True Blue Analytics

Privacy Policy

Last Updated: July 23, 2025

This Privacy Policy (“Policy”) describes the information collected by or on behalf of True Blue Analytics, LLC (“True Blue,” “we,” “us,” or “our”) through our website https://trueblueanalytics.org/ (“Site”) and our online and offline data practices (collectively the “Services”) as well as how that information is used and disclosed. If you have questions or concerns about this Policy, please contact us as set forth below.

We may modify this Policy at any time. Material changes will be conspicuously posted on the Site or otherwise communicated to you. We do not ordinarily provide advance notice of a minor change.  All changes will be effective immediately upon posting to the Site.

This Policy contains State Supplemental Privacy Disclosures. If you are a California resident, please see the California Privacy Disclosure below for additional information that may apply to you. If you are a resident of Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, or Virginia, please see the State Supplemental Privacy Disclosure below for additional information that may apply to you.

This Policy does not apply to any websites, pages, or platforms operated by True Blue or its affiliates that do not have links to this Policy. This Policy does not apply to data collected from our employees or from job applicants. 

This Policy also does not apply to data related to any program, service, offering, or communication that we provide on behalf of one of our customers or clients for which we are not a data controller and not acting as a data broker. Please contact the applicable third party customer or client for information on their privacy practices.

1.       Data Broker

True Blue qualifies as a data broker under various state data broker laws and is a registered data broker in a number of states.  Our Services include buying and selling information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly with individuals (“Personal Information”).  Our designated address for receiving requests to opt out of any sale of an individual’s Personal Information is https://trueblueanalytics.org/dont-sell.   For additional information on submitting data subject requests to us, see the California Privacy Disclosure or State Supplemental Privacy Disclosure below.

2.       Information We Collect

We may collect Personal Information in connection with our Services. The Personal Information we collect falls into three categories: (1) information you provide to us, (2) information we collect through automated methods, and (3) information we collect from other sources, each further detailed below.  We will collect, use, and disclose such Personal Information pursuant to this Policy and applicable law.

Information You Provide to Us

In using our Services, you may provide us with Personal Information, including, without limitation:

·         Individual identifiers such as name, and username

·         Contact information such as mailing address, email address, postal address, and telephone number(s);

·         Business information such as job title, company name, and location;

·         Communications with us, preferences, or other Personal Information you provide to us such as any messages, opinions, and feedback that you provide to us, your user preferences (such as in receiving updates or marketing information), and other information that you share with us when you contact us directly (such as for customer support services);

Data Automatically Collected

We may use automated technologies to collect Personal Information from your computer system or mobile device when you use our Services.

We may use cookies (small text files stored on your device when you visit our Services), web beacons, pixel tags, and other tracking technologies (collectively “Tracking Technologies”) on our Sites and in other electronic communications with you. Most browsers automatically accept Tracking Technologies. To opt out from Tracking Technologies, please see Section 9.

The Tracking Technologies on our Site collect information such as:

  • IP addresses assigned to the computers and other devices you use;

  • your internet service provider;

  • device ID number;

  • approximate geographic location;

  • browser type;

  • Site pages visited;

  • websites you access before and after visiting the Site, and

  • data related to how and when you use the Site.

 

If you access our Site and Services through a mobile device, we may automatically collect Personal Information about your device, your phone number, and your approximate physical location.

 

We use Tracking Technologies to: (i) make our Site function properly, (ii) provide personalized experiences, (iii) tailor our interactions with you, (iv) provide us with valuable data and statistics about the usage and effectiveness of our Site, and (v) to help us improve our Site and Services.

reCAPTCHA. We may use and implement reCAPTCHA, a Google tool to help fight spam and misuse on our Site. Use of ReCaptcha is subject to Google’s Terms of Service and Privacy Policy.  As a result, certain Personal Information may be disclosed to Google for this purpose.

