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5X5 WEBSITE PRIVACY POLICY
Your Privacy Rights
Effective Date: December 29, 2023
This Website Privacy Policy describes the types of information gathered by 5×5 US, LLC. (“Five by Five”, “us” or “we”) in the process of providing this website, https://5x5coop.com/, and the data, information, tools, functionality, updates and similar materials (collectively, the “Site”), how we use it, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us through the Site. It is important that you take the time to read and understand this Privacy Policy so that you can appreciate how we use your personal information (“PI”).
This policy is subject to change. If our information retention or usage practices change, we will let you know by posting the Privacy Policy changes on the Site and/or otherwise making you aware of the changes. Your continued use of the Site following our notice of changes to this Privacy Policy (or other method of legal acceptance) means you accept such changes. Please refer to the “Effective Date” above to see when this Policy was last updated.
Subject to written agreements (“Data Participation Agreements”) with Five by Five, our commercial customers (“Members”) contribute PI about individuals for use in the development and licensing of Five by Five’s commercial data products (“Products”). Our Members typically contribute PI about visitor traffic in their own network, and email or call related information (i.e., whether the phone number or email was working, or not) collected through pixels or other tracking technologies present in their commercial websites and emails. While our Members are the primary contributors of PI to the Products that we create and license, we also collect PI which may become part of one or more Products. We collect this PI through a pixel that we created (“Pixel”) and placed on the Site, and in certain commercial emails.
The Pixel will collect your IP address, a unique identifier that we assign to you, device and browser level data, and timestamps which we may use to create or improve our Product(s), along with the PI provided to us by our Members. To the extent that we are able to determine you reside outside the U.S., or are under 18 years of age, based on the PI we collect from you, our system will remove your PI (and any other information about you) before it is added to the Products. Our Products are used for lead enrichment, targeting of advertising and audiences, sales, talent acquisition, identity verification, and fraud detection/prevention. If you would like to opt out of your PI being included in our Products, please proceed here, https://5x5coop.com/ccpa/. We will retain PI for as long as reasonably needed to provide the requested services to you or as otherwise authorized, subject to you requesting that we delete it, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
1. Who Collects Your Information about you?
If you visit our Site (“Visitor”), we collect your PI.
2. What Information Do We Collect?
· Identifiers that you provide directly, such as your first and last name, and business and personal email address, such as by completing a webform on our Site expressing interest in our business;
· Personal information categories identified in the California customer records statute such as your first and last name, and business and personal email address;
· Identifiers collected through use of the Site and our Pixel, such as unique online or device identifiers, IP address, device or session IDs, and information regarding your system configuration (operating system and version); and
· Internet and other network activity such as browsing history, search history, and information regarding an Individual’s interaction with an internet website, advertisement, cookie, or our Pixel, JSON headers (device and browser level data), and timestamps.
We do not collect or process the following categories (under the CCPA) of PI: characteristics of protected class, commercial information; biometric information; geolocation data; sensory data; professional and employment information; non-public education information; sensitive personal information; or inferences based upon the same.
B. Automatically Collected Information. We may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. Information typically collected in this manner includes, but is not limited to, IP address the type of device used and its operating system, browser information, the pages accessed most frequently, how pages and features are used, time spent on a page, search terms entered, and similar data. Methods of automatically collecting PI which we use commonly include tracking IP addresses, using web beacons, pixel tags (including our Pixel), cookies, embedded links, and similar information-gathering tools. If information which does not otherwise identify you is paired to any of your PI, we will treat that information as if it were also PI.
C. Aggregate Information. We may also collect anonymous, deidentified, and aggregate information about you such as the type of browser you are using, the type of operating system you are using, the date and time of any request, language preference, referring site, and the domain name of your Internet service provider.
