This policy explains how LogicTree, Inc. and its EZCNAM service collect, use, and disclose personal information, and how you can exercise your privacy rights.

Data Broker Notice

EZCNAM is a service of LogicTree, Inc. LogicTree, Inc. is a data broker: we collect and sell personal information about consumers with whom we do not have a direct relationship.

LogicTree, Inc. is registered as a data broker with the Texas Secretary of State and the California Privacy Protection Agency.

LogicTree, Inc. also operates Data247 (data247.com). A privacy request submitted to either service reaches both. You do not need to submit separate requests.

B. Personal Information We Process

Categories of personal information:

Category	Examples	Source
Identifiers	Name, current and prior postal addresses, email address, telephone number, age	Data suppliers; public records
Telephone and carrier data	Subscriber name associated with a number, carrier, line type, portability and status, connection and disconnection dates, do-not-call registry status	Telecommunications data providers; federal government records
Financial identifying information	Identifying elements derived from consumer credit files, such as name, address, and telephone number; mortgage, lender, loan and home equity information	Licensed suppliers, subject to the Gramm-Leach-Bliley Act
Motor vehicle record data	Vehicle make, model, year, body style, fuel type, odometer reading and reading date, and vehicle identification number (VIN)	Licensed suppliers, subject to the Driver's Privacy Protection Act
Public record information	Property, deed, assessor and tax records, including ownership, sale and transfer history, assessed and market valuation, tax exemptions, and property characteristics; business filings and listings	Federal, state, and local government records
Demographic and household characteristics	Gender, age, estimated household income, education level, homeowner status, length of residence, marital status, single-parent status, presence, number and age range of children in the household, ethnicity	Data suppliers; modeled by us from the categories above
Commercial and lifestyle data	Purchase and interest propensity indicators, such as apparel, pets, travel, automotive, home improvement, outdoor recreation, gaming, fitness, and investment interest; charitable donor and credit card indicators	Data suppliers; modeled by us from the categories above
Device and network data	IP address and its associated city, region, postal code, approximate coordinates, and internet service provider	IP geolocation providers; submitted to us by customers
Inferences and derived data	Identity, address and household linkage identifiers; address recency and confidence scoring; wealth, home value, and alternative credit scoring	Generated by us from the categories above

Sensitive personal information. Some of the personal information we sell is treated as sensitive personal data under applicable state law, including information about ethnicity and about the presence and age of children in a household. Accordingly:

Notice: We may sell your sensitive personal data.

You may limit the use and disclosure of sensitive personal information, and opt out of its sale, as described in Sections E and F below.

C. Why We Process It

We process personal information to provide identity, contact, and location data services to business customers. Specific purposes:

• Identity verification and identity resolution
• Fraud prevention and detection
• Locating individuals in connection with debt collection, legal process, and litigation
• Skip tracing for customers who have certified a permitted purpose
• Marketing, lead generation, prospecting, list building, and audience segmentation
• Credit and risk scoring that is not regulated by the Fair Credit Reporting Act
• Do-not-call and telemarketing compliance screening
• Complying with legal and regulatory obligations and responding to legal process
• Operating, securing, and improving our services

You may opt out of the sale of your personal information, of targeted advertising, and of profiling as described in Sections E and F below.

D. Who Receives Personal Information

Categories of recipients:

• Licensed attorneys and law firms
• Licensed private investigators and investigative agencies
• Creditors, debt collection agencies, and their agents
• Telecommunications carriers, call centers, and communications service providers
• Fraud prevention and identity verification providers
• Marketing, advertising, and lead generation businesses
• Government agencies and law enforcement, in response to lawful requests
• Service providers supporting our operations, such as hosting, security, and payment processing, under contracts restricting their use of the information

Recipients of data governed by the Gramm-Leach-Bliley Act or the Driver's Privacy Protection Act must certify a permitted purpose before receiving access, are contractually restricted to that purpose, are prohibited from reselling or redisclosing the information outside that purpose, and are subject to audit and termination.

