Privacy Notice

BatchService understands that you care about how your information is used. This Privacy Notice (the “Notice,” “Privacy Notice”) explains how we process personal information through our websites and mobile applications (collectively, the “Sites”) and the services, features, or content we offer (collectively with the Sites, the “Services”); how we maintain, use, and share that information; and how you can manage the way information about you is handled.

This Notice supplements the Terms of Service posted elsewhere within the Sites. Please read the Notice and the Terms of Service before you use the Sites. If you do not understand and agree with this Privacy Notice, please do not use the Services.

“BatchService” for purposes of this Privacy Notice includes BatchService LLC, an Arizona limited liability company, its affiliates, and the suite of BatchService products (BatchData, BatchDialer, BatchLeads, BatchSkiptracing).

For residents of certain states, please click the corresponding links below to learn your rights under comprehensive state data privacy acts:

• California
• Colorado, Connecticut, Oregon, Utah, Texas, Virginia

I. Summary

This summary of our Privacy Notice serves to help you quickly learn who BatchService is, how you can opt-out of our database, and what remaining in it may potentially entail.

BatchService collects property and homeowner data, including contact and similar information to fuel its SaaS solutions and businesses that rely on real estate data & insights.

Under the law of some jurisdictions you may have certain rights with respect to your personally identifiable information. In that case, request a copy of your profile and amend your profile information or have it deleted by contacting us at https://batchleads.io/personal-information. You can opt out of our database by contacting us at https://batchleads.io/personal-information.

If your information remains in our database, you may be contacted by our customers when they are conducting their business-to-business sales, and marketing activities.

II. How we Collect Information

A. Type of Information Collected. We may collect the following types of information when you use the Sites:

1. Personally Identifiable Information (“PII”), which includes contact and real estate data we source from third parties and sell to you, your first and last name, home or other physical address, telephone number, email address, user I.D., 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. You also may view or engage with our Sites and its Services through third-party social networking Sites or social media plug-ins and applications. 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.
2. Device and network data such as, the type of browser you are using, the type of operating system you are using, the web pages you have 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.

B. Where does BatchService get the Personal Information?

1. How Information is Collected. We collect personal information from several sources: We collect information that you voluntarily provide while on the Sites.
2. We collect information automatically through the use of “cookies,” “web beacons,” “flash cookies” or by other electronic means.
3. We license information from third parties.
4. Our users and customers contribute information about themselves or other people and companies.

C. Customer Information.

Customer Information Collected. BatchService may collect the following information from or regarding its customers:

1. personal contact information regarding users of the Services (“User Information”);
2. information uploaded or otherwise provided to our system by a user of the Services (“Uploaded Information”);
3. usage logs regarding the use of the Sites and Services, including logins and other actions taken, time stamps, IP address, and other usage data (“Usage Logs”); and
4. any other information from or relating to users of our Services (“Related Information”) (collectively, “Customer Information”).

Use of Customer Information. Customer Information may be used in connection with a Customer or its users’ use of the Sites, including to respond to user inquiries and fulfill user requests, complete transactions, provide customer service, send administrative information, and to personalize user experience with the Sites. We may use Customer Information to better understand our users in general and to test, develop, improve, and enhance our Services and Sites. We may use Customer Information to contact customers or its users in the future about services, promotions, opportunities, and other general information about BatchService. We may use Customer Information to investigate and prosecute potential breaches of BatchService’s security or license agreements.

D. How else does BatchService Collect Information?

Information submitted through our Sites. Visitors to our Sites may choose to submit their name, email address, personal/work phone number, home/work address, and/or other information so that they can learn more about our Services, register to take part in a BatchService-sponsored event, participate in a survey, contest, or sweepstakes, or apply to BatchService’s open job positions, among other things. By accessing, using, and/or submitting information through the Sites, including by filling out forms, regardless of whether the form is ultimately submitted, a user of the Sites consents to the practices described in this Notice with regard to the information collected about them.