3. How Do We Use the PI We Collect?
We collect PI from visitors to our Site for the following purposes:
· Internal Business Operations. We may use your PI to track usage trends, conduct experiments, develop and improve the Site and other offerings, and perform research and analytics. We collect standard web log information for monitoring purposes to help us to diagnose problems with our servers, administer the Site, calculate usage levels, and otherwise provide services to you. If your organization becomes a Member, we will use the contact information of the authorized users and representatives of those organizations to develop and operate the business of Five by Five.
· Product Development and Licensing. We may use website PI to develop and improve Products and ultimately license these Products to our Members
· AI Training. We may use your PI (provided it was collected by the Pixel and you have not opted out of such processing) to train, develop, and improve the artificial intelligence models and algorithms that we have created, or otherwise have rights to (collectively, “AI Models”). Our AI Models contribute to the services provided to Members by working to match similar records and to collate them into a single identity.
· Responding To Your Inquiries and Fulfilling Your Requests. We may use your PI to respond to your inquiries and to fulfill your requests for information, such as when you complete an online webform seeking information about our commercial offerings.
· Communicating With You About Our Offerings. We may use your PI to send you information about products and services that we offer which may be of interest to you.
· Sending Administrative and Promotional Emails. We may use your PI contact you in order to (a) operate our business, such as in connection with invoicing and collecting fees and payments or overseeing Member contributions and uses of Products; (b) acknowledge receipt of your requests; (c) inform you of changes to this Privacy Policy, or our other terms, conditions, or policies; or (d) provide you with information on our services and products.
· Aggregate/De-Identified Information. We may aggregate and/or de-identify any PI collected through the Site so that such PI can no longer be linked to you (“Aggregate/De-Identified Information”). Because it is no longer PI, we may use Aggregate/De-Identified Information for any purpose, including without limitation for research purposes, and may also share such data with any third parties in our discretion.
4. Do We Share Your PI?
We will not share your PI except: (a) for the purposes for which you provided it, such as to inquire or engage with our commercial business activities; (b) with your consent; (c) as may be required by law or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); (d) with persons or organizations (including affiliates of ours) with whom we contract to perform services for us (e.g., Trovo, LLC), including the performance, or development of, aspects of the Site and other internal operations or business activities such as assessing the accuracy of the PI you provide and in the Products, and conducting system vulnerability tests; and (e) to our Members as part of the Products, on the basis that the PI was collected through the Pixel, and except to the extent that you have opted out of having your PI included in the Product(s) (provided here, https://5x5coop.com/ccpa/). Members may transmit or share your PI subject to the Data Participation Agreement we have in place with each Other Member.
We may also share Aggregate/De-Identified Information with others, including affiliated and non-affiliated entities.
Finally, we may transfer your PI to another party (affiliated or non-affiliated), or our successor-in-interest, in relation to, or in the event of, a merger, acquisition, sale of all or substantially all of our assets, reorganization, bankruptcy, or other change of control. After such disclosure or transfer, the third party or successor in interest may use your PI in accordance with this Privacy Policy.
5. How Can You Access and Control Your Information?
Please email us at privacy@5x5coop.com to access your PI that we have collected, or correct errors in such PI. If you would like to opt-out of receiving any promotional email that we send you, please click on the unsubscribe link at the bottom of any such email. We will also promptly stop using your PI and remove it from our servers and database at any time upon your e-mail request, where required by law.
If you would like to opt out of your PI being included (on a forward-looking basis) in our Products, you may do so here, https://5x5coop.com/ccpa/. It should be noted that, even after opting out, you may still see ads or be contacted by Members that obtained access to Products containing your PI before it was removed. We may retain some PI after an opt out to the extent necessary to honor your request in the future. We impose contractual terms on our Members’ use of your PI including, but not limited to, their serving interest-based advertising. If our Members proceed to serve you with targeted ads, and they are members of the Network Advertising Initiative (“NAI”), you may opt out of such ads on the NAI’s website.
To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections, or removing your PI.
