PRODUCTS PRIVACY POLICY

Last Updated and Effective: 1/31/2026

This Products Privacy Policy explains how MV Digital Group LLC (and its subsidiaries and affiliates) through its CinqDI product (collectively, “CinqDI,” “we,” “us,” and “our”) obtains, utilizes, processes, and discloses Personal Information in connection with our readership and electorate persona datasets and audience insights solutions, associated products, and online tools that facilitate use of these products (collectively, “Services”). For purposes of this Products Privacy Policy, “Personal Information” means information that may identify, relate to, describe, reference, is capable of being associated with or could reasonably be linked, directly or indirectly, with you or your device.

Our Services generally operate without direct interaction with individual consumers. Instead, we rely on data, including Personal Information, obtained from third party data providers and partners that are contractually obligated to collect, and permit our use of such Personal Information, in accordance with applicable law.  Accordingly, references to “you” or “your” in this Privacy Policy refer to individuals whose Personal Information may be processed, used, or included within our data products or Services. This policy also applies to Personal Information collected and processed about paid users of our Services (“Customers”) for purposes of providing the Services.

If you have any questions about our privacy practices, please contact us as set forth in the “Contact Information” section below. If you are a resident of certain jurisdictions, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Minnesota, Maryland, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia,  (collectively, “Applicable States”), please see the additional disclosures at the end of this Privacy Policy.

For our privacy practices surrounding our website, please visit our Website Privacy Policy here.

1. How We Collect Personal Information

We collect Personal Information in a variety of ways, depending on how individuals, Customers, and partners interact with us. In most cases, we do not collect information directly from consumers, but rather obtain, derive, or generate information from trusted sources.

We may collect or receive Personal Information as follows:

• From our data partners and suppliers, including commercial data providers, publishers, and other companies that lawfully collect and license consumer data for marketing, analytics, and advertising purposes.
• From our Customers and advertising partners, who may provide pseudonymous or non-pseudonymous identifiers, device identifiers, hashed contact data, survey data, or other audience information to enable data matching, activation, analysis, modeling, or measurement.
• From publicly available sources, such as public voter registration files as well as other information lawfully made available to the public.
• Through data modeling and analytics, where we derive or infer new attributes (for example, interests and demographics) from other data points.
• From our corporate websites and communications, including information collected when business contacts visit our sites, request information, or engage with us for services.
• From service providers and technology partners who support our operations, analytics, data enrichment, or security processes.

We may combine information obtained from different sources to create, validate, and improve our Services and as discussed further below in the “How We Use Artificial Intelligence and Machine Learning” section, may use machine learning (“ML”), artificial intelligence (“AI”), generative AI, and other automated tools with human oversight (collectively “AI Tools”), to accomplish these purposes.

2. The Categories of Personal Information We May Collect

Depending on how you interact with us, we may collect the following information:

• Contact Information, such as name, address, phone number, and email address.
• Demographic Information, such as age range, and gender.
• Location Data, such as city, ZIP code, or general geographic area. We do not collect or use precise geolocation.
• Device Information, such as mobile advertising identifiers (MAIDs), IP addresses, browser type, or other pseudonymous device identifiers provided by partners.
• Other Information Provided, such as limited business contact details or information voluntarily provided by Customers or partners during business communications.
• Inferences, such as inferences drawn from any of the Personal Information identified and discussed in this Products Privacy Policy. For example, using publicly available sources and lawfully licensed data obtained from trusted partners, we may use AI Tools in limited circumstances to generate insights about race, ethnicity, citizenship and immigration status, religious beliefs, and union membership. Please refer to the “How We Use Artificial Intelligence and Machine Learning” and “Additional Information for Residents of Applicable States” sections below to learn more.

3. How We Use Personal Information

We may use your information, including with AI Tools, for the following reasons, depending on your relationship with us:

• To provide you and our Customers with our Services as requested.
• To generate insights, build audiences, and enrich datasets.
• To match information with other data or supplement your information with other data that we may obtain directly or through third parties.
• To provide and deliver our data products and audience segments to our Customers and partners.
• To operate, maintain, and improve our Services, including our data services, models, and related technology.
• To create, enhance, and validate audience segments, surveys, insights, and measurement tools.
• To respond to Customer inquiries, fulfill contractual obligations, and manage our business relationships.
• To comply with legal obligations, enforce our terms, and maintain the security and integrity of the systems our Services rely on.
• To conduct research, analytics, and quality assurance to ensure the accuracy and relevance of our Services.
• To conduct risk and security controls and monitoring.
• To detect and prevent fraud, misuse, or other prohibited activities.
• To perform identity verification and authentication.
• To support auditing, reporting, and regulatory compliance requirements.
• Exercising and defending legal claims or rights.

