Acquired Data Privacy Policy

Acquired Data (“Acquired Data,” “we,” “us,” or “our”) provides data aggregation, enrichment, verification, analytics, matching, and licensing services. This Privacy Policy explains how we collect, obtain, use, store, cache, aggregate, enrich, disclose, license, and otherwise process information through our websites, applications, products, databases, and related services collectively referred to as the “Services.”

This Privacy Policy applies to:

• Visitors to our websites;
• Customers and prospective customers;
• Authorized users of customer accounts;
• Individuals whose information may appear in our databases;
• Individuals who submit privacy requests; and
• Other persons who communicate or interact with Acquired Data.

By using the Services, you acknowledge the data practices described in this Privacy Policy.

1. Definitions

Customer Account Information

“Customer Account Information” means information associated with a customer’s relationship with Acquired Data, including names, business names, email addresses, telephone numbers, billing information, account credentials, transaction history, communications, support requests, and platform activity.

Customer-Provided Data

“Customer-Provided Data” means records, files, leads, lists, contact information, property information, or other information uploaded, transmitted, imported, or otherwise provided to Acquired Data by or on behalf of a customer.

Acquired Database Data

“Acquired Database Data” means information that Acquired Data obtains independently from data suppliers, data licensors, public records, publicly accessible sources, websites, directories, databases, customers, service providers, or other lawful sources, as well as information that Acquired Data creates through matching, aggregation, caching, standardization, verification, scoring, modeling, or enrichment.

Personal Information

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an individual or household. Personal Information does not include information excluded from applicable privacy laws, such as certain publicly available, aggregated, or deidentified information.

2. Information We Collect and Process

Depending on how an individual or business interacts with Acquired Data, we may collect or process the following categories of information.

Contact and Identification Information

This may include:

• Name;
• Mailing or property address;
• Email address;
• Telephone number;
• Business name;
• Business contact information;
• Job title;
• Professional affiliation; and
• Internal identifiers or database reference numbers.

Property and Real Estate Information

This may include:

• Property address;
• Ownership information;
• Parcel and assessor information;
• Property characteristics;
• Property classification;
• Transfer and transaction history;
• Mortgage or lien-related public records;
• Tax-related property records;
• Estimated property values;
• Property status;
• Occupancy indicators;
• Real estate activity; and
• Other property-related information obtained from public or licensed sources.

Business and Professional Information

This may include:

• Business ownership;
• Business contact information;
• Industry;
• Professional role;
• Licensing information;
• Company websites;
• Public business records; and
• Other professional or commercial information.

Public Record Information

This may include information available through federal, state, county, municipal, court, assessor, recorder, licensing, corporate, or other government records.

Online and Technical Information

When someone uses our website or platform, we may collect:

• Internet Protocol address;
• Browser type;
• Device information;
• Operating system;
• Login activity;
• Usage activity;
• Pages viewed;
• Referring URLs;
• Cookie identifiers;
• Approximate location derived from an IP address;
• Error logs; and
• Security and fraud-prevention information.

Commercial and Transaction Information

This may include:

• Services purchased;
• Order details;
• Subscription information;
• Payment status;
• Billing history;
• Usage volume;
• Credit balances;
• Product preferences; and
• Customer service history.

Payment card information may be processed by third-party payment processors. Acquired Data may not directly receive or retain full payment card numbers.

Communications

We may collect information contained in:

• Emails;
• Support tickets;
• Telephone calls;
• Chat communications;
• Surveys;
• Reviews;
• Forms;
• Account notes; and
• Other communications with Acquired Data.

Derived and Enriched Information

We may create, calculate, infer, or associate information by:

• Matching records from different sources;
• Standardizing names, addresses, and telephone numbers;
• Removing duplicate records;
• Verifying contact information;
• Associating individuals, businesses, or properties;
• Scoring data quality;
• Estimating the likelihood that information is current;
• Identifying relationships between records;
• Categorizing properties or businesses; and
• Creating other modeled, inferred, or enriched attributes.

Derived information may be based on incomplete, outdated, conflicting, or inaccurate source information and should not be treated as independently verified fact unless expressly identified as verified.

3. How We Obtain Information

Acquired Data may obtain information from the following sources.