Use of our Services. In order to use certain Services, users may be required to create an account. From time to time, we may use a user’s email address to send information about our products and services. Users are provided with an opportunity to opt out of receiving such emails. We may also communicate with users regarding their use of our Services or Sites, including changes to this Notice. A more detailed description of how we may collect and use customer information can be found in the “Customer Information Collected” section above.

Providing information to our customers. We receive information about our customers’ end-users from or on behalf of our customers. Because of the nature of our Services, this information may contain any type of data, but typically includes name, contact information, and company information, such as company name. We may also collect data automatically through use of our Services, as described below. Any information provided through a website, application, or service on which a customer uses our Services is subject to the customer’s privacy Notice and applicable terms.

Purchasing our products and Services. Purchasers of our online subscription-based Services may need to provide credit card or other payment information to our payment service providers to allow us to fulfill the purchase request. Our payment service providers store credit card or other payment information and we do not have access to such payment card information.

Using our mobile applications. We collect certain information including your device type, operating system, location, platform used, device ID, and the date of last use, among other non-PII, through the downloading and use of our mobile applications. We may also collect other information such as the user’s name, email, company name, and information about the user’s account with us.

Connecting the Services to an email account or calendar. In order to provide certain Services, BatchService may require access to the user’s email account and/or calendar (e.g., through G-Suite or Office 365). Depending on the specific Services being used, we may collect email header information, email subjects, email signatures, and calendar meeting information such as meeting participants, meeting description, subject, and date and time of the meeting. Customers have control over what data is collected, including which mailboxes are connected, whether message attachments or content is collected, and which emails or email domains should not be collected. BatchService’s access to and use of information received from Google Accounts will adhere to the Google API Services User Data Notice, including the Limited Use requirements.

From our affiliates. BatchService may obtain personal information from our affiliates, such as our current and future parents, subsidiaries or other companies under common control and ownership with BatchService. We may use this information to enhance the information that we already maintain and to improve the accuracy of our records, in addition to other purposes described in this Notice.

From third parties. BatchService may obtain personal information from third-party sources such as our service providers and strategic partners. We may use this information to enhance the information that we already maintain and to improve the accuracy of our records, in addition to other purposes described in this Notice.

Creation of aggregated information. BatchService may aggregate collected information about our users in a form that does not allow users to be personally identified for the purpose of understanding our customer base and enhancing the Sites and the Services that we and our strategic partners and customers can provide you.

E. Automated information collection.We also collect information using cookies and similar automated technologies, as described below.

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.

Third Party Cookies. The use of cookies and similar technologies by our partners, affiliates, tracking utility company, and service providers is not covered by this Notice. We do not have access to or control over these cookies. Our partners, affiliates, tracking utility company, and service providers may use session ID cookies in order to:

• track which areas of our Sites individuals visit in order to remarket to them
• personalize visitors’ experience
• provide website features such as social sharing widgets
• analyze which pages our visitors visit
• measure advertising effectiveness

To disable or reject third-party cookies generally, please refer to the third-party’s relevant website or configure your browser settings appropriately.

Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc., on our Site. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Sites, compile reports on the Sites’ activity, and provide other services related to Sites activity and usage. The technologies used by Google may collect information such as IP address, time of visit, whether a visitor is a return visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google click here.

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.

Flash Cookies. The Sites use 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.

Third-Party Advertising and Third-Party Web Sites. These Sites allow advertising by third parties that provide links to third-party websites. 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 device and network data, 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.

Third Party Links. Please note that this Sites contains links to other web Sites that do not follow this Notice. 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 Notice 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 Notice to determine how it will handle such data.

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.) You can always refuse to provide PII to us, but this may result in decreased functionality of the services for you, limit your ability to receive information that may be of particular interest to you, and fail to receive leads or offers you could otherwise receive thanks to our services.