4. How We Disclose Personal Information

We may disclose or make available certain Personal Information that we collect, receive, or derive to the following categories of recipients and for the purposes described below.

• Customers and Advertising Partners. We may disclose Personal Information to our Customers, advertising partners, demand-side platforms (DSPs), data management platforms (DMPs), and other partners that license or activate our audience segments for advertising, analytics, or measurement purposes.
• Service Providers and Vendors. We may disclose Personal Information to service providers that perform operational or technical functions on our behalf, such as cloud hosting, data storage, analytics, modeling, auditing, security, or compliance services. These entities are contractually obligated to use the information only as necessary to provide services to us.
• Governmental, Regulatory, or Legal Requests. We may disclose information as required by applicable law, regulation, legal process, or government request, or to protect our rights, privacy, safety, or property, or that of our Customers, partners, or the public.
• Corporate Transactions. We may disclose or transfer information in connection with a merger, acquisition, restructuring, sale of assets, or other corporate transaction involving all or a portion of our business.
• At Your Direction or With Consent. We may disclose information at your direction or when you authorize us to do so.
• Aggregate or Deidentified Information. We may disclose information in an aggregated, de-identified, or other form that cannot reasonably be used to identify an individual, for research, analytics, or similar purposes.

5. Children’s Privacy

You must be 18 years or older to use our Services. Our Services are for a general audience, are not targeted to children, and we do not knowingly process Personal Information from children under 18 years of age.

6. How We Use Cookies and Similar Technology

Our Services do not directly place cookies or similar technologies on consumers’ browsers or devices for advertising purposes. Our audience segments may, however, be activated or made available to Customers, partners and platforms (such as demand-side platforms and data management platforms) that use cookies, mobile identifiers, or other technologies to deliver targeted advertising. Those partners are responsible for providing appropriate notice, honoring opt outs and obtaining consent, as pertinent, and as may be required under applicable law, for their use of such technologies.

Please visit our Website Privacy Policy here for how we may use cookies and similar technologies on our website.

7. How We Use Artificial Intelligence and Machine Learning

We use AI Tools for limited business purposes as part of our Services, including organizing and standardizing information, and generating certain inferences based on data obtained from our licensed data partners.

As described above, we may use licensed data partners and data sources to process certain categories of Personal Information (such as name, mailing address, phone number, email address, age, gender, and device information) using  AI Tools for certain activities, including identifying patterns, creating audience segments for our customers, measuring advertising effectiveness, and improving and developing our products. We implement measures designed to promote accuracy, fairness, and non-discrimination in connection with these activities.

Under limited circumstances, using publicly available sources and lawfully licensed data obtained from  trusted partners,  we may use AI Tools in to generate insights about race, ethnicity, citizenship and immigration status, religious beliefs, and union membership. You may have certain rights related to this type of processing. Please refer to the “Additional Information for Residents of Applicable States” section below to learn more.

We do not use AI Tools or process Personal Information or audience data derived from our Services to make decisions that produce legal or similarly significant effects on individuals, including decisions related to employment, credit, housing, or healthcare. Our AI and ML activities do not involve real-time tracking or profiling of identifiable individuals. However, in certain cases, our licensed data partners and customers may provide information about a user’s onsite real-time activities consistent with our Services and applicable agreements.

8. Links to Third Party Websites

We may provide links to websites and other third party content that are not owned or operated by us. The websites and third party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of these websites.

If you provide any Personal Information through a third party site, your interaction and your Personal Information will be collected by and controlled by the privacy policy of that third party site. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this Privacy Policy.

9. Interested-Based Advertising

Our Services do not directly deliver advertisements to users of our Services or consumers, or place cookies or similar technologies on individuals’ devices. However, when our audience segments are activated by our Customers or advertising partners through demand-side platforms, data management platforms, or other AdTech systems, those partners may use cookies, pixels, mobile advertising identifiers, or similar technologies to deliver and measure targeted advertising on their own websites, apps, or networks. We are not responsible for the data collection or tracking practices of these third parties, and we encourage you to review the privacy policies of the websites and advertising platforms with whom you interact to learn more about their practices and your choices.

To learn more about these practices and to exercise choices regarding interest-based advertising, you may visit the Digital Advertising Alliance’s opt out page (currently available at  http://www.aboutads.info/choices/). You can also learn more about interest-based advertising from the Network Advertising Initiative (NAI) by visiting their website (currently available at https://thenai.org/).

