Privacy policy

1. Scope

This policy explains how [LEGAL ENTITY NAME], trading as CollectiveContacts (“we”, “us”), collects and uses personal information. It covers this website and the contact database we compile and license to business customers.

We are a data broker. That means we collect personal information about people we do not have a direct relationship with, and we license it to businesses. We think you are entitled to know exactly how that works, which is what this page is for.

2. Two kinds of information

We handle two separate sets of personal information, and different rules apply to each:

• Index data. Professional contact information about people in their business capacity, which we compile from the sources listed in section 4 and license to customers. Most people in the index have never interacted with us.
• Site and customer data. Information you give us directly — when you request a list, email us, or buy something — plus basic technical data from your visit to this site.

3. What the index contains

For a person in our index we may hold:

• Name and professional title
• Employer name, business address, industry classification and headcount band
• Work email address and, where collected, a direct business telephone number
• Publicly available professional profile URLs
• Tenure in role and, where observed, a change of employer

We do not knowingly collect or sell: personal (non-business) email addresses or phone numbers, home addresses, government identifiers, financial account information, health information, precise geolocation, biometric data, or any of the categories treated as sensitive personal information under applicable law.

4. Where it comes from

Index records are assembled from at least three independent sources. Those sources include public business filings and registrations, professional and trade licensing boards, permit and inspection records, trade association and industry directories, publicly accessible company websites and professional profiles, and licensed third-party data suppliers who warrant to us that they collected the data lawfully.

We do not buy scraped data of unknown origin, and we do not collect data from sources that prohibit it in their terms.

5. Why we process it

We process index data to compile, verify and maintain a business contact database, and to license it to business customers for business-to-business sales, recruitment and marketing purposes.

We process site and customer data to answer your enquiry, deliver what you have bought, take payment, meet our legal and tax obligations, and keep the service secure.

6. Who we disclose it to

We license index data to business customers, who agree by contract to use it only for business purposes, to comply with applicable marketing and calling law, and not to resell it.

We also share information with service providers who work on our behalf — hosting, payment processing, email delivery and data verification vendors — under contracts limiting them to our instructions. And we disclose information where we are legally required to, or to establish or defend legal claims.

Under California law, our licensing of index data is a “sale” of personal information. In the twelve months before the date at the top of this page we sold the categories described in section 3 to the categories of customer described above. We do not sell or share the personal information of anyone we know to be under 16.

7. Your rights

Depending on where you live, you may have the right to:

• Know what personal information we hold about you, where we got it, and who we have disclosed it to
• Delete it
• Correct anything inaccurate
• Opt out of its sale or sharing
• Receive a portable copy of it
• Not be discriminated against for exercising any of these rights

You can use an authorised agent to make a request on your behalf. We will ask for proof of their authority.

8. How to exercise them

The fastest route for removal is the opt-out page. For any other request, email info@collectivecontacts.com or write to us at the address in section 14.

We will acknowledge within 10 business days and respond substantively within 45 calendar days, extendable once by a further 45 days where a request is complex — we will tell you if that happens. We do not charge for this.

To protect you, we need to be reasonably sure a request is genuinely yours. We will usually ask you to confirm details we already hold. We will not ask you for a government identity document.

If you are unhappy with how we have handled a request, you may complain to the California Privacy Protection Agency or to the attorney general of your state.

9. Retention

We keep index records for as long as they remain accurate and relevant, and we re-verify on a rolling 30-day cycle. Records that fail verification repeatedly are removed.

When you opt out, we delete your record. We keep a minimal suppression entry — a one-way hash of your email address — indefinitely, purely so that our sources cannot re-add you later. That entry cannot be used to contact you or to rebuild your record, and keeping it is what makes your removal permanent.

Customer and billing records are kept for [X] years to meet tax and accounting obligations.

10. Security

We encrypt data in transit and at rest, restrict access to staff who need it, log access to the index, and review our controls annually. No system is perfectly secure, but if a breach affects your personal information we will notify you and the relevant regulator as required by law.

11. Cookies

This site uses only the cookies necessary to make it work. We do not use advertising cookies and we do not permit third-party tracking on this site. [If you later add analytics, this section must be updated.]

12. Changes

If we change this policy we will update the date at the top. Where a change materially affects your rights we will give notice on this site before it takes effect.

13. Contact us

[LEGAL ENTITY NAME]
[STREET ADDRESS]
[CITY, STATE ZIP]

Privacy enquiries: info@collectivecontacts.com
Telephone: [PHONE]
California data broker registration: [REGISTRATION NUMBER]