Directly From Customers and Users

We receive information when customers:

• Create an account;
• Purchase Services;
• Upload records;
• Request data enrichment;
• Submit forms;
• Communicate with us;
• Use our platform; or
• Submit privacy requests.

Data Suppliers and Licensors

We may purchase, license, or otherwise obtain information from:

• Data providers;
• Data brokers;
• Property data providers;
• Public-record aggregators;
• Contact-information providers;
• Marketing data providers;
• Verification providers;
• Analytics providers; and
• Other commercial data sources.

Public and Publicly Accessible Sources

We may collect information from:

• Government records;
• Property records;
• Corporate filings;
• Licensing records;
• Court or recorder records;
• Public directories;
• Public business websites;
• Public professional profiles;
• Publicly accessible web pages;
• Public listings; and
• Other sources available to the general public.

Collection from publicly accessible sources may be completed manually or through automated collection technologies, including web crawling, indexing, extraction, or scraping, where permitted by applicable law.

Aggregation, Caching, and Enrichment

We may retain or cache information obtained from our sources to:

• Improve response times;
• Reduce duplicate data requests;
• Maintain data-source history;
• Identify changes;
• Verify data;
• Improve matching;
• Maintain suppression and opt-out records;
• Detect inaccurate or inconsistent information;
• Create aggregated datasets;
• Create derived or enriched data; and
• Improve our database and Services.

Information may remain in caches, backups, logs, or archived systems for a period after it is changed or removed from active systems.

Service Providers and Business Partners

We may receive information from vendors that assist with:

• Payment processing;
• Identity verification;
• Hosting;
• Security;
• Customer support;
• Communications;
• Analytics;
• Data validation; and
• Business operations.

4. Customer-Provided Data and Client Confidentiality

Acquired Data recognizes that customers may provide private lead lists, customer records, prospect information, property information, or other proprietary business data.

We may use Customer-Provided Data to:

• Perform the Services requested by the customer;
• Clean, verify, match, append, or enrich records;
• Deliver results;
• Prevent fraud or abuse;
• Provide support;
• Resolve billing or service disputes;
• Comply with legal obligations;
• Enforce our agreements; and
• Improve the Services using aggregated or deidentified information.

Unless the customer authorizes otherwise in writing, Acquired Data will not sell or license a customer’s confidential uploaded list as a standalone list to an unrelated third party.

This restriction does not prevent Acquired Data from:

• Using information already contained in Acquired Database Data;
• Using information independently obtained from another lawful source;
• Retaining matching keys, suppression records, quality metrics, provenance information, or service results;
• Using aggregated or deidentified information;
• Disclosing information to contracted service providers;
• Processing information as required to provide the Services; or
• Disclosing information when required by law.

Customers are responsible for ensuring that they have all rights, notices, permissions, consents, and lawful grounds required to provide Customer-Provided Data to Acquired Data.

Customers must not upload information that they are prohibited from possessing, processing, sharing, or using.

5. How We Use Information

Acquired Data may use information to:

• Provide, operate, and maintain the Services;
• Create and administer customer accounts;
• Process payments and subscriptions;
• Fulfill data orders;
• Match, clean, standardize, verify, append, and enrich records;
• Develop and maintain Acquired Database Data;
• License or provide data products to customers;
• Cache and aggregate information;
• Detect duplicate, fraudulent, inaccurate, or abusive activity;
• Monitor service quality;
• Improve our products, models, matching systems, and databases;
• Conduct internal analytics;
• Communicate with customers;
• Respond to support and privacy requests;
• Market our Services to customers and prospective customers;
• Protect Acquired Data, our customers, and other persons;
• Comply with legal requirements;
• Establish, exercise, or defend legal claims; and
• Enforce our contracts and acceptable-use requirements.

6. How We Disclose or License Information

We may disclose, provide, transfer, or license information to the following categories of recipients.

Customers and Data Purchasers

We may license or provide Acquired Database Data to customers that use the data for lawful business purposes, including real estate research, marketing, lead generation, business development, analytics, verification, and related activities.

Licensing or providing Personal Information in exchange for money or other valuable consideration may be considered a “sale” under certain state privacy laws.