Some browsers offer a “Do Not Track” (“DNT”) setting. There is no consistent industry standard for interpreting DNT, so we do not respond to DNT. We do, however, honor global privacy preferences when required by law.

Please note that opting out through opt-out tools will not stop advertising entirely; you may still see advertisements that are not based on interest-based data. You may also have additional rights related to targeted advertising, as described in the section “Additional Information for Residents of Applicable States” below.

10. Information Security

We use commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in our possession against loss, theft, unauthorized use, disclosure, or modification. However, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting Personal Information over the internet. We cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting Personal Information to us, you do so at your own risk.

11. Your Marketing Preferences

We may periodically send promotional materials or notifications related to our Services. If you no longer wish to receive promotional marketing materials from us, you may opt out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from us by following the instructions included in the email or by emailing us with the subject line “Email Unsubscribe” to CinqDI Support at support@cinqdi.com.

There are certain service notifications and other non-promotional emails that you may not opt out of, such as notifications of changes to our Services or policies.

12. Additional Information for Residents of Applicable States

Depending on where you reside, you may have certain additional rights regarding your Personal Information, as discussed below in the subsection entitled, “To Exercise Rights”. This “Additional Information for Residents of Applicable States” section provides information for consumers residing in Applicable States in connection with the laws in those states (“Applicable Laws”).

Personal Information does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been deidentified or aggregated; or other information covered by certain sector-specific privacy laws, as consistent with state law. We do not reidentify Personal Information that has been deidentified.

We make available or license certain Personal Information, such as pseudonymous identifiers and audience segments, to our Customers and advertising partners, who may use that information to deliver online advertisements to individuals’.  This activity may be considered “sharing,” “selling,” or “targeted advertising” in Applicable States under Applicable Laws. This Section provides details about the categories of Personal Information of consumers in Applicable States that we have collected, disclosed, processed for purposes of targeted advertising, “shared,” or “sold” during the last 12 months, as well as the rights consumers have under Applicable Laws.

Categories of Personal Information Collected, Disclosed, “Shared”, “Sold”, or Processed for Targeted Advertising: 

The categories of Personal Information that we, under Applicable Laws, have collected, disclosed, “shared,” processed for purposes of targeted advertising, or “sold” in the past 12 months are listed below, along with the purposes for processing and the categories of third parties to whom each category of Personal Information was disclosed, “shared,” “sold,” or processed for the purpose of targeted advertising. Depending on how you interact with us, we may not have processed Personal Information about you for each (or any) of these purposes.

Additionally, we do not knowingly “share” or “sell” Personal Information of minors under 18 years of age.

Category of Personal Information Collected	Categories of Parties to Whom Personal Information Is Disclosed	Categories of Third Parties to Whom Personal Information is “Sold” or “Shared”	“Sold” or Processed for Targeted Advertising, depending on Applicable Law
Identifiers, such as hashed email addresses, pseudonymous IDs, IP addresses, and device identifiers	Service providers that support data processing, cloud hosting, analytics, auditing, and compliance operations.	Advertising technology partners, demand-side platforms (DSPs), data management platforms (DMPs), and Customers who license audience segments.	Yes
Personal information, as defined in the California Customer Records law, such as contact identifiers (in pseudonymized or hashed form)	Service providers assisting with operational, security, and client management functions.	AdTech partners and Customers who activate audience segments based on pseudonymous identifiers.	Yes
Characteristics of protected classifications under California or federal law, such as age range or gender (but not gender identity), as inferred or modeled attributes	Service providers assisting with data modeling, analytics, and quality assurance.	AdTech partners and Customers who license or activate audience segments containing demographic attributes.	Yes
Commercial information, such as purchase history  or product category interest.	Service providers assisting with analytics, modeling, and client reporting.	AdTech partners, DSPs, and Customers using commercial-interest segments for targeted advertising.	Yes
Biometric information	Not collected.	Not applicable.	N/A
Internet or network activity information, such as browser type, device type, IP Address, operating system, and engagement data (received from Customers and/or partners)	Service providers that support analytics, data matching, and measurement functions.	AdTech partners and platforms that use pseudonymous identifiers for ad activation and measurement.	Yes
Geolocation data, such as approximate location (e.g., ZIP code or census block group)	Service providers supporting analytics and geographic modeling.	AdTech partners and Customers who use geographic-based audience segments for advertising or analytics.	Yes
Audio, electronic, visual, or similar information	Not collected for our data products; may be processed for limited operational or client-support purposes only.	N/A	N/A
Professional or employment-related information, such as industry, job function, or business role (if used in B2B audience segments)	Service providers supporting analytics, modeling, and client relationship management.	AdTech partners and Customers who license professional or B2B audience segments.	Yes (if used in B2B advertising)
Other Information Provided, such as limited business contact details or communications provided by Customers, partners, or vendors in connection with our business operations.	Service providers supporting client relationship management, security, or operational processes.	N/A	Yes
Personal Information obtained from self–reported sources, publicly available sources, and surveys.	Service providers supporting data modeling, validation, and quality assurance.	AdTech partners, DSPs, and Customers who license or activate inferences-based audience segments for targeted advertising or analytics.	Yes
Inferences, drawn from any of the Personal Information above to create profiles or audience segments reflecting likely interests, preferences, or characteristics, including race, ethnicity, citizenship and immigration status, religious beliefs, and union membership.	Service providers supporting data modeling, validation, and quality assurance.	AdTech partners, DSPs, and Customers who license or activate inferences-based audience segments for targeted advertising or analytics.	Yes