6. How We Store and Protect Your PI
A. After receiving your PI, we will store it on our servers for future use. We have physical, electronic, and administrative procedures in place to safeguard and help prevent unauthorized access, maintain data security of, and correctly use the PI we collect. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your PI (e.g., strong encryption, multifactor authentication, and limiting access to only those employees whose job function truly requires access to your PI), we cannot ensure the security of any PI you transmit to or receive from us or that we store on our or our service providers’ systems.
B. If you are accessing the Site from outside of the United States, you understand that your internet connection will be through and to servers located in the United States, and the PI you provide will be securely stored in our servers and internal systems located within the United States.
C. We store your PI (i) for as long as necessary for the purpose for which it was provided, (ii) as otherwise required for our legitimate business purposes (e.g., internal analytics, improving the Site, and providing the Products (if such PI was collected via the Pixel); or (iii) until our receipt of your opt-out request, or that we delete the PI/remove the PI from our servers. We will use commercially reasonable efforts to remove the affected PI from our Products and/or system within 30 days of the first to occur of either (i), (ii) or (iii).
7. How Do We Use Cookies and Other Network Technologies?
A. To enhance your online experience with us, our web pages may use “cookies.” Cookies are text files that our web server may place on your device to store your preferences. Cookies, by themselves, do not tell us your email address or other PI unless (1) you choose to provide PI to us, and/or (2) we already have PI that can be linked to you in our Products, in either case, the PI may be linked to the data stored in the cookie. Certain features of the Site may not function properly without the aid of cookies. Five by Five uses cookies to allow you to seamlessly navigate from one page or area of the Site to another during your visit, and these are normally deleted when you close your web browser.
B. We or our service providers may also use “pixel tags,” “web beacons,” “clear GIFs,” or similar means (collectively, “Pixel Tags”) in connection with some Five by Five Site pages and email messages formatted to, among other things, compile aggregate statistics about Site usage and response rates. Specifically, we use our Pixel, which we developed. A Pixel Tag is an electronic image, often a single pixel (1×1), that is ordinarily not visible to website visitors and may be associated with cookies on visitors’ device. Pixel Tags allow us and our service providers to count users who have visited certain pages of the Site, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in formatted email messages, Pixel Tags can inform the sender of the email whether and when the email has been opened.
C. As you use the internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as “clickstream data”, and can be collected and stored by a website’s server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to our Site. We may use clickstream data as a form of Aggregate/De-Identified Information to determine how much time visitors spend on each page of our Site, how visitors navigate through the Site, and how we may tailor our web pages to better meet the needs of visitors.
D. Do Not Track. At present, the Site does not specifically respond to browser do-not-track signals, which are settings in your internet browser that sends signals to websites and indicate that the use does not wish to be tracked for targeted advertising or analytics.
8. Collection of PI by Others
Our Site may provide links to certain third-party websites. When you leave our Site, please check the privacy policies of these other websites to learn how they collect, use, store and share PI that you may submit to them or that they collect. We are not responsible for the privacy practices of such other sites and/or any third parties. This privacy policy applies solely to PI collected through the Site and processed by Five by Five.
9. Children and Young People’s PI
We do not knowingly collect any PI from any minors, and we comply with all applicable privacy laws including the CCPA (defined below), and the Children’s Online Privacy Protection Act (“COPPA”), and associated Federal Trade Commission (“FTC”) rules for collecting PI from minors. Please see the FTC’s website (www.ftc.gov) for more information. If you have concerns about this Site, wish to find out if your child has accessed our services, or wish to remove your child’s PI from our servers, please contact us at privacy@5x5coop.com. Our Site will not knowingly accept PI from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. If we discover that a child under the age of 13 has provided PI to us, we will make efforts to delete the child’s PI in accordance with the COPPA. If you believe that your child under 13 has gained access to our Site without your permission, please contact us at privacy@5x5coop.com.
10. General Privacy Rights
A. You have the following rights with respect to our practices regarding your PI:
· The right of access. This is your right to be informed about what PI we are processing, why, and who else the data may be passed to.