III. How we Use Your Data

In addition to the uses described in the above section, we may use PII for the purpose of conducting our business and pursuing our legitimate interests. For example, we may use PII for one or more of the following purposes:

• Create and manage user accounts
• Provide the products and Services
• Analyze the use of our Sites
• Maintain and improve the Sites
• Manage the Sites and Services
• Enroll users in contests, programs or other offers
• Tell Customers about other products and services that may be of interest to them (Customers can opt out of receiving such communications by following the instructions provided in the communication)
• Process payment for purchases
• Protect against or identify possible fraudulent transactions
• Develop new products and services
• Understand how users arrived at the Sites
• Send technical notices, updates, security alerts, and support and administrative messages
• Respond to comments, questions, and requests, and provide customer support
• Create user account(s) and identify users signing in to their account
• Communicate about products, services, offers, promotions, rewards, and events offered by BatchService and others, and provide news and information
• Monitor and analyze trends, usage, and activities in connection with the Sites
• Detect, investigate, and prevent fraud and other illegal activities
• Protect the rights and property of BatchService, our customers, and others
• Personalize and improve the Sites
• Provide notice of important changes to the Sites, including changes or updates to this Privacy Notice
• Facilitate contests, sweepstakes, and promotions, process entries, and deliver rewards
• Consider persons for possible employment with BatchService, and communicate about employment opportunities or submitted employment applications
• Respond to requests from individuals to access, correct, or delete their information, or requests to exercise other rights related to their information under applicable law
• Create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners or customers may use to provide and improve our respective services
• Comply with our contractual and legal obligations, resolve disputes with users, and enforce our agreements
• Carry out any other purpose described at the time the information was collected.

IV. How We Share the Data

Disclosure of Homeowner Profiles. We may make any homeowner profiles collected as described in this Notice available to our strategic partners and to our customers.

Disclosures to Parent Companies and Subsidiaries. We may share the data we collect with our parent companies and subsidiaries, both current and future, for any of the purposes set out in this Privacy Notice. This includes sharing with other companies under common control and ownership with BatchService.

Disclosures to Service Providers. BatchService may from time to time disclose PII and Non-PII or other collected information to service providers, solely for providing functions related to our operation of the Sites and provision of the Services and for no other purpose. For example:

• BatchService uses service providers to process credit card payments on our Sites. Information such as name, billing address, phone number, email address, and credit card information will be submitted to service providers for verification and to manage any recurring payments.
• BatchService uses software hosted by a service provider to provide us with information regarding our visitors’ activities on our Sites. When individuals visit our Sites, that service provider may set cookies on our behalf and may receive information about such individuals’ browsing activity on our Sites.

In addition, we may share your information as described below:

Disclosures for Legal Reasons. We may disclose collected information to a third party if we believe in good faith that such disclosure is necessary or desirable:

• to comply with lawful requests, subpoenas, search warrants, or orders by public authorities, including to meet national security or law enforcement requirements;
• to address a violation of the law;
• when we believe it is necessary to prevent, investigate, or address (a) possible illegal activities, including fraud, (b) violation of our Terms of Service, (c) threats to the physical safety of any person;
• to protect the rights, property, or safety of BatchService, its users, or the public;
• to allow BatchService to exercise its legal rights or respond to a legal claim; or (v) to respond to data subject requests for access to data to the extent necessary to comply with applicable laws.

Disclosures to Advertising Partners. We may disclose personal information to third-party advertising partners to help us advertise and promote our business and our services, including to display targeted advertising to you and others on third-party websites and platforms.

Disclosures to a Buyer of the Company. 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 Notice. 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.

Testimonials. We post customer testimonials on our Sites which may contain the customers’ names. We obtain consent from the customer prior to posting any testimonial. If a customer wishes to update or delete their testimonial, they can contact us at https://batchleads.io/personal-information.

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.

V. Your Rights.

Under the law of some jurisdictions, 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.

California Privacy Rights. Under California law, California residents may request twice 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 Notice. 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. California residents should also access our California Consumer Protection Act (CCPA) Notice at the end of this document.

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 Notice accordingly.

VI. The Choices You Make

1. A. How To Access, Change or Delete Your Data

Update Profile. Individuals or authorized corporate representatives can keep their BatchService Profile up to date by verifying it and updating information such as email address, phone number, or billing address. To view, verify, and update your Profile, please contact us at https://batchleads.io/personal-information.