Please note that we may process Personal Information in each of the above categories in order to protect ours and others’ rights, and/or to complete a merger or sale of assets or other corporate transaction.

Under Applicable Law, “sale” and “share” do not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other similar transaction involving all or any portion of our business.

Sensitive Personal Information

We do not process ‘sensitive’ Personal Information, as defined by Applicable Law, for purposes other than those that may involve publicly available information lawfully obtained by our trusted partners, those described in the “How We Use Artificial Intelligence and Machine Learning” section of this Privacy Policy, or as otherwise permitted by Applicable Law (such as to provide the Services and for security purposes).

Data Retention

We will retain your Personal Information for the period necessary and proportionate to fulfill the purpose(s) for which the Personal Information was collected or processed as outlined in this Section unless a longer retention period is required or allowed by law.

Purposes

We may use this Personal Information, including with AI Tools, for the following purposes, including commercial purposes:

• To operate, manage, and maintain our business, systems, and infrastructure.
• To provide our products and Services, including delivering data products and audience segments to our Customers and partners.
• To respond to requests, inquiries, and questions from Customers, partners, or individuals.
• To accomplish our business purposes and objectives, including:
• Developing, improving, and maintaining our data services, models, and related technology.
• Creating, enhancing, and validating audience segments, surveys, insights, and measurement tools.
• Conducting research, analytics, and data analysis to ensure accuracy and relevance.
• Performing quality and safety assurance measures.
• Conducting risk and security controls and monitoring.
• Detecting and preventing fraud, misuse, or other prohibited activities.
• Performing identity verification and authentication.
• Carrying out accounting, auditing, and other internal business functions.
• Complying with applicable laws, legal processes, and internal policies.
• Maintaining business records and documentation.
• Exercising and defending legal claims or rights.

Depending on how you interact with us, we may not have used Personal Information collected about you for each (or any) of these purposes.

Sources of Personal Information

We collect Personal Information from a variety of sources, as permitted by applicable law, including from our data partners and suppliers, Customers and advertising partners, publicly available sources, service providers, and through derived or modeled data created using analytics. All sources of Personal Information collected are noted in the “How We Collect Personal Information” and “The Categories of Personal Information We May Collect” sections above.

Your Privacy Rights Under Applicable Laws

If you are a resident of an Applicable State, you may have the following rights with respect to any information about you that constitutes Personal Information.

We are required by law to verify your identity in connection with certain requests in order to prevent unauthorized access of your data. Failure to verify your identity may result in your request not being processed. Where required by Applicable Law, we will notify you if we deny your request to know/access, deletion, and/or correction and notify you of the reasons we are unable to honor your request and any available appeal processes available to you.

Right to Know and Access Personal Information: You may request to access the following information we have collected and maintain about you:

• The specific pieces of Personal Information we collected about you;
• The categories of Personal Information we collected about you and the categories of sources;
• The business or commercial purpose for collecting, disclosing, or selling Personal Information about you; and,
• The categories of Personal Information about you that we sold, shared, or otherwise disclosed and the categories of third parties (or, depending on your state of residence, a list of specific third parties) to whom we sold, shared, or otherwise disclosed that Personal Information.

Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

Deletion of Personal Information: You may request that we delete your Personal Information. Depending on the scope of your request, we may refrain from granting your request, as permitted by Applicable Law. For example, we may be legally required to retain your Personal Information in our business records. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

Right to Process and Limit the Use of Sensitive Personal Information:  You have the right to request that we limit our processing and disclosure of “sensitive” Personal Information to what is necessary to provide the Services and as otherwise permitted by Applicable Law (including when such information is obtained from publicly available sources or licensed data partners responsible for obtaining applicable consent).