· The right to correct. This is the right to have your PI corrected or amended if what is held is incorrect in some way.
· The right to deletion. Subject to certain exceptions, and limitations, this is the right to have your PI deleted.
· Right to Non-Discrimination. If you exercise one of your rights described in this policy, we won’t treat you differently in terms of the goods or services you can request, but if we gave you a discount on pricing in exchange for your PI that is no longer available to us, your pricing may increase based on the value of the data we no longer have or can no longer use.
B. Exercising Your Rights. You can find instructions for enforcing some of these rights in Section 5 and elsewhere in this Privacy Policy. Otherwise, if you wish to find out more about, or to exercise, any of your rights as described in this Agreement, please contact us at privacy@5x5coop.com and include “Privacy Rights Request” in the subject line of your email.
We will acknowledge receipt of your request within 10 days of receiving it, and will do our very best to respond within 30 days of receipt of your request, and in no event will our response come more than 90 days after receiving your request.
Before we respond to any requests relating to your PI, we will take steps to reasonably verify the identity of the person making the request (“Requestor”) to make sure it’s you, or your authorized agent. We do this to make sure we’re sending it to you, or someone that you have approved, not to inconvenience you in any way. As the sensitivity of the PI relating to your request increases, we will do more to verify your identity, in order to properly protect this sensitive PI. If someone is making a request on your behalf, we will need to also verify that person’s identity and if they can truly act on your behalf. If the identity of the Requestor cannot be reasonably verified, as you or someone asking on your behalf, then in order to protect that consumer, we shall deny the applicable request(s).
11. Notice to California Residents
The CCPA applies to what we do with the PI of California residents (“Consumers”) collected from visitors to https://5x5coop.com/, and the individual representatives and authorized users of our Members or potential Members. In addition to the rights described in Section 10, under the CCPA, Consumers have certain rights regarding their PI.
· Additional Information Regarding Your Right to Access (Collect). As a Consumer, your Right of Access in Section 10 includes any PI we have collected about you and disclosed in the previous 12 months including the categories of PI collected by us, the specific pieces of PI collected, the source(s) of such PI, and the purpose for collecting such PI. In the previous 12 months, we have collected the categories of PI about Consumers as disclosed in Section 2.
We collect PI about Consumers in such categories from the Consumers themselves, from third parties, and by automatic means for the purposes described in Section 3 above, and as required to comply with applicable law.
· Right to Access (Sale/Share). As a Consumer, you also have the right to request that we tell you which of your PI we have disclosed, sold, and/or shared in the previous 12 months. With respect to PI being disclosed, the Consumer shall receive the specific pieces of PI disclosed, sold, or shared, and the types of entities that receive this PI. In the past 12 months, we have disclosed and shared PI falling under the following categories:
o Identifiers that you provide directly, such as your first and last name, and business and personal email address;
o Personal information categories identified in the California customer records statute such as your first and last name, and business and personal email address;
o Identifiers collected through use of the Site and our Pixel, such as unique online or device identifiers, IP address, device or session IDs, and information regarding your system configuration (operating system and version); and
o Internet and other network activity such as browsing history, search history, and information regarding an Individual’s interaction with an internet website, advertisement, cookie, or our Pixel, JSON headers (device and browser level data), and timestamps.
In the past 12 months, we have sold PI falling under the following categories:
o Identifiers that you provide directly, such as your first and last name, and business and personal email address;
o Personal information categories identified in the California customer records statute such as your first and last name, and business and personal email address;
o Identifiers collected through use of the Site and our Pixel, such as unique online or device identifiers, IP address, device or session IDs, and information regarding your system configuration (operating system and version); and
o Internet and other network activity such as browsing history, search history, and information regarding an Individual’s interaction with an internet website, advertisement, cookie, or our Pixel, JSON headers (device and browser level data), and timestamps.