E. Your Rights

Depending on where you live, you may have some or all of the following rights. We honor this full list for every U.S. consumer, except where the law requires or permits otherwise.

• Confirmation and access — confirm whether we process your personal information, and access it.
• Correction — correct inaccuracies, taking into account the nature of the information.
• Deletion — request deletion of personal information provided by you or obtained about you.
• Portability — obtain a copy in a portable and, to the extent technically feasible, readily usable format.
• Opt out — opt out of the sale of your personal information, of targeted advertising, and of profiling in furtherance of decisions producing legal or similarly significant effects.
• Limit sensitive information — limit the use and disclosure of sensitive personal information, where applicable.
• Appeal — appeal any decision to decline a request.
• Non-discrimination — exercise these rights without discriminatory treatment.

Authorized agents. You may use an authorized agent, including a recognized universal opt-out mechanism. A parent or legal guardian may act for a child. We may verify the agent's authority and your identity.

F. How to Submit a Request

You may submit a request in either of these ways:

• Email: [email protected], with “Privacy Request” in the subject line
• Mail: LogicTree, Inc., Attn: Privacy Requests, 15 Main Street, Suite 12A, Franklin, MA 02038

To help us locate your records, include your full name, current and recent postal addresses, telephone number, and email address. We use this information only to process your request.

What happens next. We respond within 45 days. If we need more time, we may extend once by an additional 45 days, and will notify you of the extension and the reason within the first 45 days.

We must verify your identity before acting on a request. If we cannot verify you, we will tell you, and where the law requires it we will treat an unverified deletion request as a request to opt out of the sale of your personal information.

G. When We May Decline a Request

Some information we process is regulated by federal laws that limit or override state access and deletion rights:

• Information governed by the Gramm-Leach-Bliley Act, when processed in compliance with that Act
• Information governed by the Driver's Privacy Protection Act
• Information governed by the Fair Credit Reporting Act, where applicable
• Information lawfully available from federal, state, or local government records, which is generally not treated as personal information under state privacy laws

We may also retain information where necessary to comply with a legal obligation, to detect and protect against security incidents or fraudulent activity, or to establish, exercise, or defend legal claims.

Where an exemption applies, we may decline your request as to that information. If we do, we will tell you the specific provision we relied on, and we will honor your request as to all other information we hold about you.

Appeals. If we decline a request, you may appeal by emailing [email protected] with “Privacy Appeal” in the subject line, referencing the request you are appealing. We will respond in writing within 60 days, explaining our decision.

If we deny your appeal, you may complain to your state attorney general. Texas residents may file online with the Office of the Texas Attorney General at texasattorneygeneral.gov/consumer-protection/file-consumer-complaint. We will include this link in any denial we send.

H. State-Specific Information

California. LogicTree, Inc. is registered as a data broker with the California Privacy Protection Agency. California residents may also submit one deletion request to all registered data brokers through the CPPA's Delete Request and Opt-Out Platform (DROP) at cppa.ca.gov/data_brokers. We access DROP at least once every 45 days and process the requests we retrieve.

Texas. LogicTree, Inc. is registered as a data broker with the Texas Secretary of State. Texas residents may exercise the rights above under Chapter 541 of the Texas Business and Commerce Code and may complain to the Texas Attorney General.

I. Information About EZCNAM Account Holders

This section describes how we handle information about you as an EZCNAM customer or website visitor. It is separate from the consumer data described in Sections A through H.

Our registration form requires users to provide their e-mail address and other contact information. This information is kept confidential and will only be used for account verification and notifications to the email address listed on your account. We do not disclose, sell or give this information to any other companies or organizations without your consent.

All 3rd party data sent to us by our customers, including phone numbers, names, addresses, or other data, is kept private; we will not sell or disclose this data to others, nor will we use it ourselves for marketing or any other such purposes.

We occasionally use "cookies", which allows us to recognize who you are at subsequent visits to our site and to your member control panel. You can change your browser settings to accept or reject cookies.

If you have any questions regarding this policy, please contact [email protected].