Service Providers

We may disclose information to companies that provide:

• Cloud hosting;
• Database infrastructure;
• Data processing;
• Payment processing;
• Security;
• Communications;
• Analytics;
• Customer support;
• Verification;
• Compliance; and
• Professional services.

These service providers are permitted to process information only for authorized business purposes and subject to applicable contractual restrictions.

Data Suppliers and Verification Partners

We may exchange limited information with data providers or verification partners to match, verify, update, suppress, or improve records.

Affiliates and Related Companies

We may disclose information among companies under common ownership or control for business operations, service delivery, security, compliance, and administrative purposes.

Legal and Safety Disclosures

We may disclose information when we reasonably believe disclosure is necessary to:

• Comply with applicable law;
• Respond to a subpoena, court order, warrant, or government request;
• Protect legal rights;
• Investigate fraud;
• Prevent harm;
• Enforce an agreement;
• Protect the security of the Services; or
• Establish, exercise, or defend a legal claim.

Business Transactions

Information may be disclosed or transferred in connection with a merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or other corporate transaction.

7. Data Purchasers and Downstream Use

Customers and data purchasers are independent businesses that determine how they use data after receiving it from Acquired Data.

Purchasers are solely responsible for:

• Determining whether their intended use is lawful;
• Providing legally required notices;
• Obtaining legally required consent;
• Maintaining internal suppression and do-not-contact lists;
• Honoring opt-out and revocation requests;
• Complying with federal, state, and local privacy laws;
• Complying with telemarketing, email, advertising, consumer-protection, and anti-discrimination laws;
• Properly securing downloaded or exported data;
• Managing their employees, contractors, systems, and vendors; and
• Responding to claims arising from their communications, decisions, or conduct.

Purchasers may not use Acquired Data information to:

• Harass, threaten, stalk, intimidate, or harm any person;
• Commit fraud, identity theft, deception, or unlawful surveillance;
• Discriminate unlawfully;
• Violate privacy or consumer-protection laws;
• Send unlawful calls, text messages, emails, or advertisements;
• Circumvent a do-not-call, do-not-contact, or suppression request;
• Locate or target an individual for an unlawful purpose;
• Publish personal information for harassment or retaliation;
• Resell data in violation of an Acquired Data agreement; or
• Engage in any activity prohibited by applicable law or our agreements.

To the maximum extent permitted by law, Acquired Data is not responsible for the independent actions, communications, decisions, security practices, or legal compliance of a customer or purchaser after data has been delivered or made available to that customer or purchaser.

Nothing in this Privacy Policy limits any obligation or liability that cannot lawfully be waived.

8. No Fair Credit Reporting Act Use

Acquired Data is not a consumer reporting agency, and its products are not intended to constitute “consumer reports” under the Fair Credit Reporting Act.

Customers may not use Acquired Data products to determine an individual’s eligibility for:

• Credit;
• Loans;
• Insurance;
• Employment;
• Promotion or reassignment;
• Residential tenancy;
• Housing eligibility;
• Government benefits; or
• Any other purpose regulated by the Fair Credit Reporting Act or similar state laws.

Acquired Data does not authorize customers to use its information for background screening or regulated eligibility determinations.

9. Marketing, Calls, Text Messages, and Emails

The presence of a telephone number or email address in an Acquired Data product does not represent a guarantee that a person has consented to receive calls, automated calls, prerecorded messages, text messages, emails, or marketing communications from a purchaser.

Purchasers are responsible for complying with all applicable communications laws and regulations, including requirements concerning:

• Prior express consent;
• Prior express written consent;
• Automated calls and text messages;
• Artificial or prerecorded voice communications;
• National and state do-not-call registries;
• Entity-specific do-not-call requests;
• Email opt-outs;
• Calling-hour restrictions;
• Caller identification;
• Consent revocation;
• Recordkeeping; and
• Internal suppression lists.

Acquired Data does not provide legal advice or determine whether a purchaser has sufficient consent for a particular communication.

10. Accuracy and Availability of Data

Acquired Data obtains information from numerous third-party, public, commercial, and customer-provided sources.