Request Access to Information BatchService has Collected. Individuals who want to access the information that BatchService has collected about them can contact us at https://batchleads.io/personal-information to submit an access request. Once we have verified an individual’s identity, we will send a report with the information we have collected about the individual.

Remove BatchService Profile Completely. If you wish to completely remove your existing Profile from the database, please contact us at https://batchleads.io/personal-information. If you make this choice, your Profile and the information within it will be removed from our database as soon as possible.

VII. How Do We Keep Information Secure?

Information security is important to us. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We employ reasonable administrative, technical, and physical safeguards to protect the PII we collect from unauthorized access, use or disclosure. However, no method of Internet transmission or electronic storage is 100% secure, nor can we have control over the security of other websites on the Internet that you might visit. Therefore, while we strive to use commercially acceptable means to protect information, we cannot guarantee its absolute security. If you share your computer or use a computer that is accessed by the 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.

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.

BatchService employs security and back-up procedures designed to protect Customer Information. However, in the unlikely event there is a loss or corruption of Customer Information, BatchService is not responsible or liable for such loss or corruption. We encourage our users to retain copies of all Uploaded Information on their own system.

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.

VIII. Data Retention

We will retain personal information for a period of time consistent with the original purpose(s) for which we collected it, as described in this Privacy Notice, including, as applicable,

1. for as long as we have an ongoing relationship with the individual to whom the information pertains;
2. as long as needed to provide users, our customers, or our partners the Services;
3. as necessary to comply with our legal obligation(s);
4. as necessary to resolve disputes or to protect ourselves from potential future disputes; or
5. as necessary to enforce our agreements. Retention periods will be determined considering the amount, nature, and sensitivity of the personal information and the purpose(s) for which it was collected. After the retention period ends, we will delete the personal information. Where we are unable to do so, we will ensure that appropriate measures are put in place to prevent any further use of such information.

IX. Social Media Widgets

Our Sites includes social media features, such as the Facebook “Like” button and “Widgets,” such as the “Share” button or interactive mini programs that run on our Sites. These features may collect IP address and which page was visited on our Sites and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Sites. Interactions with these features are governed by the privacy Notice of the company providing it.

X. Users Outside of the U.S.

Individuals who use our Sites outside of the United States should understand that we may collect, process, and store their personal information in the United States and other countries in which we or our affiliates or subcontractors maintain facilities. The laws in the U.S. regarding personal information may be different from the laws of such individuals’ state or country. If you are using the Sites from outside the United States, please be aware that BatchService is located in the United States and your PII will be stored and processed in the United States where we locate and operate the servers and databases we use. 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.

XI. Children’s Privacy

Our Sites is not directed to or intended for individuals under the age of 18. We do not knowingly collect or use any personal information from users of our Sites who are under the age of 18. No personal information should be submitted to our Sites by individuals who are under 18 years of age. If we learn that we have collected information from someone who is under 18, we will take steps to delete the personal information as soon as possible. Individuals who believe we may have collected personal information from someone under 18 should contact us at https://batchleads.io/personal-information.

XII. Changes to this Notice

BatchService reserves the right to modify this Notice from time to time, so please review it regularly. If we make material changes to this Notice, we will notify individuals here, by email, and/or by means of a notice on our homepage prior to the changes becoming effective. Continued use of the Sites after any updates to this Privacy Notice constitutes acceptance of the updated Privacy Notice.

XIII. Contact Information

Questions concerning the Notice or the Sites, including any request to review or change your PII, should be directed to https://batchleads.io/personal-information.

XIV. Privacy Notice for California Residents

This Notice of Privacy is for California Residents and applies to all consumers who interact with BatchService who reside in the State of California. It supplements the information above in our Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”) and other California privacy laws, and it applies solely to “consumers” as that term is defined in the CCPA. Any terms defined in the CCPA have the same meaning when used in this Privacy Notice. No provision of this Notice may be construed to provide consumers any rights (or our company any obligations) beyond those required by the CCPA and other applicable law.

Disabled consumers who need these disclosures presented in an alternate medium, may contact us at the email address or telephone number listed further below.

