Privacy Policy

The Wheelhouse (“WH” “we,” “our,” or “us”) respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use, share, and safeguard your information. This Privacy Policy applies to individuals who access this website, (“Site”) and any of our online and offline services and business interactions (collectively, “Services”).

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically.

This Privacy Policy covers the following topics:

1. Personal Data We Collect
2. How We Use Your Personal Data
3. How We Share Your Personal Data
4. Data Broker Disclosure
5. Cookies and Other Tracking Technologies
6. Universal Opt-Out Mechanisms
7. Security
8. Third-Party Links
9. Children’s Privacy
10. Notice to California Residents
11. Accessibility
12. How to Contact Us

Personal Data We Collect

We collect personal data from you through your use of the Site and Services. Personal data is information that is linked or reasonably linkable to an identified or identifiable individual. We collect the following types of personal data:

Personal Data You Provide

Depending on how you interact with our Site and Services, we will collect the following personal data that you voluntarily provide to us for the following purposes:

• Contact Us. If you contact us, you will provide us with your contact information (for example, your name, email address, and telephone number), and any other information you choose to provide.
• Sign Up for Email. If you sign up to receive emails from us, you will provide us with your email address. To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails or contact us at privacy@thewheelhouse.net.
• Marketing. Subject to applicable law, we may use your contact information to market our Services to you.
• Careers. If you apply for a job with us, you will provide us with your contact information and employment information.

Personal Data as You Navigate Our Site

We automatically collect certain personal data through your use of our Site and our use of cookies and other tracking technologies, such as the following:

• Usage Information. For example, the pages on the Site you access, the frequency of access, and what you click on while on the Site.
• Device Information. For example, hardware model, operating system, application version number, and browser.
• Mobile Device Information. Aggregated information about whether the Site are accessed via a mobile device or tablet, the device type, and the carrier.
• Location Information. Approximate location information from visitors to the Site on a city-regional basis.

To learn more about how we use cookies and to manage your cookie settings, please see the “Cookies and Other Tracking Technologies” section.

Personal Data We Collect About You from Other Sources

Additionally, we may receive personal data about you from other sources. This includes our advertising and analytics partners, third-party data providers, identity resolution and data enrichment providers, public databases, and commercially available sources.

How We Use Your Personal Data

In addition to the purposes stated above, we may use your personal data in accordance with applicable law such as to:

• Maintain and improve our Site and Services;
• Provide our Services (including audience development and segmentation, data enrichment, cross-channel targeted advertising, campaign execution and activation);
• Protect the security and integrity of our Site and Services;
• Investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, and to otherwise fulfill our legal obligations;
• Monitor compliance with and enforce this Privacy Policy and any applicable agreements and policies;
• Defend our legal rights and the rights of others;
• Better provide customer support;
• Fulfill any other purposes for which you provide it;
• For any purpose that is reasonably necessary to or compatible with the original purpose for which we collected the personal data as disclosed to you; and
• Comply with applicable law.

How We Share Your Personal Data

We may share the personal data that we collect about you in the following ways:

• With vendors who perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, and analysis) and affiliates and business partners who assist us in providing our Services (e.g., campaign activation, contracted services);
• To the extent that we are required to do so by law;
• In connection with any legal proceedings or prospective legal proceedings;
• To establish, exercise, or defend our or a third party’s legal rights, including providing information to others for the purposes of fraud prevention;
• With any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal data;
• With any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding, or in preparation for any of these events;
• With any other person or entity where you consent to the disclosure; and
• For any other purpose disclosed by us when you provide the personal data or for any other purpose we deem necessary, including to protect the health or safety of others.

Data Broker Disclosure

We may collect and process personal information obtained from third parties about individuals with whom we do not have a direct relationship. As we do not have a direct relationship with all individuals whose data we process, we rely on third-party data providers and partners to obtain and process personal information in connection with our marketing and data services.

Cookies and Other Tracking Technologies

Like many other companies, we use cookies and other tracking technologies (collectively, “Cookies”). Cookies are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets). We set some Cookies ourselves, while separate entities set other Cookies.

When you first visit our Site, you may be presented with a banner which offers you choices about whether to accept or reject cookies or tracking technologies of different types. You can also block Cookies by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies, including essential Cookies, you may not be able to access all or parts of the Sites.

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org or www.allaboutcookies.org. You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

Please note these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.

