Privacy Policy

Effective as of March 2023

Introduction

Tunnl (“we,” “our,” or “us”) respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use, share, and safeguard your information. This Privacy Policy applies to individuals who access this website (“Site”) and any of our online and, where required, offline products and services (collectively, “Services”), as well as the individuals with whom we do not have a direct relationship but whose information we process in connection with the Services we provide to our clients.

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically.

For more information as to our Site’s use of cookies and other tracking technologies, please see our Cookie Policy.

This Privacy Policy covers the following topics:

1. Personal Data We Collect
2. How We Use Your Personal Data
3. How We Share Your Personal Data
4. Universal Opt-Out Mechanisms
5. Security
6. Third-Party Links
7. Children’s Privacy
8. Your State Privacy Rights and Additional Disclosures
9. Notice to California Residents
10. Accessibility
11. How to Contact Us

1. Personal Data We Collect

Personal data is information that is linked or reasonably linkable to an identified or identifiable individual.

Personal Data Collected Through Your Use of the Site and Services

We collect the following types of personal data from you through your use of the Site and Services:

Personal Data You Provide

Depending on how you interact with our Site and Services, we will collect the following personal data that you voluntarily provide to us for the following purposes:

• Create an Account. If you sign up for a Tunnl account, you will provide us with your email address, name, company name, and you will create a password for the account. You may also choose to provide us with your phone number and job title.
• Log In. When you log into your Tunnl account, you will provide us with your email address and password associated with the account.
• Use Our Services. If you use our software and platforms, you may provide us with your name; your company name, address, email, phone and billing contact; your political election and advertising entity; and your state, media market, target and tier.
• Contact Us. If you submit a form to contact us, you will provide us with your email address and any information you chose to provide in your message, and you may choose to provide us with your name, phone number, and organization’s name. If you submit a form to make a media inquiry, request a demo, or talk to our sales team, you will also provide us with your first name.
• Subscribe to Email. If you subscribe to receive emails from us, you will provide us with your first name and email address. To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us at notice@tunnldata.com.
• Careers. If you apply for a job with us, you will provide us with your name, email address, phone number, street address, and any information you choose to provide in your resume and cover letter.

Personal Data as You Navigate Our Site

We automatically collect certain personal data through your use of our Site and our use of cookies and other tracking technologies, such as the following:

• Usage Information. For example, the pages on the Site you access, the frequency of access, and what you click on while on the Site.
• Device Information. For example, hardware model, operating system, application version number, and browser.
• Mobile Device Information. Aggregated information about whether the Site is accessed via a mobile device or tablet, the device type, and the carrier.
• Location Information. Location information from Site visitors on a city-regional basis.

To learn more about how we use cookies on the Site and to manage your cookie settings, please see our Cookie Policy.

Personal Data We Collect About You from Other Sources

In some cases, we may receive personal data about you from other sources. This includes operating systems and platforms, mailing list providers, and advertising and marketing partners.

Personal Data Collected in Connection with Our Services

We collect the following types of personal data about you to process in connection with the Services we provide our clients:

Personal Data from Survey Respondents

If you participate in the opinion surveys that we conduct via a third-party survey provider or market research company, you will provide us with your views and opinions on topics ranging from consumer products to politics. When we conduct these surveys, we use the data, including any personal data, for aggregate analysis purposes. We use this data in combination with other third-party data to make predictions about audiences with similar characteristics as to how likely they are to buy a certain product or service or support a candidate.

Personal Data from Third Parties

In order to provide our clients (e.g., companies, political campaigns, and issue advocacy organizations) with the most accurate analyses possible, we also license data sets from third-party vendors who have lawful access to that information and comply with any and all federal and state laws that apply to these data sets. These data sets contain personal data, including:

• Television viewership data, such as the programs audiences watch and the devices on which they watch those programs;
• Data about individuals’ interests such as travel interests, purchasing interests, and other preferences;
• Information collected by states’ election divisions or secretaries of state, such as individual names, birthdates, physical address, ethnicity (in states where available), phone numbers, party registration (in states where available), and the elections individuals voted in, such as general elections or primary elections; and
• Data about predicted views on issues, politics, and purchases. As noted above, Tunnl uses either its own surveys or survey data from third parties to make predictions about how likely individuals are to take an action, such as support a candidate or cause.