We disclose, sell, and share PI in the preceding categories to the other parties as the Consumer may direct, to our service providers, to our Members (if collected through the Pixel and Consumer has not opted out), and government/law enforcement agencies for the purpose it was provided, to comply with applicable law, and as otherwise described above in Section 3.
· Right to Limit the Use and Disclosure of Sensitive Personal Information. Residents of California may, at any time, request that we cease using or disclosing any sensitive personal information that we have collected about them to only such uses as permitted by the CCPA. We have not in the past 12 months collected Sensitive Personal Information at https://5x5coop.com/, and do not anticipate collecting such PI during the time this version of the Privacy Policy is posted.
· Right to Opt-Out of Selling and/or Sharing of Your PI. Consumers have the right to opt-out of the “sale” or “sharing” of their PI to third parties, including when we do so to track you across sites that we don’t own to serve you targeted ads. You can request that all or a portion of your PI in our possession or control not be “sold” or “shared” by clicking the “Do Not Sell My Info” link, available here https://5x5coop.com/ccpa/, and on our Site and following the instructions to submit your request.
As part of our on-going compliance efforts, below are the metrics for our CCPA responsiveness in the previous calendar year:
# Received | # Complied with in whole or in part | # Denied in whole or in part | Median or mean response days | |
Access Requests | 0 | 0 | 0 |
|
Correction Requests | 0 | 0 | 0 |
|
Deletion Requests | 0 | 0 | 0 |
|
Do Not Sell/Share Requests (all states) | 170,578 | 170,578 | 0 |
|
12. Notice to Nevada Residents
If you are a Nevada resident, we “sell” your “covered information” as such terms are defined in Chapter 603A of the Nevada Revised Statutes (“Nevada Privacy Law” or “NPL”). To exercise this right, please follow the process described in Section 10B above. As someone that is subject to the NPL, under your Right of Access described in Section 10, you are entitled to additional information about what PI of yours that we have or use. For this PI, please see Sections 2 and 11 for the PI we have collected, sold, and disclosed. Please note that defined terms, such as “sell” may have a different definition under the NPL than they do under the CCPA.
13. Notice to Virginia Residents
If you are a Virginia resident, this section and the Virginia Consumer Data Protection Act (the “VaCDPA”) also apply to you.
A. As someone that is subject to the VaCDPA, under your Right of Access described in Section 10, you are entitled to additional information about the PI of yours that we have or process. For this information, please see Sections 2 and 11 above the categories of PI we have collected, sold, and disclosed. Please note that defined terms, such as “sell” may have a different definition under the VaCDPA than they do under the CCPA.
B. Additional Rights for Virginia Residents. In addition to the rights described in Section 10 above, under the VaCDPA, consumers have the following rights:
· The Right to Opt-Out of Sales of Your PI. You may opt-out of such sales at any time.
· The Right to Opt-In to the Use of Your Sensitive Data. Five by Five will not process your sensitive data without first obtaining your consent to do so.
· The Right to Opt-Out of Profiling. You may opt-out of automated processing of PI to make decisions that produce legal or very significant effects on you.
· The Right to Opt-Out of Targeted Advertising. As a Virginia consumer, you may also be able to opt-out of targeted advertising based on your activity on websites that we do not own. You may still see generic ads, and ads based on what you do on our Site, even if you exercise this right.
· Right to Appeal Denial. If we deny your request to exercise rights under the VaCDPA, we will tell you why, and will have the right to appeal our decision by emailing us at privacy@5x5coop.com with “VaCDPA Appeal” in the subject line. If we deny your appeal, you have the right to submit a complaint to the Virginia Attorney General’s Office at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.
14. Notice to Connecticut Residents
If you are a Connecticut resident, this section and the Connecticut Data Privacy Act (the “CTDPA”) also apply to you.
