Switchboard Privacy Policy

Last Revised: June 11, 2021

Switchboard Labs, LLC (“our,” “we,” or “us”) respects your privacy. This Privacy Policy describes the types of information we may collect from you when you visit https://myswitchboard.com, use the Switchboard mobile application or use our other Switchboard products and services that include an authorized link to this Privacy Policy (collectively, the “Services”), how we use the information we collect, with whom we share it, how we protect it, and the choices we offer you regarding our collection and use of such information.

1. INFORMATION WE COLLECT

We may collect personal information about you, meaning information that can uniquely identify you, from various sources, such as:

• Directly from you when you use the Services, such as when you register for an account or access certain features or content;
• Social networks through which you may interact with us; and
• Our parent, subsidiaries, service providers, business partners, and other third parties.

The personal information we collect about you may include, without limitation:

• Contact information, such as name, postal address, email address, and phone number;
• Demographic information, such as age, gender, and postal code;
• Login information, such as username, password, and security questions and answers; and
• Payment information, such as billing address, zip code and card type, through our third-party payment processor.

When you use the Services, we may also collect certain information by automated means, such as cookies and web beacons. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag, or clear GIF, is used to transmit information about actions of the user opening the page or email containing the beacon back to a web server. We may also use third-party analytics tools (such as Google Analytics) that collect information about use of the Services and user traffic. The information we collect by automated means may include, without limitation:

• Information about the devices you use to access the Services (such as the IP address and the type of the device, operating system, and web browser);
• Dates, times, and duration of use of the Services (including whether you are a repeat or first-time visitor); and
• Information on actions taken when using the Services (such as page views and website navigation patterns).

The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve and personalize our Services, including by enabling us to identify and authenticate users.

2. HOW WE RESPOND TO DO NOT TRACK SIGNALS

Your web browser may let you choose your preference as to whether you want to allow the collection of information about your online activities over time and across different websites or online services. At this time, the Services do not respond to the preferences you may have set in your web browser regarding such collection of your information, and the Services may continue to collect information in the manner described in this Privacy Policy.

3. THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Some content or applications available through the Services, including advertisements, may be served by third parties. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Services, such as your IP address, pages you visit, and when you view a page or open an email in which a tag is embedded. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content and for other purposes. We do not control these third parties’ tracking technologies or how they may be used. The information practices of these third parties are governed by their own privacy policies and are not covered by this Privacy Policy. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

4. HOW WE USE THE INFORMATION WE COLLECT

We may use information we obtain about you to:

• Complete transactions you have requested using the Services, and provide you with products and services you request or allow you to utilize the Services directly;
• Contact you in relation to the Services;
• Send you information or materials you request or that we think may be of interest to you;
• Respond to your questions and comments and provide customer support;
• Communicate with you about our products, services, offers, and promotions;
• Operate, evaluate, and improve our business and the products and services we offer;
• Analyze and enhance our marketing communications and strategies;
• Analyze trends and statistics regarding use of the Services and transactions conducted using the Services;
• Protect against and prevent fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;
• Enforce our Terms of Service (https://myswitchboard.com/terms-of-service.html), services agreement and other agreements; and
• Comply with applicable legal requirements and industry standards.

We may combine the information we collect with information we receive from our parent, affiliate, or subsidiary companies, business partners, and other third parties. We may use that combined information to enhance and personalize your experience with us, to communicate with you about products, services, and events that may be of interest to you, for promotional purposes, and for other purposes described in this Privacy Policy.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

5. DISCLOSURE OF INFORMATION

We may disclose aggregated information about our users and information that does not identify any individual user without restriction. We may disclose personal information about you:

• To service providers and other third parties we use to support our business;
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• To enforce or apply our Terms of Service (https://myswitchboard.com/terms-of-service.html), service agreements and other agreements;
• If we believe disclosure is necessary or appropriate to protect our rights, property, safety, users of the Services, or others;
• To third parties to market their products or services to you if you have not opted out of these disclosures; and
• With your consent.

We also reserve the right to transfer your personal information to a buyer or other transferee in the event of a merger, divestiture, restructuring, reorganization, dissolution, sale, or other transfer of some or all of our assets, equity or similar transaction. Should such a transaction occur, we will use reasonable efforts to direct the transferee to use your personal information in a manner that is consistent with our Privacy Policy.

6. DATA SECURITY

We have implemented measures intended to protect your personal information from accidental loss and from unauthorized access, use, alteration and disclosure including encryption all personal information at rest. Please note that the electronic transmission of information is not completely secure. We cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that such measures will always be sufficient or effective. Any transmission of personal information is at your own risk.

7. YOUR CHOICES

We offer you the following choices about the information we collect from you and how we communicate with you:

Cookies

Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all of the features of the Services.

Promotional Communications

If you do not want us to use your contact information to promote our own or third parties’ products or services, you can opt out by sending us an email stating your request. If you have received a promotional email from us, you can also opt out of receiving future promotional emails from us by following the unsubscribe instructions contained in such email.

