Untitled Privacy Policy

Untitled, LLC ("Untitled," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information in connection with our websites, Platform, identity resolution and data services, and other interactions with Untitled.

Our privacy practices generally fall into three contexts:

1. Direct interactions with Untitled, such as visiting our websites, requesting a demo, creating an account, participating in a trial, using the Platform, or communicating with us.
2. Client Personal Data, meaning personal information we process on behalf of clients using the Untitled Platform.
3. Untitled Personal Data, meaning personal information used in connection with our identity resolution, enrichment, audience, intent, activation, and related data services.

Our role under privacy law may differ depending on the context.

1. How This Privacy Policy Applies

Direct Interactions with Untitled

When you interact directly with Untitled, we generally determine how and why your information is processed and act as a business, controller, or similar role under applicable privacy law.

Client Personal Data

Untitled clients may provide or connect information from their websites, CRM systems, ecommerce platforms, email platforms, data warehouses, analytics systems, advertising systems, and other client-controlled sources.

Personal information included in that data is referred to as Client Personal Data.

For Client Personal Data, the client generally acts as the business or controller and Untitled acts as its service provider or processor. Untitled processes this information to provide the Platform Services on behalf of the client and in accordance with the applicable client agreement and law.

Untitled does not sell or share Client Personal Data.

Clients remain responsible for their own privacy notices, consent practices, and collection and use of personal information. Clients using the Untitled Identity Tag are required to maintain an appropriate privacy policy and consent management or cookie consent solution where the tag is deployed.

If you have a privacy request concerning information collected by an Untitled client, that client is generally the appropriate party to contact.

Untitled's processing of Client Data and Client Personal Data is addressed more comprehensively in Untitled's Platform Services Agreement.

Untitled Personal Data

Untitled provides identity resolution, enrichment, audience, intent, analytics, activation, and related data services using information that Untitled owns, licenses, receives from authorized sources, derives through permitted processing, or otherwise has the right to use.

Personal information included in these data assets and provided through our services is referred to as Untitled Personal Data.

Untitled Personal Data may be used by authorized clients for permitted marketing, sales, enrichment, audience, activation, analytics, and related business purposes, subject to applicable law and their agreements with Untitled.

Untitled's identity graph and identity resolution services are designed for United States records and U.S.-based audiences.

The licensing, permitted use, and processing of Untitled Personal Data and related data assets are addressed more comprehensively in Untitled's Platform Services Agreement.

2. Personal Information We Collect

The information we collect depends on how you interact with Untitled and which services are involved.

Information You Provide

We may collect:

• name, email address, telephone number, company, and job title;
• account, profile, login, and authentication information;
• billing and subscription information;
• information submitted through contact, demo, trial, support, or other forms;
• communications with our sales, customer success, support, or other teams; and
• other information you choose to provide.

Payment information may be processed by our payment providers. Untitled may receive related billing, transaction, and payment-status information.

Website, Device, and Platform Information

When you visit our websites or use the Platform, we and technologies operating on our behalf may collect:

• IP address;
• browser, device, and operating system information;
• approximate location derived from IP address;
• pages viewed and referring pages;
• website interactions, clicks, and form activity;
• dates, times, sessions, and event information;
• cookie, browser, device, advertising, and similar identifiers;
• marketing attribution and conversion information;
• Platform usage, integrations, API activity, and administrative actions; and
• authentication, diagnostic, performance, security, and audit logs.

We may also receive information about interactions with Untitled emails or advertisements. If you provide identifying information to Untitled, we may associate it with related website, marketing, or Platform activity.

Cookies, Pixels, Tags, and Similar Technologies

Our websites use cookies, pixels, tags, scripts, and similar technologies operated by Untitled and by analytics, advertising, social media, marketing technology, and other service providers.

These technologies may collect browser and device information, IP addresses, identifiers, website activity, form and conversion events, referring URLs, approximate location, and similar online activity.

We use these technologies to operate and secure our websites, understand usage, measure marketing and advertising performance, attribute conversions, create or measure audiences, and market Untitled products and services.