Google Analytics

Depending on the Site you visit, we may use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies to help us analyze how users interact with a site, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here.

Other Types of Collecting Activities

Depending on the Site you visit, we may use Cookies third-party vendors provide to collect information on user behavior (e.g., screens and pages visited, buttons and links clicked, limited information entered, and user taps and mouse movements). This information enables us to monitor and improve the user experience.

Universal Opt-Out Mechanisms

The Site does not recognize the Global Privacy Control (“GPC”) signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, the Site will not treat that as a valid request to opt out. To opt out of the selling or sharing of your personal data, please email us at privacy@thewheelhouse.net or use Your Privacy Choices.

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

Security

We maintain commercially reasonable security measures to protect the personal data we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.

Third-Party Links

The Site may contain links that will let you leave the Site and access another website. Linked websites are not under our control. We accept no responsibility or liability for these other websites.

Children’s Privacy

The Site and Services are not intended for individuals under 18 years of age. We do not knowingly collect, use, or disclose personal data from users under 18.

Notice to California Residents

The California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, de-identified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Notice to California Residents” section, we will refer to this information as “Personal Information.”

Notice at Collection of Personal Information

We currently collect and, in the 12 months prior to the Last Updated date of this Privacy Policy, have collected the following categories of Personal Information:

• Identifiers (name, email address, postal address, telephone number, IP address, device identifiers, household identifiers)
• Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias)
• Employment data (occupation, industry, and other employment data)
• Internet or other electronic network activity information (browsing history; search history; engagement data, and other information regarding a consumer’s interaction with a website, application or advertisement)
• Geolocation data (approximate location derived from an IP address)
• Inferences drawn from the above and other information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

We do not collect all categories of Personal Information from each source.

In addition to the purposes stated above in the section “How We Use Your Personal Data,” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

• Identity resolution. We enable our affiliates and business partners to match client-provided identifiers to additional contact fields.
• Contact enrichment. We work with data aggregators like credit reporting agencies to enhance incomplete contact records with verified, missing details.
• Targeted advertising. We facilitate advertising platforms and other business partners in targeted advertising and campaign deployment on behalf of clients.
• Audience insights. We share information with analytics providers to receive analytics and reporting related to campaign performance and audience insights.

Sale, Sharing, and Disclosure of Personal Information

The CCPA and CPRA give California residents the right to limit the selling or sharing of their personal information. We engage in online activities that constitutes a sale or a share of Personal Information under California law. This may include showing consumers advertisements on other websites. The following table identifies the categories of Personal Information that we sold or shared to third parties in the 12 months preceding the Last Updated date of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:

We do not knowingly collect, sell, or share the Personal Information of consumers under 18 years of age. We do not use sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.

Retention of Personal Information

We generally retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us. Otherwise, active campaign data is retained for up to 90 days, and is then archived, along with data related to reporting, analytics, and billing, for up to 18 months, after which both categories of data are deleted.

Your Rights

If you are a California resident, you have the following rights with respect to your Personal Information:

1. The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
2. The right to delete Personal Information that we collected from you, subject to certain exceptions;
3. The right to correct inaccurate Personal Information that we maintain about you;
4. If we sell or share Personal Information, the right to opt out of the sale or sharing;
5. If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
6. The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

How to Submit a Request to Know, Delete, and/or Correct

You may submit a request to access, delete, and/or correct your personal information by emailing us at privacy@thewheelhouse.net or by calling us toll free at (888) 417-4284

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

Right to Opt Out of Sale or Sharing of Personal Information

If you are a California resident, you have the right to direct us to stop selling or sharing your Personal Information.

You may submit a request to opt out of sales or sharing by submitting a request on Your Privacy Choices. If you have enabled privacy controls on your browser (such as a plugin), we may not treat that as a valid request to opt out. Please see the “Universal Opt-Out Mechanisms” section above for more information.

Shine the Light Law

If you are a California resident and have an established business relationship with us, you may request that we do not disclose your personal information to third parties for the third parties’ own direct marketing purposes (as those terms are defined in California Civil Code § 1798.83). You may submit such a request by emailing us at privacy@thewheelhouse.net.

Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please email us at privacy@thewheelhouse.net.

How to Contact Us

To contact us for questions or concerns about our privacy policies or practices, please email privacy@thewheelhouse.net.