Information may be:

• Incomplete;
• Incorrect;
• Duplicated;
• Outdated;
• Associated with the wrong person;
• Based on an estimate or inference;
• Changed after collection; or
• Unavailable from the original source.

Acquired Data does not guarantee that all information is complete, current, accurate, or suitable for a particular purpose.

Customers must independently verify material information before relying on it for a transaction, communication, investment, legal decision, or other significant action.

11. Data Retention

We retain information for as long as reasonably necessary to:

• Provide the Services;
• Maintain and improve our databases;
• Fulfill customer requests;
• Maintain account and transaction records;
• Protect against fraud and abuse;
• Preserve data provenance;
• Enforce agreements;
• Resolve disputes;
• Maintain suppression and privacy-choice records;
• Comply with legal obligations; and
• Establish, exercise, or defend legal claims.

Retention periods vary depending on the type of information, source, purpose, contractual requirements, and applicable law.

When information is deleted from active systems, copies may remain temporarily in backups, caches, archives, logs, or disaster-recovery systems.

We may retain limited information after an opt-out or deletion request when necessary to document and honor the request, prevent future reintroduction of the information, detect fraud, comply with law, or exercise legal rights.

12. Information Security

Acquired Data uses reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, loss, misuse, alteration, or disclosure.

These safeguards may include:

• Access controls;
• Authentication;
• Encryption where appropriate;
• Logging and monitoring;
• Vendor management;
• Data minimization;
• Employee and contractor restrictions;
• Backup procedures; and
• Incident-response measures.

No system, network, database, or transmission method is completely secure. Acquired Data cannot guarantee absolute security.

Customers are responsible for protecting their login credentials, downloads, exports, application programming interface credentials, and systems connected to the Services.

13. Cookies and Online Tracking

We and our service providers may use cookies, pixels, scripts, local storage, and similar technologies to:

• Maintain login sessions;
• Remember preferences;
• Secure accounts;
• Measure website usage;
• Diagnose errors;
• Improve performance;
• Analyze traffic;
• Prevent fraud; and
• Support marketing.

Users may be able to control certain cookies through their browser settings or our available cookie controls. Blocking cookies may prevent some Services from functioning properly.

Where required by applicable law, we will process legally recognized browser-based opt-out preference signals, such as the Global Privacy Control, as a request to opt out of the sale or sharing of browser-associated Personal Information.

14. Privacy Rights

Depending on where an individual resides, the individual may have the right to:

• Confirm whether we process their Personal Information;
• Request access to Personal Information;
• Request a copy of Personal Information;
• Request correction of inaccurate Personal Information;
• Request deletion of Personal Information;
• Opt out of the sale of Personal Information;
• Opt out of targeted advertising or certain sharing;
• Request a list of certain third parties or categories of recipients;
• Limit certain uses of sensitive Personal Information;
• Obtain data portability;
• Appeal the denial of a privacy request; and
• Exercise privacy rights without unlawful discrimination.

These rights are subject to legal definitions, exceptions, verification requirements, and limitations.

Submitting a Request

Privacy requests may be submitted through:

Privacy Request Page: https://data.acquiredcrm.com/privacy
Email: admin@acquiredcrm.com

A request should include enough information for us to reasonably identify the relevant records, such as a name, email address, telephone number, and current or prior address.

We will use information submitted with a privacy request only to verify, process, document, and respond to the request, prevent fraud, and comply with law.

We may request additional information when reasonably necessary to verify identity or authority. We will not require more information than reasonably necessary for the applicable request.

Authorized Agents

Where permitted by law, an authorized agent may submit a request on an individual’s behalf. We may require proof of authorization and may request direct confirmation from the individual.

Appeals

Where applicable, an individual may appeal a denied request by replying to our decision or emailing the privacy address listed above with the subject line “Privacy Request Appeal.”

15. Opting Out of Data Sale or Licensing

An individual may request that Acquired Data stop selling or licensing Personal Information associated with that individual by using our Privacy Request Page or contacting our privacy email address.

After processing a valid opt-out request, we may retain limited suppression information necessary to prevent the individual’s information from being reintroduced into data products.

An opt-out request may not require Acquired Data to:

• Delete all information;
• Remove information from government or public records;
• Remove information from third-party systems not controlled by Acquired Data;
• Delete information subject to a legal exception; or
• Prevent a third party from independently obtaining the same information from another source.