Untitled may also deploy the Untitled Identity Tag on its own websites. Information collected directly through the Identity Tag may include IP address, browser or device information, website interactions, event information, and other pseudonymous identifiers. Untitled may use its identity resolution processes and authorized data assets to associate that activity with an existing identity record where permitted by law.

Client Personal Data

Depending on the client and services used, Client Personal Data may include customer or prospect records, contact information, customer identifiers, CRM data, ecommerce or transaction information, website activity, audience or campaign information, and other information controlled by the client.

Untitled Personal Data

Depending on the service and available data, Untitled Personal Data may include:

• names and contact information;
• postal addresses and telephone numbers where offered and authorized;
• online, network, and pseudonymous identifiers;
• IP addresses and website interaction information;
• consumer, commercial, demographic, or household attributes;
• professional information such as employer, job title, department, company domain, industry, and company size;
• audience or segment information;
• contextual interests or intent topics; and
• inferences, classifications, scores, or other derived attributes.

A particular record may contain only a subset of these categories.

Untitled Personal Data does not include information regarding minors under the age of 18, sensitive medical or health information, race or ethnicity, religious beliefs, sexual orientation, precise geographic location, or those elements described as sensitive information as defined under applicable law.

Untitled may separately process account login and authentication information where necessary to operate and secure the Platform.

The restrictions above concerning Untitled Personal Data do not necessarily describe Client Personal Data independently collected and controlled by a client.

Additional restrictions governing sensitive information, regulated uses, Client Data, and Untitled Personal Data are set forth in Untitled's Platform Services Agreement.

Sources of Information

We may obtain personal information:

• directly from you;
• from Untitled clients and their authorized users;
• through Untitled-owned or client-controlled websites;
• through integrations authorized by clients;
• from service providers and advertising or analytics partners;
• from licensed commercial data providers and other authorized data sources;
• from publicly available sources where permitted by law; and
• through information generated or derived by Untitled's technology.

3. How We Use Personal Information

For personal information Untitled collects and controls directly, we may use that information to:

• operate, secure, support, develop, test, maintain, and improve our websites, Platform, and services;
• create and administer accounts;
• provide customer support and account management;
• respond to inquiries and communicate about our services;
• manage subscriptions, billing, and payments;
• market, advertise, and promote Untitled products and services, including through sales outreach, email, digital advertising, personalized communications, campaign measurement, and attribution;
• measure and analyze website, marketing, advertising, and service performance;
• personalize and improve user experiences;
• detect and prevent fraud, abuse, unauthorized access, and security incidents;
• process and honor privacy choices, opt-outs, and consumer rights requests;
• enforce agreements and protect our legal rights; and
• comply with applicable laws, regulatory requirements, and legal process.

Client Personal Data

We use Client Personal Data to provide Platform Services on behalf of our clients.

We may use de-identified information derived from use of the Platform for analytics, service improvement, system performance, support, and related purposes where permitted by the applicable client agreement and law.

Untitled Personal Data

We use Untitled Personal Data and related information to provide identity resolution, enrichment, audience, intent, analytics, segmentation, activation, API, and integration services; maintain and improve our data assets; perform quality assurance; and comply with privacy choices, legal requirements, and contractual obligations.

4. How We Disclose Personal Information

Service Providers

We use service providers for hosting, infrastructure, authentication, security, communications, analytics, payments, customer support, and other business operations.

These providers may process personal information as needed to perform services for Untitled and are subject to applicable contractual and legal requirements.

Clients and Client-Selected Destinations

We provide information to clients and their authorized users as necessary to deliver the services they have licensed.

At a client's direction, we may also transmit information or audiences to advertising platforms, CRM systems, marketing and email platforms, analytics systems, data warehouses, or other destinations selected by the client.

Advertising, Analytics, and Marketing Partners

We may disclose website, browser, device, advertising, and conversion information to analytics providers, advertising platforms, social media platforms, and marketing technology providers that help us measure activity, attribute conversions, create or measure audiences, and advertise our services.

Identity and Data Services

We may license or provide Untitled Personal Data and related information to clients authorized to use our identity resolution, enrichment, audience, and related services.

Depending on applicable law, these disclosures may be considered a sale of personal information or otherwise be subject to consumer opt-out rights.

Untitled does not provide Untitled Personal Data concerning an individual where, at the time of delivery, an applicable deletion or opt-out request prohibits that disclosure.