XV. Information BatchService Collects

In the last twelve (12) months, we may have collected the following categories of personal information:

• Identifiers, such as a real name, account name, address, alias, bank account number, credit card number, email address, debit card number, driver’s license number, insurance policy number, internet protocol address, passport number, physical characteristics or description, postal address, online identifier, signature, Social Security number, state identification card number, telephone number, unique personal identifier, or other similar identifiers.
• Personal Information Categories Listed in the California Customer Records Statute, such as name, business address, telephone numbers (general or direct business numbers, faxes, and/or mobile numbers), education, employment, employment history, and credit or debit card number.
• Commercial Information, such as products or services considered, obtained or purchased, purchasing or consuming histories or tendencies, records of personal or real property.
• Internet or Other Similar Network Activity, such as Internet Protocol address and information on a consumer’s interaction with a website, application, or advertisement, browsing history, and search history.
• Characteristics of protected classifications under California or federal law. Age (40 years or older), ancestry, citizenship, color, disability (physical or mental), marital status, medical condition, national origin, race, religion or creed, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
• Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address.
• Professional or Employment-Related Information, such as past or present job history, performance evaluations, email address, including business and/or other email addresses (including “freemails” such as Gmail, Yahoo, Hotmail, etc.), telephone numbers (general or direct business numbers, faxes, and/or mobile numbers), business-related physical address, current or past job history, and title.
• Non-public / Private (non-public) educational information protected by the Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Class lists, disciplinary records, financial information, grades, identification codes, schedules, transcripts or other information directly related to a student which is collected by educational institutions or agencies acting on their behalf.
• Sensory information. Audio, electronic, visual, thermal, olfactory or similar data.
• Inferences, which may be drawn from the information identified above to create a profile about a consumer reflecting the consumer‘s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• Sensitive Information, such as your BatchService account login and password (if you are a BatchService customer or user) and the biometric information as described above. BatchService only uses sensitive information for the purposes specified in the CPRA and does not collect or process sensitive personal information for purposes of inferring characteristics about consumers.

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 prior notice.

XVI. Categories of Sources from which Personal Information is Collected

BatchService collects personal information from the following categories of sources:

• Publicly available information
• Independent research
• Submissions from BatchService’s customers
• Third-party data vendors, advertising networks, consumer data resellers, data analytics providers, government entities, internet service providers, social networks, operating systems and platforms.
• BatchService’s affiliates
• Government entities
• Directly and indirectly from activity or submissions on BatchService’s website
• Directly and indirectly from our customers or their representatives
• Directly from vendors and other contractual counterparties
• Through communications with prospective customers and other businesses and their representatives
• Any other sources described in this Privacy Notice under “How we Collect Information”

XVII. Purposes for Collection, Disclosure, Sharing, and Sale of Personal Information

BatchService collects, discloses, shares, and sells personal information for the following business and commercial purposes:

• Provide, maintain, and improve the Sites
• Verify, cleanse, update, and maintain information provided through the Sites
• Provide and deliver the Services, process transactions, and send related information, including communications and invoices
• Send technical notices, updates, security alerts, and support and administrative messages
• Respond to comments, questions, and requests, and provide customer support
• Create BatchService account(s) and identify users signing in to their account
• Communicate about products, services, offers, promotions, rewards, and events offered by BatchService and others, and provide news and information
• Monitor and analyze trends, usage, and activities in connection with the Sites
• Detect, investigate, and prevent fraud and other illegal activities
• Protect the rights and property of BatchService, our customers, and others
• Personalize and improve the Sites
• Provide notice of important changes to the Sites, including changes or updates to this Privacy Notice
• Facilitate contests, sweepstakes, and promotions, process entries, and deliver rewards
• Consider persons for possible employment with BatchService, and communicate about employment opportunities or submitted employment applications
• Create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners or customers may use to provide and improve our respective services
• Comply with our contractual and legal obligations, resolve disputes with users, and enforce our agreements
• Carry out any other purpose described at the time the information was collected or as otherwise set forth in the CCPA

XVIII. Third-Party Recipients

BatchService may disclose personal information to the following third-party recipients for the business and commercial purposes identified above:

• BatchService affiliates
• Service providers
• BatchService customers
• BatchService partners
• Any other recipients described in this Privacy Notice under “How we Share Information”

XIX. Sale, Sharing, and Disclosure of Personal Information

We sell personal information collected for our database to our customers. This database may contain information about consumers’ business personas including name, employer, job title and department, email address, phone number, office address, social media or professional profile link, and work or educational history. This information is sold to BatchService’s customers for the purpose of sales, marketing, and recruiting and is provided subject to license agreements that limit its use to those purposes. We may also disclose personal information to third-party advertising partners and such disclosures may constitute “selling” or “sharing” under the CCPA.