DNT Signals. Various browsers (i.e., Internet Explorer, Chrome, Firefox, Edge, etc.) allow a “do not track” (“DNT”) setting, which sends a signal to websites visited by an individual about their browser DNT setting. At this time, there is no general agreement on how companies, like us, should interpret DNT signals. Therefore, at this time our Services do not respond to “Do Not Track” signals transmitted by browsers. 

Data from Other Sources.

We obtain and may purchase Personal Information about individuals from various third-party sources within the political campaign industry, including political campaigns, fundraisers, donor data providers, email verification providers, phone validation services and other services providers.  This may include campaign information such as donation amount, communication preferences, your age (not your birthdays), and your engagement with such campaigns. We may combine that Personal Information with other data we may already have. 

3.       How We Use Your Information 

We use Personal Information that we collect for the following purposes:

As Stated or Agreed to at the Point of Collection.  We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to process and respond to your questions, inquiries, comments, or complaints. We may also use your Personal Information as otherwise requested or consented to by you.

Administration.  We use Personal Information for administrative purposes, such as to understand our users’ demographics and user preferences, troubleshoot, problems, improve the content and functionality of the Services and develop new products and services.

For Our Business Purposes. We use Personal Information that we collect to provide our customers with our services and offerings.

Business Analytics. We use Personal Information for business analytics purposes and consumer and operations research to assess the effectiveness of our Site and Services.

Advertising and Other Communications. We may use Personal Information to send you campaign information on behalf of our customers and similar communications. If you are acting in the capacity or on behalf of a customer of ours, we may use Personal Information to send you advertising materials, to notify you of new services or programs,  to notify you of changes to our website terms of use or this Policy, and for other similar communications. If you provide your email address to us, we may send you both emails about your business transactions with us and marketing emails.

To Protect Our Rights.  We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Services, or to other users of the Services. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests. 

Create Aggregated and De-Identified Data. We may process Personal Information to create deidentified and aggregated data in accordance with applicable laws. Any such deidentified and aggregated data is no longer subject to this Policy.  True Blue is the sole and exclusive owner of such de-identified and anonymized information.

4.       Disclosure of Personal Information

We may disclose Personal Information to the following categories of third parties:

Affiliates. We may disclose Personal Information to our affiliates who have a need to know the information for our business or operational purposes.

Customers: We disclose Personal Information to our customers when providing our offerings and Services.

Third Parties and/or Service Providers.  We may disclose Personal Information to third parties and/or service providers that we engage to provide our Site and Services. For example, we may disclose Personal Information to vendors to help us host and manage the Site, improve the content and functionality of the Services, troubleshoot problems with the Site, support or provide the security of the Site, append Personal Information, verify addresses, and send communications on behalf of our customers and clients.   

Government Officials / Law Enforcement.  We will cooperate with law enforcement and other governmental agencies and may disclose Personal Information:  (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, True Blue or any other party, or (iv) as otherwise appropriate.

Professional Advisors.  We may disclose Personal Information to our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to True Blue.

Subsequent Owner or Operator. We may disclose your Personal Information to a successor entity or an operator upon a merger, consolidation, acquisition, bankruptcy, dissolution, liquidation or other corporate reorganization or discussions related to the same, to a purchaser or potential purchaser of all or a portion of our assets, or pursuant to a financing arrangement or co-promotional agreement. The Personal Information we have about you may be transferred to parties to the transaction.

Other.  We may disclose Personal Information to third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

5.       Children's Information

We do not knowingly collect or solicit personal information directly from anyone under the age of thirteen (13). If you are under thirteen (13), please do not share any personal information about yourself with us through the Services. If you are a parent or guardian and become aware that your child has provided us with personal information, please contact us using one of the methods in Section 11 (Contact Us), and we will work with you to address this issue.

6.       Data Security

We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed.

ALTHOUGH WE HAVE MEASURES IN PLACE THAT ARE INTENDED TO PROTECT YOUR PERSONAL INFORMATION, NO DATA TRANSMISSION OVER THE INTERNET CAN BE 100% SECURE. THEREFORE, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION, SO PLEASE EVALUATE THE RISKS BEFORE DECIDING TO PROVIDE PERSONAL INFORMATION TO US.

