5X5 Consumer Data Privacy Notice

Your Privacy Rights

Effective Date: March 4, 2025

This Privacy Policy describes the types of information gathered by 5×5 US, LLC. (“Five by Five,” “our,” “us” or “we”) in the process of providing data products and data-related services to our customers (“Members”), our tag/pixel (“Pixel”), our AI Models (as defined below) and the data, information, tools, functionality, updates, and similar materials (collectively, the “Service”), how we use it, with whom the information may be shared, what choices are available to you regarding collection, use, and distribution of information, and our efforts to protect the information provided to us through the Service. For purposes of this Privacy Policy, “you” and “your” means you as an individual whose information we have gathered through the Services. This Privacy Policy does not apply to you if you are a visitor to our website, a representative of a Member or other entity with which we engage, or a job applicant – please visit https://5x5data.com/privacy-and-security/ for more details about our processing of such information.

It is important that you take the time to read this Privacy Policy to appreciate how we gather and use your personal information (“PI”) and understand your privacy rights and choices.

About Five by Five – Our Members and Our Products

In providing the Service, we operate as a data aggregator and broker. We enter into written agreements (“Data Participation Agreements”) with our Members, who may contribute PI of individuals for lead enrichment, targeting of advertising and audiences, sales, talent acquisition, identity verification, and fraud detection/prevention (“Use Cases”). Your PI may be included in such contributions. Our Members pay a fee for access to our data products (“Products”) through the Service. Some Members contribute PI that they collect which we use in providing them the Products they request and for the development and licensing of our Products and Service to other Members, including by combining it with PI received from other Members. Those contributions contain PI collected by the Member through various means, including by use of our Pixel, which may be placed on the Member’s website(s) or in email messages to individuals.

The Member chooses what PI to contribute; PI that is typically found in such contributions is described below. We contractually prohibit our Members from providing certain information, such as information about children under 13 and individuals outside the United States.

While our Members are the primary contributors of PI that we use in the Products and Services, we also collect PI from other sources, including directly from you if you visit our website or open one of our commercial emails, as further discussed below.

You may opt out of having your PI included in the Products or Services here, https://5x5data.com/opt-out-preferences/. We will retain PI for as long as needed to provide the Service to our Members or as otherwise authorized, as directed or permitted by our Members, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

  1. What PI Is Collected?

A. PI Collected from Members: Members collect a wide range of PI based upon the nature of their business and their Use Case(s). Five by Five collects, and have in the past 12 months collected, the following PI about you from Members (as categorized by the California Consumer Privacy Act of 2018, as amended (the “CCPA”)), with sensitive personal information as defined under the CCPA denoted with a *:

  1. Identifiers such as name, mailing address (both personal and professional), email address (both personal and professional), hashed emails, phone number (both personal and professional), whether the phone number(s) and email address(es) are still valid, IP address, unique personal identifier (assigned by the Member);
  2. Personal information categories identified in the California customer records statute such as your name, mailing address (both personal and professional), email address (both personal and professional), phone number (both personal and professional), education, and employment history;
  3. Characteristics of protected classifications, namely your gender and age/date of birth;
  4. Professional or employment information, including, but not limited to your current employer, title, level of seniority, employment history, publicly available education information (such as institutions attended, degrees obtained, and majors), and information about your current employer;
  5. Internet and other network activity such as browsing history, search history, and information regarding your interaction with an internet website, advertisement, cookie, or our Pixel, JSON headers (device and browser level data), timestamps, and other visible traffic in the Member’s network;
  6. Geolocation data*, namely, latitude and longitude data about you is collected as part of digital ad placement data that Five by Five receives from its Members;
  7. Inferences drawn from any of the information identified above including behavioral and intent data (i.e., comparison shopping, ready to purchase); and
  8. Any other information Members choose to contribute to us, such as your marital status, family information, and socioeconomic status.

In addition, in the last 12 months, we may have collected your ethnicity*.