In the preceding twelve (12) months, we may have sold or shared the following categories of personal information to BatchService customers, partners, or affiliates:

• Identifiers
• Characteristics of protected classifications under California or federal law
• Commercial information
• Geolocation information
• Inferences or conclusions drawn from personal information
• Personal information categories listed in the California Customer Records statute
• Professional or employment-related information
• Non–public / Private (non-public) educational information protected by the Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

BatchService may also disclose personal information to its service providers for business purposes necessary for providing functions related to our operation of our business and provision of our products and services. In the preceding twelve (12) months, we have disclosed for a business purpose the following categories of personal information to our service providers:

• Identifiers
• Characteristics of protected classifications under California or federal law
• Commercial information
• Geolocation information
• Inferences or conclusions drawn from personal information
• Personal information categories listed in the California Customer Records statute
• Internet or other similar network activity
• Professional or employment-related information
• Non–public / Private (non-public) educational information protected by the Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

We do not knowingly sell or share the personal information of minors under 16 years of age.

XX. A Consumer’s Right to Opt-Out of the Sale or Sharing of Personal Information

A consumer has the right to opt-out of the sale or sharing of that consumer’s personal information by BatchService. Consumers may opt-out of the sale of their information by contacting us at https://batchleads.io/personal-information. In order to submit a request, a consumer or an Authorized Agent will be required to demonstrate that such person has control of an email inbox associated with the profile in question. If such person cannot, then we may be contacted regarding other means of verifying such person’s identity or the authorization of a third party to exercise a consumer’s rights on that consumer’s behalf.

XXI. A Consumer’s Other CPRA Rights and Choices

The CPRA provides consumers with specific rights regarding their personal information. This section describes a consumer’s CPRA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

A consumer has the right to request that we disclose certain information to that consumer about BatchService’s collection and use of that consumer’s personal information over the past twelve (12) months. Once we receive and confirm a consumer’s verifiable consumer request, we will disclose:

• The categories of personal information we collected about that consumer.
• The categories of sources from which the personal information was collected.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about that consumer (also called a data portability request).

Correction Request Rights

A consumer has the right to request that we correct personal information that we maintain about the consumer if it is inaccurate, taking into account the nature of the personal information and the purposes for which it is processed. Once we receive and confirm a consumer’s verifiable consumer request, we will use commercially reasonable efforts to correct the inaccurate personal information. We may require documentation if necessary to confirm the accuracy of the requested correction. We may deny the request if:

1. We determine, based on the totality of the circumstances, that the contested personal information is more likely than not accurate as maintained.
2. We determine that the requested correction would be impossible or would involve disproportionate effort.
3. The requested correction is in conflict with federal or state law.
4. We denied the same request to correct within the past six months and the consumer has not provided additional documentation in support of the request.
5. We have a good-faith, reasonable, and documented belief that the request to correct is fraudulent or abusive.

In any case, we will inform you of the action we take and, where the request has been denied, the reasons for the denial. Subject to the exceptions given below, a consumer whose request to correct has been denied may be able to exercise a right to delete the contested data.

Deletion Request Rights

A consumer has the right to request that BatchService delete any of his or her personal information that we have collected and retained, subject to certain exceptions. Once we receive and confirm a consumer’s verifiable consumer request, we will delete (and direct our service providers and/or customers to delete) that consumer’s personal information from our records, unless an exception applies.