Other Disclosures

We may also disclose personal information:

• to professional advisors;
• to comply with law, legal process, or governmental requests;
• to protect rights, safety, security, or property;
• to investigate fraud, abuse, or security incidents;
• in connection with a merger, acquisition, financing, reorganization, or similar transaction; and
• in aggregated or de-identified form where permitted by law.

Sale, Sharing, and Targeted Advertising

Some U.S. privacy laws define "sale" and "sharing" more broadly than an exchange of information for money.

Untitled does not sell or share Client Personal Data.

Certain disclosures associated with Untitled's website advertising technologies and Untitled Personal Data may constitute a sale, sharing, or processing for targeted advertising under applicable law.

Where applicable, consumers may opt out as described below.

5. Privacy Choices

You may be able to manage certain cookies and similar technologies through our website privacy controls or through your browser settings. Blocking some technologies may affect website or Platform functionality.

You may unsubscribe from promotional emails using the unsubscribe link included in those communications. We may still send transactional, security, legal, account, or service-related messages.

Do Not Track and Global Privacy Control

There is no single generally accepted standard for traditional browser "Do Not Track" signals, and our response to those signals may vary.

Where required by law, Untitled recognizes qualifying browser or device-based opt-out preference signals, including Global Privacy Control ("GPC"), as a request to opt out of applicable sale, sharing, or targeted advertising.

A browser-based signal generally applies to the browser or device from which it is received unless applicable law requires us to associate it with a known consumer or record.

6. Automated Processing and Inferences

Certain Untitled services use algorithms, statistical methods, machine learning, or other automated processing for identity resolution, matching, enrichment, classification, audience segmentation, intent analysis, scoring, search, and analytics.

These processes may generate attributes, classifications, scores, segments, or inferences.

Untitled's services are intended for marketing, advertising, sales, enrichment, activation, analytics, and related business uses.

Untitled does not provide the Platform for determining an individual's eligibility for credit, housing, employment, insurance, healthcare, or another decision that produces legal or similarly significant effects concerning an individual.

7. Your Privacy Rights

Depending on your state of residence and applicable law, you may have the right to:

• access personal information we maintain about you;
• correct inaccurate information;
• request deletion;
• receive certain information in a portable format;
• opt out of sale or sharing;
• opt out of targeted advertising;
• opt out of certain profiling involving legally or similarly significant decisions;
• limit certain uses of sensitive personal information;
• appeal a decision concerning a privacy request; and
• exercise your privacy rights without unlawful discrimination or retaliation.

These rights are subject to applicable legal requirements and exceptions.

How to Submit a Request

You may submit a privacy request through our Consumer Privacy Request / Do Not Sell or Share My Personal Information process or by contacting us using the information at the end of this Privacy Policy.

We may take reasonable steps to verify your identity before fulfilling certain requests. Where applicable law does not permit identity verification as a condition of an opt-out request, we will not require it.

An authorized agent may submit a request where permitted by law.

Client Personal Data Requests

If your request concerns Client Personal Data controlled by an Untitled client, that client is generally responsible for responding. Untitled will assist its clients with applicable requests as required by law and our agreements.

Untitled Personal Data Requests

If your request concerns Untitled Personal Data controlled by Untitled, we will process the request in accordance with applicable law.

When an applicable deletion or opt-out request becomes effective, we will apply it to our systems and will not provide Untitled Personal Data in a manner prohibited by that request or applicable law.

8. California Privacy Disclosures

This section supplements this Privacy Policy for California residents where the California Consumer Privacy Act, as amended ("CCPA"), applies.

Categories of Personal Information

During the preceding 12 months, depending on the services and interactions involved, Untitled may have collected the following CCPA categories:

• identifiers;
• contact and account information described in California Civil Code Section 1798.80(e);
• commercial information;
• internet or other electronic network activity information;
• approximate geolocation information;
• professional or employment-related information;
• inferences; and
• sensitive personal information used for limited operational purposes, such as account login and authentication information.

The specific information included in these categories and the sources from which we obtain it are described in Section 2. Our business and commercial purposes are described in Section 3.

Personal Information Sold or Shared

Untitled does not sell or share Client Personal Data.