7.       Retention of Personal Information

We will keep Personal Information for the period necessary to fulfill the purposes described in this Policy, unless a longer retention period is permitted or required by law. We take reasonable steps to delete the Personal Information we collect when: (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, or (3) if you ask us to delete your Personal Information, unless we determine that doing so would violate our existing legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your Personal Information if we believe it is incomplete, inaccurate, or that our continued storage of your Personal Information is contrary to our legal obligations or business objectives. When we delete your Personal Information, it will be removed from our active servers and databases; however, it may remain in our archives when it is not practical or possible to delete it.

8.       Access from Outside the United States

If you access the Services from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by in other jurisdictions. If you are located outside of the United States, please be aware that information and data we collect will be processed and stored in the United States, a jurisdiction in which the data protection and privacy laws and principles, including your data subject rights, might be different from the laws and principles of the country/region where you reside or are a citizen.

9.       Third-Party Websites.

The Site may link to, or be linked from, websites not controlled by us. We are not responsible for third parties’ privacy policies or practices. This Policy does not apply to any third-party websites or to any data that you provide to third parties, including social media sites. You should read the privacy policy for each website that you visit.  In addition, opting out of our databases does not remove you from third party databases that may have your data.  You should reach out to those third parties for that information. 

10.   Your Choices to Control Your Information

Tracking Technologies Opt-Out: You may control the use of certain Tracking Technologies. These features and options are browser and device specific and are not uniform. You may be able to disable Tracking Technologies by changing your browser settings, depending on your browser. You can usually find these settings in the options or preferences menu of your browser. You may also opt out from Cookie and Tracking Technologies using our cookie banner. If you choose to block Tracking Technologies, certain features of the Services may not work. Blocking or rejecting cookies will not stop all of the tracking described in this Policy. You cannot disable all Tracking Technologies, such as those that are essential to the functioning of the Services.

Opt-Out: For certain types of our Services, you may opt-out by: (i) contacting us according to Section 11 (Contact Us); (ii) if applicable, following opt-out instructions made available to you at the time of collection or via other communications. For example, you may opt out of receiving text messages by following the opt out instructions provided in that text message.  

11.   Contact Us

If you have questions or concerns regarding this Policy, contact us at:

privacy@trueblueanalytics.org

919 North Market Street, Suite 950, Wilmington, DE, USA, 19801

California Privacy Disclosure

Last Updated: July 23, 2025

This Section provides additional terms that apply to California Consumers. In the event of a conflict between this Section and the remainder of this Policy, this Section shall take precedence for California Consumers.  In this Section only, any capitalized terms not defined in this Policy have the meanings set forth in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act, and including its implementing regulations (the “CCPA”).

The Collection, Source, Purpose and Sharing of Your Personal Information.

Categories of Personal Information.  In the last twelve (12) months, we have collected the following categories of Personal Information:

  • Identifiers consisting of: real name, postal address,, email address, and other similar identifiers.

  • Internet Activity consisting of: browsing history, search history, and information regarding a consumer’s interaction with an internet website, or advertisement.

  • Inferences: inferences drawn from any Personal Information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

  • Professional or employment-related information: occupation or employer.

  • Sensitive Personal Information: Personal Information that reveals a consumer’s racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership.

Categories of Sources from Which Personal Information is Collected.  The categories of sources from which your Personal Information is collected are described in Section 1 (Information We Collect).

Purposes for Collecting Personal Information. We use the categories of Personal Information listed above for the business purposes as disclosed in Section 2 (How We Use Your Information).  We also use the categories of Personal Information listed above for the following business purposes expressly identified by CCPA, which fall under one or more of the following categories below:

  • Auditing related to counting ad impressions to unique visitors and auditing compliance.

  • Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.

  • Debugging to identify and repair errors that impair existing intended functionality.

  • Short-term, transient use.

  • Providing advertising and marketing services, except for cross-context behavioral advertising.