Opt Out of “Sale”, “Shares”, and Targeted Advertising: Depending on the state you reside in, you have the right to opt out of the “sale”/“share”/targeted advertising (cross-context behavioral advertising) of your data. We honor alternative opt out signals, such as the GPC. We process opt out preference signals in a frictionless manner.

Correction of Inaccurate Personal Information: You have a right to request the correction of inaccurate Personal Information that we may have on file about you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

Non-Discrimination: You have the right to be free from unlawful discrimination for exercising their above-listed rights under Applicable Law.

Right to Appeal: Depending on your state of residence, you may have the right to request an appeal of a denied consumer request. Please see below for how to submit an appeal.

Authorized Agent

If you reside in an Applicable State, you may have the right to submit a request through an authorized agent. If you are an authorized agent acting on behalf of a consumer to exercise a privacy right discussed in this section, you must be able to demonstrate that you have the requisite authorization to act on behalf of the consumer. We may also contact the consumer directly to verify his or her own identity and that the consumer granted you authorization to act on their behalf as an authorized agent. An authorized agent may also be permitted to act on behalf of a consumer in order to exercise certain opt-out rights.

If you are an authorized agent trying to exercise rights on behalf of a consumer, please submit a request via the linked form here and select the option for “Authorized Agent” under requestor type. We may request supporting verification information, which should include proof that you have the consumer’s authorization to act and to prove and verify your identity.

To Exercise Rights

To exercise your Right to Opt Out of “Sales” and/or “Shares”, please visit our Privacy Center. You may also click on the “Your Privacy Choices” link located in the footer of our website (Cinqdi.com) and follow the instructions to exercise these rights (including the right to Limit the Use of Sensitive Personal Information). This link may only appear where such rights are available under applicable law.

In order to exercise your other rights described above, please send an email [suppport@cinqdi.com] or submit a request through the linked form here. Authorized agents may submit requests through the linked form. Additionally, we may need to obtain information about you or your specific request in order to verify your identity and respond.

13. Additional Information for Nevada Residents

Nevada residents have certain rights with respect to their covered information. We have provided information on the categories of covered information collected and the categories of third parties with whom this covered information may be disclosed above, as well as above in the “How We Collect Personal Information,” “The Categories of Personal Information We May Collect,” “How We Use Your Personal Information,” and “How We Disclose Personal Information” sections of this Privacy Policy.

If you would like to make a request to review and request changes to any of the covered information that we may have collected about you, please email us at [suppport@cinqdi.com] and specify that you are a Nevada resident in your email.

If you would like to make a request to opt out of the sale, as defined by Nevada law, of covered information, please submit a request at [Your Privacy Choices].

We are required by law to verify both the authenticity of the request and your identity prior to honoring your request. Failure to verify your identity may result in your request not being processed.

14. Information For Texas Residents and Metrics for California Related to Data Broker Activities

 

1. Information for Texas Residents 

The entity maintaining this website is a data broker under Texas law. To conduct business in Texas, a data broker must register with the Texas Secretary of State (Texas SOS). Information about data broker registrants is available on the Texas SOS website.

1. Annual Data Request Metrics for California

As of 2026, CinqDI is a registered data broker in California. As part of its registration requirements, CinqDI must compile and disclose information regarding their compliance with consumer requests under the CCPA for the previous calendar year. Please see the table below for information about the reporting period of January 1, 2025 – December 31, 2025.

Type of Request	Requests Received	Complied with (in whole or in part)	Denied	Median Response Time (days)	Mean Response Time (days)
Request to Delete Personal Information	0	Not applicable	0	Not applicable	Not applicable
Request to Access Personal Information	0	Not applicable	0	Not applicable	Not applicable
Right to Know What Personal Information is Sold or Shared	0	Not applicable	0	Not applicable	Not applicable
Right to Opt Out of Sale or Share of Personal Information	0	Not applicable	0	Not applicable	Not applicable
Right to Limit Use and Disclosure of Sensitive Personal Information	0	Not applicable	0	Not applicable	Not applicable

15. International Data Transfers

We are based in the United States. Any information you provide to us through use of the Services may be stored and processed, transferred between, and accessed from the United States and other countries which may not guarantee the same level of protection of Personal Information as the one in which you reside. We may need to send your Personal Information overseas as part of our normal business operations. Provided the data protection laws of these other countries differ from those in the United States, please be assured that we take reasonable steps to protect your privacy.

16. Changes to Our Privacy Policy

This Privacy Policy may be amended from time to time. Any changes will be posted on this page. We will notify you of any material changes by, as applicable, placing a prominent notice on our Websites or otherwise as legally required.

17. Contact Information

Questions about our Privacy Policy may be directed to CinqDI Support at support@cinqdi.com.