A. As someone that is subject to the CTDPA, under your Right of Access described in Section 10, you are entitled to additional information about the PI of yours that we have or process. For this information, please see Sections 2 and 11 above, specifically the subsections on the Right of Access and what categories are collected, sold, and disclosed. Please note that defined terms may vary among different state laws, and that the CTDPA definitions of certain terms apply to this Section 14, and your reading of Section 11 in reference to this Section.
B. Additional Rights for Connecticut Residents. In addition to the rights described in Section 10 above, under the CTDPA, Connecticut residents have the following rights:
· The Right to Opt-Out of Profiling. You may opt-out of automated processing of PI to make decisions that produce legal or very significant effects on you.
· The Right to Opt-Out of Targeted Advertising. As a Connecticut consumer, you may also be able to opt-out of targeted advertising based on your activity on websites that we don’t own. You may still see generic ads, and ads based on what you do on our Site, even if you exercise this right.
· Right to Appeal Denial. If we deny your request to exercise rights under the CTDPA, we will tell you why, and you will have the right to appeal our decision by emailing us at privacy@5x5coop.com with “CTDPA Appeal” in the subject line. If we deny your appeal, you have the right to submit a complaint to the Connecticut Attorney General’s Office.
15. Notice to Colorado Residents
If you are a Colorado resident, this section and the Colorado Privacy Act (the “CPA”) also apply to you.
A. As someone that is subject to the CPA, under your Right of Access described in Section 10, you are entitled to additional information about the PI of yours that we have or process. For this information, please see Sections 2 and 11 above, specifically the subsections on the Right of Access and what categories are collected, sold, and disclosed. Please note that defined terms may vary among different state laws, and that the CPA definitions of certain terms apply to this Section 15, and your reading of Section 11 in reference to this Section.
B. Additional Rights for Colorado Residents. In addition to the rights described in Section 10 above, under the CPA, Colorado residents have the following rights:
· The Right to Opt-Out of Profiling. You may opt-out of automated processing of PI to make decisions that produce legal or very significant effects on you.
· The Right to Opt-Out of Targeted Advertising. As a Colorado resident, you may also be able to opt-out of targeted advertising based on your activity on websites we don’t own. Please be aware, if you do exercise this right, you may still see generic ads on the Site and targeted ads based on your activity with Five by Five.
· Right to Appeal Denial. If we deny your request to exercise rights under the CPA, you will be notified of the basis for such denial, and will have the right to appeal such denial by emailing us at privacy@5x5coop.com with “CPA Appeal” in the subject line. If we deny your appeal, you have the right to contact the Colorado Attorney General’s Office to submit a complaint.
16. Notice to Utah Residents
If you are a Utah resident, this section and the Utah Consumer Privacy Act (the “UCPA”) will apply to you as of December 31, 2023.
A. As someone that is subject to the UCPA, under your Right of Access described in Section 10, you are entitled to additional information about the PI of yours that we have or process. For this information, please see Sections 2 and 11 above, specifically the subsections on the Right of Access and what categories are collected, sold, and disclosed. Please note that defined terms may vary among different state laws, and that the UCPA definitions of certain terms apply to this Section 16, and your reading of Section 11 in reference to this Section.
B. Additional Rights for Utah Residents. In addition to the rights described in Section 10 above, under the UCPA, Utah residents have the following rights:
· The Right to Opt-In to the Use of Your Sensitive Data. Five by Five will not process your sensitive data without first obtaining your consent to do so.
· The Right to Opt-Out of Targeted Advertising. As a Utah consumer, you may also be able to opt-out of targeted advertising based on your activity on non-affiliated websites and services. You may still see generic ads, and ads based on what you do on our Site, even if you exercise this right.
17. Our Contact Information
If you have any questions or concerns about this Privacy Policy:
5×5 US, LLC
1800 E 4th St
Austin, Texas 78702
512-827-9312
Copyright © 5×5 US, LLC. All rights reserved. The Site is the property of Five by Five, and is protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Site, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.
5×5 US, LLC Is a Member Driven Organization. © 2023
Privacy Center | Do Not Sell or Share My Info