  • Undertaking internal research for technological development and demonstration.

  • Other purposes as expressly authorized by the implementing regulations of the CCPA.

Categories of Service Providers or Contractors  with Whom Personal Information is Disclosed for a Business Purpose.  In the last 12 months we have disclosed all the categories of Personal Information listed above for business purposes. The categories of Service Providers or Contractors  with whom we disclose Personal Information in the last 12 months are described above in Section 3 (Disclosure of Personal Information).

Categories of Third Parties with Whom Personal Information is Sold or Shared.  In the last 12 months we have sold all the categories of Personal Information listed above for monetary compensation to our customers. We do not share Personal Information for cross-context behavioral advertising.

We do not have any actual knowledge that we have sold or shared Personal Information of any individual under the age of 16 for monetary compensation or for cross-context behavioral advertising.

Your California Privacy Rights

California Consumers have the right to make the following requests:

·         Right to Know and Access.  You have the right to request that we disclose the following information regarding our collection and use of your Personal Information over the past 12 months.

o    The categories of Personal Information we have collected about you;

o    The categories of sources from which we collect the Personal Information about you;

o    The business or commercial purpose(s) for which the Personal Information was collected, sold, or shared;

o    The categories of Service Providers and Contractors with whom we disclose that Personal Information for a business purpose;

o    The specific pieces of Personal Information we collected about you in a format easily understandable to the average Consumer ;

o    The categories of Personal Information that we sold or shared, and the categories of third party recipients to whom it was sold or shared. 

·         Right to Delete.  You have the right to request that we delete any of your Personal Information that we collected from you and retained.

·         Right to Opt-out of “Sale” and Certain “Sharing” Practices. You have the right to opt-out of the “sale” and “sharing” of your Personal Information with third parties, as those terms are defined under CCPA. 

·         Right to Correct. You have the right to request that we correct Personal Information that we maintain about you that you can prove is inaccurate.

·         Right to Limit Use and Disclosure of Sensitive Personal Information.  In certain circumstances, a California Consumer has the right to limit the use and disclosure of Sensitive Personal Information. 

·         Right to Non-Discrimination. We will not discriminate against you for exercising any of your rights under the CCPA.

How to Exercise Your California Privacy Rights.  To exercise your California privacy rights, you may submit your request to us by contacting us at any of the following:

Via Toll-Free Phone: 1-866-I-OPT-OUT (1-866-467-8688) ext. 2245

Via Webform: https://trueblueanalytics.org/dontsellmydata

 

In addition, some browsers (like Mozilla Firefox, Duck Duck Go, and Brave) and browser extensions (such as Privacy Badger by EFF) support the Global Privacy Control (“GPC”) that can send a signal to websites you visit indicating your choice to opt-out from the sale or sharing of your data for targeted advertising. We have implemented tools such that when we detect a GPC signal, we will make reasonable efforts to treat the signal as request to opt out of selling and sharing. To learn more about the GPC, you can visit its website here. 

 

Verifiable Consumer Request.  In order to verify your request, we may require additional information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request. This information may vary depending on the Personal Information we already have. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why. We may reject or deny your request as permitted or as required by law.

We may charge a fee as permitted by the CCPA, such as to process or respond to your request if it is excessive, repetitive, manifestly unfounded, or if we believe the request is fraudulent or submitted for purposes other than exercising applicable privacy rights.

Authorized Agents. You may only make a request to exercise your rights on behalf of yourself, or a parent or legal guardian may make a request on behalf of their minor child. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity. We will also require proof of your written authorization to the agent to be your agent and to make the specific request submitted, unless the agent is subject to a Power of Attorney under California probate laws. If the agent is a Power of Attorney under California probate laws, we may require evidence of that status. 

Appeal: You may have the right to appeal our decision if we deny your request. To appeal, please contact us at the email address set out in the Contact Us section and specify what you wish to appeal. We will review and respond to your appeal in accordance with applicable law.

CCPA Data Subject Rights Received June 2024 to June 2025