Depending on the applicable activity, the following categories may have been sold or shared, as those terms are defined by the CCPA, during the preceding 12 months:

• Identifiers and internet or network activity information with advertising, social media, marketing technology, and authorized client recipients for advertising measurement, attribution, audience services, identity resolution, enrichment, and activation.
• Commercial information with authorized clients and applicable client-selected destinations for identity resolution, enrichment, audience, analytics, and activation services.
• Professional or employment-related information with authorized clients for identity resolution, enrichment, marketing, sales, audience, and analytics purposes.
• Inferences with authorized clients and applicable client-selected destinations for audience, intent, enrichment, analytics, and activation services.

A sale or sharing under the CCPA may occur without an exchange of money.

Untitled does not have actual knowledge that it sells or shares personal information of consumers under 16 years of age. As a higher standard Untitled Personal Data does not include information regarding individuals under the age of 18.

Disclosures for Business Purposes

During the preceding 12 months, Untitled may have disclosed identifiers, contact and account information, commercial information, internet or network activity information, approximate geolocation information, professional information, and inferences to service providers or contractors for business purposes.

These disclosures support functions such as hosting, infrastructure, security, authentication, communications, billing, analytics, customer support, Platform operations, fraud prevention, and advertising measurement.

Sensitive Personal Information

Untitled does not use or disclose sensitive personal information for purposes of inferring characteristics about consumers where the CCPA requires a right to limit such processing.

Account login and authentication information is used for account administration, authentication, fraud prevention, and security.

California Privacy Rights

California residents may exercise applicable rights described in Section 7, including rights to access, correct, delete, and opt out of applicable sale or sharing.

California residents may also exercise applicable opt-out rights through a recognized opt-out preference signal as described in Section 5.

9. Retention and Security

Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, taking into account the type of information, our relationship with the applicable person or client, contractual requirements, security needs, and legal or regulatory obligations.

Client Personal Data is retained and deleted in accordance with the applicable client agreement and legal requirements.

We may retain limited suppression or opt-out records where needed to continue honoring privacy choices. Aggregated or de-identified information may be retained where permitted by law.

Security

Untitled maintains technical, administrative, physical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, misuse, or destruction.

These safeguards may include encryption, authentication and access controls, network security, testing, backup and recovery, and employee security practices.

Our core Platform production infrastructure and identity resolution systems are hosted in the United States.

No information system can be guaranteed to be completely secure. If you believe an Untitled account or interaction may no longer be secure, please contact us.

10. Children and International Visitors

Children and Minors

Untitled's websites, Platform, and services are designed for businesses and adult users and are not directed to children or minors.

Untitled Personal Data does not include information regarding individuals under the age of 18. Our identity resolution and data services are not intended to identify, enrich, license, or provide personal information concerning minors.

If we become aware that information concerning a minor has been processed contrary to our policies, contractual obligations, or applicable law, we will take appropriate steps to address it.

International Visitors

Untitled is headquartered in the United States. Our identity graph and identity resolution services are designed for U.S. records and U.S.-based audiences.

Our public websites may be accessed from outside the United States. If you communicate with Untitled or use an Untitled website from another country, information you provide may be processed in the United States.

Where required by law, we will apply appropriate safeguards to international transfers of personal information.

11. Third-Party Services

Our websites and Platform may link to or integrate with third-party websites, applications, advertising platforms, social networks, analytics services, marketing systems, and other services.

Untitled does not control those third parties' independent privacy practices. Their handling of information is governed by their own privacy notices and agreements.

When a client directs Untitled to transmit information to a third-party integration or destination, that third party's terms and privacy practices may govern its subsequent use of the information.

12. Changes and Contact Information

We may update this Privacy Policy to reflect changes to our services, technologies, data practices, legal requirements, or business operations. When we do, we will update the "Last Updated" date above and provide additional notice where required by law.

If you have questions about this Privacy Policy, our privacy practices, or a privacy request, contact:

Untitled, LLC
1131 Logan Street
Louisville, Kentucky 40204
United States

Email: support@getuntitled.ai

You may also exercise applicable privacy rights through our Consumer Privacy Request / Do Not Sell or Share My Personal Information process.