From time to time, we may also collect personal data from other publicly available third-party sources, including personal data posted on websites and social media platforms such as YouTube, Reddit, and Twitter. We do not collect personal data from any non-public or private portions of these platforms, such as Direct Messages and private subreddits. Most social media platforms provide tools and settings that allow you to manage the publicly available content about you. While Tunnl does not control the privacy-related features of these third-party platforms, we strongly encourage you to explore these tools and settings so that you are comfortable with the information disclosed about you.

2. How We Use Your Personal Data

In addition to the purposes stated above, we may use all the personal data we collect in accordance with applicable law such as to:

• Maintain and improve our Site and Services;
• Protect the security and integrity of our Site and Services;
• Investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our terms, conditions, and policies, and to otherwise fulfill our legal obligations;
• Monitor compliance with and enforce this Privacy Policy and any applicable agreements and policies;
• Defend our legal rights and the rights of others;
• Fulfill any other purposes for which you provide it;
• For any purpose that is reasonably necessary to or compatible with the original purpose for which we collected the personal data as disclosed to you; and
• Comply with applicable law.

3. How We Share Your Personal Data

Our sharing of your personal data depends on the way in which we collect that personal data. If you are using our Site and Services, we may share the personal data that we collect about you in the following ways:

• With vendors who perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.);
• To the extent that we are required to do so by law;
• In connection with any legal proceedings or prospective legal proceedings;
• To establish, exercise, or defend our or a third party’s legal rights, including providing information to others for the purposes of fraud prevention;
• With any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal data;
• With any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding, or in preparation for any of these events;
• With any other person or entity where you consent to the disclosure; and
• For any other purpose disclosed by us when you provide the personal data or for any other purpose we deem necessary, including to protect the health or safety of others.

If we collect your personal data to process in connection with our Services, we may share such data in the following ways:

• With vendors who perform services on our behalf (e.g., hosting, maintenance, backup, etc.);
• With our clients at the aggregate level;
• When requested, with our clients at the individual level; and
• With any person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding, or in preparation for any of these events.

For more information on how we sell personal data with third parties, see our “Your State Privacy Rights and Additional Disclosures” section below.

4. Universal Opt-Out Mechanisms

The Site recognizes the Global Privacy Control (“GPC”) signal.     If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

5. Security

We maintain commercially reasonable security measures to protect the personal data we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.

6. Third-Party Links

The Site may contain links that will let you leave the Site and access another website. Linked websites are not under our control. We accept no responsibility or liability for these other websites.

7. Children’s Privacy

The Site and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal data from children under 13.

8. Your State Privacy Rights and Additional Disclosures

Depending on the state in which you reside, you may have certain privacy rights regarding your personal data. If you are a California resident, please see our “Notice to California Residents” section below. For other state residents, your privacy rights may include (if applicable):

• The right to confirm whether or not we are processing your personal data and to access such personal data;
• The right to obtain a copy of your personal data that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
• The right to delete personal data that we collected from and/or about you, subject to certain exceptions;
• The right to correct inaccurate personal data that we maintain about you, subject to certain exceptions;
• The right, if applicable, to opt out of the processing of your personal data for purposes of (1) targeted advertising; (2) the “sale” of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• If we are required by applicable law to obtain your consent to process sensitive personal data, the right to withdraw your consent; and
• The right not to receive discriminatory treatment by us for the exercise of your privacy rights.

We sell the following categories of personal data to our clients (e.g., companies, political campaigns, not-for-profits, foundations, and issue advocacy organizations):

• Contact information
• Inferences as to consumer demographics and consumer views on various issues, politics, and purchases

In addition, depending on how the applicable privacy law defines a “sale,” our Site’s use of cookies and tracking technologies may constitute a sale of personal data (i.e., information from cookies) to third-party advertisers and analytics companies. Our Site also uses cookies and other tracking technologies to display advertisements about our products to you on nonaffiliated websites, applications, and online services. This is “targeted advertising” under applicable privacy laws. We do not use personal data for profiling in furtherance of “decisions that produce legal or similarly significant effects” concerning individuals.