We may deny a consumer’s deletion request if retaining the information is necessary for us or our service providers or customers to:

1. Complete the transaction for which we collected the personal information, fulfill the terms of a product warranty or product recall conducted in accordance with federal law, provide a good or service that a consumer requested, take actions reasonably anticipated within the context of our ongoing business relationship with that consumer, or otherwise perform our contract with that consumer.
2. Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
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 that conforms or adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the ability to complete such research, if a consumer provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on a consumer’s relationship with us and compatible with the context in which the consumer provided the information.
8. Comply with a legal obligation.

Exercising Access, Correction, Data Portability, and Deletion Rights

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

• Visiting the Request Information Removal page

Only a consumer, or a natural person or business entity that a consumer authorizes to act on a consumer’s behalf (an “Authorized Agent”), may make a verifiable consumer request related to a consumer’s personal information. A consumer may also make a verifiable consumer request on behalf of that consumer’s minor child.

A consumer or the consumer’s Authorized Agent 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 BatchService to reasonably verify a consumer is the person about whom we collected personal information.
• If an Authorized Agent is being used, provide sufficient proof that the consumer has provided the Authorized Agent with permission to submit the request on the consumer’s behalf, such as signed permission or a power of attorney executed pursuant to California Probate Code Sections 4121 to 4130.
• Describe a consumer’s request with sufficient detail that allows BatchService to properly understand, evaluate, and respond to it.
• You need not create an account to make requests, but if you have an account and login with us, signing in through our portal with a password serves to verify your identity.
• Select the format in which you would like to receive your personal information. This format should be readily accessible and allow you to transport the data to others without issue.
• You will need to prove your identity to us. If you have no password-protected account with us, you will need to provide us with at least 2 data points which we already maintain about you, and possibly other information and a signed declaration under penalty of perjury if the information maintained about you is of a sensitive nature. In some cases, we might not be able to successfully verify your information and in such a case, we will notify you as to why we cannot provide it.

We cannot respond to a consumer’s or an Authorized Agent’s request or provide a consumer or Authorized Agent with personal information if we cannot verify the consumer’s or Authorized Agent’s identity and/or authority to make the request and confirm the personal information relates to that consumer. Making a verifiable consumer request does not require a consumer to create an account with us. We will only use personal information provided to us 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 the consumer 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 choose a format to provide a consumer’s personal information that is readily useable and should allow a consumer to transmit the information from one entity to another entity without hindrance.

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

XXII. Non-Discrimination

To the extent required by the CCPA, we will not discriminate against individuals who choose to exercise any of their rights under the CCPA. Unless allowed by the CCPA, we will not:

1. Deny you goods or services because you exercised your rights.
2. Charge different rates or prices, impost penalties or grant differential discounts for punitive purposes.
3. Provide (or suggest) those who exercise their rights different quality goods or a different level of service.
4. We may, however, offer financial incentives to those who provide personal information which may result in variations in price, rates or quality depending on the value of the information provided.
5. You must opt-in or provide prior written consent to participate in financial incentive programs and you may revoke this consent at any time.

We do not offer financial incentives to consumers to induce their agreement for us to sell their personal information. Rather, if you do not agree, we might not be allowed to provide your information to third parties who have the quotes, services or other information you have requested. Note that under the CCPA, the “sale” of information does not include the disclosure of information at the consumer’s request. Consumers have the right to not receive discriminatory treatment by a business for exercising their rights under the CCPA. We will not discriminate against a consumer for exercising any CCPA rights.

XXIII. Deidentified Data

To the extent BatchService may collect or process deidentified data, we will maintain and use the information in deidentified form and will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy applicable requirements.

XXIV. Data Retention

For all categories of personal information we collect, we will retain personal information for a period of time consistent with and not longer than is reasonably necessary for the original purpose(s) for which we collected it, as described in this Privacy Notice, including, as applicable, (i) for as long as we have an ongoing relationship with the individual to whom the information pertains; (ii) as long as needed to provide users, our customers, or our partners the Services; (iii) as necessary to comply with our legal obligation(s); (iv) as necessary to resolve disputes or to protect ourselves from potential future disputes; or (v) as necessary to enforce our agreements. Retention periods will be determined taking into account the amount, nature, and sensitivity of the personal information and the purpose(s) for which it was collected. After the retention period ends, we will delete the personal information. Where we are unable to do so, we will ensure that appropriate measures are put in place to prevent any further use of such information.

