some of this content may include PII.
b. Third-Party Advertisers and Web Sites: We may share your non-PII with, or make your non-PII available to, Third Parties as described in the section above titled Third-Party Advertising and Third-Party Web Sites.
c. Information Disclosed to Vendors, Partners, Service Providers, and Others for Business Purposes: We contract with vendors to provide services related to the Sites and may share PII with such vendors in order to provide products or services to you or to help maintain the Sites. We also may share non-PII with our partners, service providers and other persons with whom we conduct business. We will only share your PII in accordance with applicable law.
d. Information Disclosed for the Protection of the Sites and for Others. We may disclose PII when (1) required by law or to respond to legal process or lawful requests, including from law enforcement; (2) when we believe it is necessary to prevent, investigate, or address (a) possible illegal activities, including fraud, (b) violation of our Terms of Use, (c) violation of this Policy, or (d) threats to the physical safety of any person; or (4) to protect our rights or property.
17. Forums. The Sites may include forums (such as message boards, chat rooms, comment boards, and reviews) that enable users to post a comment or communicate with each other. We are under no obligation to moderate or edit the forums and will not be responsible for the content or use of any material posted on any forum within the Sites. We retain the right to delete at any time and for any reason any material posted within the Sites.
18. Information Security. We take information security seriously, and we use reasonable administrative, technical and physical safeguards to protect the PII we collect from unauthorized access, use or disclosure. But we have no control over the security of other websites on the Internet that you might visit. If you share your computer or use a computer that is accessed by the general public, remember to sign off and close your browser window when you have finished your session. This will help to ensure that others cannot access your PII.
19. Additionally, and as you are likely aware, no system can be completely secure. Therefore, although we take commercially reasonable steps to secure your information, we do not promise, and you should not expect, that your PII, searches or other communications always will remain secure. In the event of a breach of the confidentiality or security of your PII, we will notify you if reasonably possible and as reasonably necessary so that you can take appropriate protective steps. We may notify you under such circumstances using the e-mail address(es) we have on record for you. You should also take care with how you handle and disclose your PII. Please refer to the Federal Trade Commission’s Web Sites at http://www.consumer.ftc.gov/ for information about how to protect against identity theft.
20. Your Rights. Under the law of some countries, you may have certain rights with respect to your PII. These rights include the right to: (i) request access to and rectification or erasure of your PII; (ii) obtain restriction of processing or object to processing of your PII; and (iii) ask for a copy of your PII to be provided to you or a third party in a machine-readable format. If you wish to exercise one of the above-mentioned rights, please send us your request to the contact details set out below. If you have unresolved concerns, you may also have the right to lodge a complaint about the processing of your PII with your local data protection authority in the European Union or elsewhere.
21. California Privacy Rights. Under California law, California residents may request once a year, free of charge, certain information regarding our disclosure of PII to third parties for direct marketing purposes. Specifically, we will provide a list of the categories of PII disclosed to third parties for third-party direct marketing purposes, along with the names and addresses of these third parties. To make such a request, please contact us using the contact information at the bottom of this Policy. We reserve our right not to respond to requests submitted other than to the contact points listed below. You should put “California Privacy Rights” in the subject line and in your request. We may need to verify your identity before providing information to you.
22. California Do Not Track Disclosure. Certain web browsers may allow you to enable a “do not track” option that sends signals to the websites you visit indicating that you do not want your online activities tracked. This is different than blocking cookies as browsers with the “do not track” option selected may still accept cookies. Our Sites currently do not have the functionality to recognize or honor “do not track” browser signaling. We do not respond to “do not track” signals. If we do so in the future, we will modify this Policy accordingly.
23. California residents should also click here to access our California Consumer Protection Act (CCPA) Notice.
24. If you reside in California, the California Consumer Privacy Act (“CCPA”) grants you certain rights regarding your Personal Information (PI), including: (i) the right to know what data we collect, disclose, and sell; (ii) the right to request deletion of your PI, subject to certain exceptions; and (iii) the right to opt out of the sale of your PI. For details on the PI we collect and how we gather it, refer to the section titled “The Types of Data That We Obtain and Use”. For information on how we use your PI, see the section titled “Our Services and How We Use Personal Information”.