Our website should provide a clearly visible link labeled:

Your Privacy Choices
or
Do Not Sell or Share My Personal Information

16. California Privacy Notice

This section applies to California residents where the California Consumer Privacy Act applies to Acquired Data.

During the preceding 12 months, Acquired Data may have collected the following categories of Personal Information:

• Identifiers and contact information;
• Customer-record information;
• Commercial information;
• Internet or network activity;
• Professional or employment-related information;
• Property and real estate information;
• General location or property-location information;
• Public-record information;
• Inferences and derived information; and
• Communications and customer-service information.

We may obtain these categories from:

• Individuals;
• Customers;
• Data suppliers;
• Data licensors;
• Public records;
• Publicly accessible sources;
• Websites and directories;
• Service providers;
• Affiliates; and
• Our own matching, caching, aggregation, and enrichment activities.

We may use these categories for the business and commercial purposes described in this Privacy Policy.

Acquired Data may sell or license the following categories of Personal Information:

• Identifiers and contact information;
• Customer-record information;
• Commercial information;
• Professional or business information;
• Property and real estate information;
• Public-record information;
• General location or property-location information; and
• Inferences and derived information.

These categories may be sold or licensed to:

• Real estate professionals and businesses;
• Marketing and lead-generation businesses;
• Investors;
• Service providers;
• Data and analytics companies;
• Business customers; and
• Other purchasers contractually authorized to use the information for lawful purposes.

Acquired Data may disclose the categories described above to service providers, contractors, professional advisers, affiliates, government authorities, and transaction counterparties for business purposes.

California residents may have the right to:

• Know the categories and specific pieces of Personal Information collected;
• Know the categories of sources;
• Know the purposes for collecting, selling, or sharing information;
• Know the categories of recipients;
• Request correction;
• Request deletion;
• Opt out of sale or sharing;
• Limit certain uses of sensitive Personal Information;
• Use an authorized agent; and
• Receive equal service and pricing after exercising a privacy right, subject to lawful exceptions.

Acquired Data does not knowingly sell or share Personal Information belonging to individuals under 16 years of age.

Where required, Acquired Data will honor valid opt-out preference signals, including the Global Privacy Control.

17. Sensitive Information

The Services are not designed for the collection or use of highly sensitive Personal Information such as:

• Social Security numbers;
• Government identification numbers;
• Financial account credentials;
• Account passwords;
• Health or medical information;
• Biometric identifiers;
• Exact GPS location;
• Private communications;
• Sexual-orientation information;
• Religious-belief information; or
• Information concerning children.

Customers should not upload these categories unless Acquired Data has expressly agreed in writing to process them and the customer has established all required legal grounds and safeguards.

We may delete, restrict, quarantine, or refuse to process information that creates an unacceptable security, legal, or privacy risk.

18. Children’s Privacy

The Services are intended for businesses and adults and are not directed to children under 18.

We do not knowingly collect Personal Information directly from children under 13 or knowingly sell or share Personal Information belonging to individuals under 16.

Anyone who believes that a child’s information has been submitted to Acquired Data may contact us using the information below.

19. Third-Party Websites and Services

The Services may contain links to third-party websites, platforms, applications, or services.

Acquired Data does not control and is not responsible for the privacy, security, content, or practices of independent third parties. Users should review the privacy policies of those third parties.

20. United States Processing

Acquired Data operates from the United States. Information may be stored and processed in the United States and other jurisdictions in which our service providers operate.

Individuals accessing the Services from outside the United States acknowledge that privacy laws in the United States may differ from those in their jurisdiction.

The Services are not offered to individuals outside the United States unless Acquired Data expressly agrees otherwise.

21. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our Services, data practices, technology, legal obligations, or business operations.

We will post the updated Privacy Policy with a revised “Last Updated” date. Where required by law, we may provide additional notice of material changes.

22. Contact Acquired Data

Questions, privacy requests, complaints, and concerns may be submitted to:

Acquired Data
Trendtubes LLC
8034 252nd Street
Bellerose, NY 11426
admin@acquiredcrm.com
https://data.acquiredcrm.com/privacy