To exercise your rights, please submit a request through our interactive webform available here or by calling us toll-free at 1-866-498-2784. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting a request on behalf of another individual, please use the same contact methods described above. If we refuse to take action regarding your request, you may appeal our decision through our interactive webform available here.

9. Notice to California Residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”

Notice at Collection of Personal Information 

We currently collect and, in the 12 months prior to the Last Updated Date of this Privacy Policy, have collected the following categories of Personal Information:

• Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address, account name)
• Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
• Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (telephone number, education, employment, employment history, as well as the categories listed in “Identifiers” category above)
• Characteristics of protected classifications under California or federal law (race, color, sex/gender, age (40 and older), religion (including religious dress and grooming practices), national origin, ancestry, citizenship status, marital status, military or veteran status, political affiliations or activities)
• Commercial information (records of personal property, products or services purchased, obtained or considered; other purchasing or consuming histories or tendencies)
• Internet or other electronic network activity information (browsing history; search history; information regarding consumer’s interaction with a website, application, or advertisement)
• Geolocation data
• Audio, electronic, visual, or similar information
• Professional or employment-related information (including employment history)
• Education information
• Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
• Sensitive Personal Information (account login in combination with any required password allowing access to an account; racial or ethnic origin, religious or philosophical beliefs, or union membership)

We collect Personal Information directly from California residents (e.g., clients, potential clients, and Site visitors) and from data analytics providers, survey providers and market research companies, operating systems and platforms, social networks, and data brokers. We do not collect all categories of Personal Information from each source.

In addition to the purposes stated above in the “How We Use Your Personal Data” section, we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
• Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
• Debugging to identify and repair errors that impair existing intended functionality
• Short-term, transient use
• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, providing analytic services, or providing similar services
• Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality of our products and Services, and to improve, upgrade, or enhance our products and Services
• Advancing our commercial or economic interests, such as by enabling or effecting, directly or indirectly, a commercial transaction

Sale, Sharing, and Disclosure of Personal Information

The following table identifies the categories of Personal Information that we sold or shared to third parties in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:

We sold or shared Personal Information to third parties for the following business or commercial purposes:

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
• Performing services, such as providing analytic services
• Providing advertising and marketing services
• Advancing our commercial or economic interests

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information:

We disclosed Personal Information for the business or commercial purposes stated in the “Notice at Collection of Personal Information” section above.

We do not knowingly collect, sell, or share the Personal Information of consumers under 16 years of age.

Retention of Personal Information

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.

Your Rights

If you are a California resident, you have the following rights with respect to your Personal Information:

1. The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
2. The right to delete Personal Information that we collected from you, subject to certain exceptions;
3. The right to correct inaccurate Personal Information that we maintain about you;
4. If we sell or share Personal Information, the right to opt out of the sale or sharing;
5. If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
6. The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

How to Submit a Request to Know, Delete, and/or Correct

You may submit a request to know, delete, and/or correct through our interactive webform available here or by calling us toll free at 1-866-498-2784.

If you submit a request to delete online, you may be asked to confirm separately that you want your Personal Information deleted.

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

Our Process for Verifying a Request to Know, Delete, and/or Correct

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.

We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.

Right to Opt Out of Sale or Sharing of Personal Information

If you are a California resident, you have the right to direct us to stop selling or sharing your Personal Information.

You may submit a request to opt out of sales or sharing through our interactive webform available here or by calling us toll free at 1-866-498-2784. If you have enabled privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt out. Please see the “Universal Opt-Out Mechanisms” section above for more information.

Right to Limit Use and Disclosure of Sensitive Personal Information

California residents have the right to limit our use and disclosure of sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations. You may submit a request to limit our use and disclosure of your sensitive Personal Information through our interactive webform available by clicking here.

CCPA Request Metrics

Below are metrics regarding requests to know, delete, and opt out of sales received from all individuals pursuant to the CCPA for the 2022 calendar year.

Shine the Light Law  

If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes (as those terms are defined in that statute). To make such a request, please send an email to notice@tunnldata.com with the subject line “Shine the Light Request.”

10. Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

11. How to Contact Us

If you have any questions or concerns about our privacy policies or practices, please email us at notice@tunnldata.com.