If you are a California resident and wish to exercise any of these CCPA rights, please click here to email us or select “Do Not Sell or Share My Data” at the bottom of this page. We will respond promptly and within the legal timeframe. To process your request, we will verify your identity, which may require government-issued identification. Consumers may use authorized agents to submit requests, and we will verify the consumer’s identity and the agent’s authority to act on their behalf. Due to our internal compliance procedures and cybersecurity policies, we reserve the right to limit the size of bulk requests for opt-out and deletion requests. If you are an authorized agent submitting a large batch (more than 100 requests) of opt-out or deletion requests, please contact us directly at privacyteam@data-axle.com. We offer batch processing options to efficiently handle large groups of requests in line with our security controls. Please note that email-based bulk requests from unknown domains may be filtered as spam or blocked by our email provider, preventing successful receipt. We are only required to respond to two such requests per consumer each year. You also have the right not to face discrimination if you exercise any of your CCPA rights.
a. Statistical Reporting
The CCPA and the California Delete Act require certain businesses to compile and disclose information regarding their compliance with the CCPA for the previous calendar year. The statistics provided below relate to requests made by or on behalf of California consumers to Data Axle, Exact Data, and DonorBase. Statistics for the reporting period of January 1, 2023 – December 31, 2023, are as follows:
- Requests to Opt Out: 19,421 received; 19,421 fulfilled; 0 denied.
- Requests to Delete: 19,343 received; 19,343 fulfilled; 0 denied.
- Requests to Know: 20 received; 17 fulfilled; 3 denied.
- Completion Time: 9 days.
- Average Completion Time: 27 days.
Any denials of Requests to Know were due to consumers not verifying their identity as required by the CCPA.
25. Users from outside the United States. This Sites is hosted in the United States and is governed by U.S. law. If you are using the Sites from outside the United States, please be aware that Giant Partners, Inc is located in the United States and your PII will be stored and processed in the United States where we locate and operate our servers and databases. The data protection laws in the United States may not be as strict or comprehensive as those in your country. However, we value your privacy and always strive to treat it in accordance with applicable law. By voluntarily sharing your PII with us, you understand that your PII will be stored and processed in the United States.
26. Retention. We retain your PII for as long as you remain a customer and thereafter only for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or allowed by law, including to fulfill a legal obligation.
27. Contact Information. Questions concerning the Policy or the Sites, including any request to review or change your PII.
Website: www.giantpartners.com
Physical Address: Giant Partners, Inc.
Attn: Compliance Officer
1461 Lawrence Dr. 2nd Floor
Thousand Oaks, CA 91320
(888) 442-6898
28. Data Protection Policy. This policy refers to all companies of Giant Partners, Inc. (“GP”), and its customers who provide any information (“Data”) to us. GP is committed to ensuring that all Data handled by us will be processed according to legally compliant standards of data protection. Client Data is never shared or sold. Giant Partners uses voluntarily submitted client Data to build lookalike audiences to model consumer profiles for list generation. Once a project is complete, a notarized “Certificate of Data Destruction” is available upon request.
How Data is sent to GP
Firstly, some clients require a Non-Disclosure Agreement (“NDA”), in which GP will provide a copy of their NDA, where both parties will execute.
- Some clients wish to send their data directly to their GP sales representative via email.
- If client desires to send GP their suppression file or Data via a secure FTP site, the below steps transpire:
- GP has a proprietary dashboard available only to its employees, where the client’s sales representative will log in to, and they will click the “upload link” function.
- The sales representative will then fill out the form and a link will be sent to their client’s email address.
- This link is a private upload page that is available for only 24 hours.
- Once the client sends the information via the link provided, GP’s processing team will get a notification that the Client has sent their data.
- One of the data processors will then send an email to the client’s sales representative notifying them that GP is in possession of the Data. Once the sales representative has given instructions on how the processing team needs to fulfill the order, processing then goes into Amazon S3 and download the Data to a secure server.
What happens when Data is downloaded by GP
Once the data processor has downloaded Data onto the secure server, the data processor will at this point, add any appends needed for the client’s Data. The Data is then address standardized.
After address standardization, the Data either:
- Used to suppress out any data from GP’s database goes to either, OR
- Used to model a lookalike audience for the client.
After the results are achieved using the client’s Data, and upon client’s request, GP can either store that data in-house on a secure server, or GP can destroy the file and supply the client with a notarized “Certificate of Data Destruction” that assures client that the Data sent by client has been destroyed. A sample copy of the “Certificate of Data Destruction” can be provided upon request.
29. Changes to This Policy
We may update this Policy from time to time to reflect changes in our practices, legal requirements, or for other reasons. Any changes will be posted on this page, and the date of the latest revision will be indicated at the top of the page.