XXV. Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) provides California residents with the right to request information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make a request, please contact us using the contact information found at the end of this notice.

XXVI. Changes to Our Privacy Statement

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

XXVII. Contact Information

If you have any questions, comments or queries about our privacy policy, how we collect or use personal information, your rights regarding such use, or how to exercise your rights please feel free to contact us at https://batchleads.io/personal-information.

This Privacy Statement was last updated on 10/31/2023

XXVIII. Privacy Notice for Residents of Virginia, Colorado, Connecticut, Utah, Oregon, and Texas

This Privacy Notice For Residents of Virginia, Colorado, Connecticut, Utah, Oregon, and Texas (“Notice”) supplements the information contained in the Privacy Policy of BatchService and applies solely to those individuals who have consumer privacy rights under the following laws (“consumers” or “you”): the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), the Oregon Consumer Privacy Act (“OCPA”), and the Texas Data Privacy and Security Act (“TDPSA”). No provision of this Notice may be construed to provide consumers any rights (or our company any obligations) beyond those required by above-listed laws and other applicable law.

Disabled consumers who need these disclosures presented in an alternate medium, may contact us at the email address or telephone number listed further below.

XXIX. Rights and Choices

Residents of Colorado, Connecticut, Utah, Virginia, Oregon, and Texas have specific rights regarding their personal information under state law. This section describes a consumer’s rights and explains how to exercise those rights.

A Consumer’s Right to Opt-Out of the Sale or Sharing of Personal Information

Depending on the consumer’s jurisdiction, a consumer may have the right to opt-out of the processing, targeted advertising, sale or sharing of that consumer’s personal information by BatchService.

Consumers may opt-out of the sale of their information by contacting us at https://batchleads.io/personal-information. In order to submit a request, a consumer or an Authorized Agent will be required to demonstrate that such person has control of an email inbox associated with the profile in question. If such person cannot, then we may be contacted regarding other means of verifying such person’s identity or the authorization of a third party to exercise a consumer’s rights on that consumer’s behalf.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Before we disclose information to you, we will ask you for information to verify your identity. 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, selling, or sharing that personal information.
• The categories of third parties to whom we disclose that personal information.
• If we disclosed your personal information for a business purpose, the business purpose and the categories of personal information that each category of recipient received.
• The specific pieces of your personal information that we have about you.
• We will provide this information in a portable and readily usable format.

Deletion Request Rights

You have the right to request that we delete personal information that we have about you. 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.

Correction Request Rights

You have the right to request that we correct inaccuracies in your personal information, considering the nature of the personal information and the purposes of the processing. Once we receive and confirm your verifiable consumer request, we will correct your personal information in our records, unless an exception applies.

If we deny your request, you may have the right to appeal our decision. To appeal, please contact us using the ways provided at the end of this Notice and provide the information that will help us identify your case. We will respond to appeals as required by applicable laws.

If you have concerns about the outcome of the appeal, you may also have the right under applicable laws to contact the respective state’s Attorney General’s office. A decided appeal with BatchService is a prerequisite for contacting the Attorney General.

Exercising Access, Correction, Deletion, and Data Portability Rights

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

• Contacting us at https://batchleads.io/personal-information

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 the consumer 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 choose a format to provide a consumer’s personal information that is readily useable and should allow a consumer to transmit the information from one entity to another entity without hindrance.

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

Non-Discrimination

We will not discriminate against you for exercising any of your state privacy rights. Specifically, 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.
• Retaliate against you in your role as an employee, applicant, or independent contractor.

XXX. Changes to This Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will notify you by posting the updated Notice on our website homepage. Please be sure to check back periodically for any updates.

XXXI. How to Contact Us

If you have any questions or comments about this Notice, this Privacy Notice, or the ways in which we collect and use your personal information, please do not hesitate to contact us at:

• https://batchleads.io/personal-information

Last updated: [6/26/2024]