Third-Party Tracking

Although we do not control third parties’ collection or use of your information to serve interest-based advertising or other targeted content, a number of these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted advertisements from members of the Network Advertising Initiative by visiting http://www.networkadvertising.org/choices.

8. ACCESSING AND CHANGING YOUR INFORMATION

You can review and change the personal information associated with your account by logging into your account and visiting your account profile page. You may also send us an email to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

9. CHILDREN UNDER THE AGE OF 13

The Services are not directed to, and we do not knowingly collect or solicit personal information from, children under the age of 13. If we learn we have collected or received personal information from a child under the age of 13, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please contact us.

10. CHANGES TO OUR PRIVACY POLICY

We reserve the right to update or change this Privacy Policy at any time. If we make a material change to our Privacy Policy, we will provide notice to you by posting on our website that our privacy practices have changed and will provide a link to the new policy. In the event we make a material change to how we use your personal information, we will provide you with an opportunity to opt out of such new or different use. The date this Privacy Policy was last revised is at the top of this page. We encourage you to review this Privacy Policy periodically to check for any updates or changes.

11. DATA TRANSFERS

We are based in the United States. When we obtain information about you, we may transfer, process, and store such information outside of the country in which you reside, including in the United States. By using the Services, you consent to the transfer to and processing and storage of your information in countries outside of your country of residence, which may have different data protection laws than those in the country where you reside.

12. YOUR CALIFORNIA PRIVACY RIGHTS

This privacy notice applies to California residents from whom we collect personal information (“consumers” or “you”). We adopt this privacy notice to comply with the California Consumer Privacy Act of 2018 (“CCPA") and any terms defined in the CCPA have the same meaning when used in this privacy notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). We may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). “Personal information” does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope.

In particular, within the last 12 months the Services have collected the following categories of personal information from the sources and for the business or commercial purposes described below:

Description of Category	What We Collect	Source	Business or Commercial Purposes for Collection
Identifiers (“Identity Data”).	A real name, postal address, internet protocol address, email address, account name, or other similar identifiers.	Directly from the consumer; from third-party marketing partners; indirectly from the consumer, e.g., through the use of cookies.	Creating user accounts; providing our services; sending communications; conducting promotions.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (“Customer Records Data”).	A name, address, telephone number, financial information. Some personal information included in this category may overlap with other categories.	Directly from the consumer.	Creating user accounts; providing our services; sending communications; conducting promotions.
Commercial information (“Commercial Data”).	Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Directly from the consumer; indirectly from the consumer (e.g. through cookies).	Providing and bettering our services.
Internet or other similar network activity (“Internet Use Data”).	Interaction with a website, application, or advertisement.	Indirectly from the consumer, e.g., through the use of cookies and web beacons.	Providing and bettering our services.
Sensory data (“Sensory Data”).	Audio, electronic, visual, or similar information.	Directly from the consumer.	Providing and improving our services.

Use of Personal Information

In addition to the business or commercial purposes for collection described above, we have in the preceding 12 months collected all categories of personal information described above for the following purposes:

• To process your requests and transactions.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To create, maintain, customize, and secure your account with us.
• For testing, research, analysis, and product development, including to develop and improve the Services.
• To provide, support, personalize, and develop the Services.
• To help maintain the safety, security, and integrity of the website and our products, services, databases, other technology assets, and business.
• To deliver content and product and service offerings relevant to your interests, including targeted offers and ads through the Services, third-party sites, and via email or text message (with your consent, where required by law).
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, equity or a similar transaction, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the users of the Services is among the assets transferred.
• As otherwise described to you when collecting your personal information.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

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

• Service providers.
• Advertising networks.
• Internet service providers.
• Operating systems and platforms.

When we disclose your personal information to a service provider, we enter into a contract with the service provider that describes the business purpose for which your personal information is disclosed and restricts the service provider from using your personal information for any purpose except performing the contract.

In the preceding 12 months, we have disclosed to these third parties the following categories of personal information for a business purpose:

• Identity Data.
• Customer Records Data.
• Commercial Data.
• Internet Use Data.
• Sensory Data.

No mobile information will be shared by us with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Sales of Personal Information

We do not sell your personal information, as defined under the CCPA to third parties.

Your Rights and Choices

The CCPA provides you as California residents with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed for a business purpose, a list identifying the personal information categories that each category of recipient obtained.

Deletion Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty conducted in accordance with federal law, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

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

• Filling out the form at https://myswitchboard.com/ccpa.
• Emailing us at info@myswitchboard.com.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us, but we may require authentication of the consumer that is reasonable in light of the nature of the personal information requested. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (for a maximum total of 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the receipt of a verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless the request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Alternatively, we may decline to respond to the request and notify you of our reason for doing so.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.
• Provide you a different level or quality of goods or services, including denial 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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, levels, or quality of goods or services. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to us.

13. CONTACT US

If you have any questions about this Privacy Policy or our information practices, please contact us at:

Switchboard Labs, LLC
2001 K St NW
Washington, DC 20006
United States