B. PI We Collect Directly: We collect certain PI about you when you access our website, when you contact us or submit a request through our website, or otherwise when you submit such PI, including:

  1. Identifiers that you provide directly, such as your first and last name and business and personal email address, such as by completing a webform on our website expressing interest in our business;
  2. Personal information categories identified in the California customer records statute such as your first and last name, and business and personal email address;
  3. Identifiers collected through use of the website and our Pixel, such as unique online or device identifiers, IP address, device or session IDs, and information regarding your system configuration (operating system and version); and
  4. Internet and other network activity such as browsing history, search history, and information regarding an Individual’s interaction with an internet website, advertisement, cookie, or our Pixel, JSON headers (device and browser level data), and timestamps.

C. Automatically Collected Information. Five by Five may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. Information typically collected in this manner includes, but is not limited to, IP address, the type of device used and its operating system, browser information, the pages accessed most frequently, how pages and features are used, time spent on a page, search terms entered, and similar data. If any information automatically collected from you through your use of our website which does not otherwise identify you is paired to any of your PI we will treat that information as if it were PI.

For more information on automatically collected information, please refer to “How Do We Use Cookies and Other Network Technologies”

D. Aggregate Information. We may deidentify or anonymize your information such that it cannot reasonably be used to infer information about you or otherwise be linked to you (“deidentified information”) (or we may collect information that has already been deidentified/anonymized) and we may use such deidentified information for any purpose. To the extent we possess or process any deidentified information, we will maintain and use such information in deidentified/anonymized form and not attempt to re-identify the information, except as permitted by applicable law.

2. How Do We Use the PI?

A. We use your PI contributed to our Service by Members for the following purposes:

  1. Provide Services to Our Members. We use the PI to provide the Service that we offer to our Members, including, but not limited to developing our Products for our Members’ individual Use Cases.
  2. Internal Uses. We may use PI to develop and improve the Service and the content of the Products, prevent security issues and protect the confidentiality, availability, and integrity of our systems, enforce Members’ obligations, provide Member support, perform analytics on the use of the Service, comply with legal obligations, and identify functionality issues.
  3. AI Training. We may use PI to train, develop, and improve the artificial intelligence models and algorithms that we have created or otherwise have rights to (collectively, “AI Models”). Our AI Models contribute to the Service by matching similar records and collating them into a single identity.
  4. Product and Service Development. We may also use PI to develop new products and services.
3. Do We Disclose Your PI?

We may disclose your PI to third parties, including in the following situations: (a) as may be required by law or as we think necessary to protect our organization or others from injury (e.g., in response to a court order, subpoena, or a law enforcement agency request); (b) with persons or organizations with whom we contract to perform services for us, including the performance, or development of, aspects of the Service and other internal operations or business activities of 5×5 US, LLC;  (c) to Members as part of the Services;  (d) with our affiliates or others within our corporate group; (e) with partner organizations; and (f) with professional advisors, such as auditors, law firms or accounting firms.

We may also share deidentified information with others, including affiliated and non-affiliated entities.

Finally, we may transfer PI to another party (affiliated or non-affiliated), or our successor-in-interest, in relation to, or in the event of, a merger, acquisition, sale of all or substantially all of our assets, reorganization, bankruptcy, or other change of control. After such disclosure or transfer, the third party or successor in interest may use the PI in accordance with this Privacy Policy.

We do not knowingly “sell” or “share” (as those terms are defined under the CCPA”) PI of residents under 16 years of age. However, we do sell and share certain categories of PI and, in the preceding 12 months, we have sold and shared the following categories of PI about California residents:

Category of Personal Information Sold or Shared Categories of Recipients Business Purpose
Identifiers such as name, mailing address (both personal and professional), email address (both personal and professional), hashed emails, phone number (both personal and professional), whether the phone number(s) and email address(es) are still valid, IP address, unique personal identifier (assigned by the Member) Both Members Provision of Services
Personal information categories identified in the California customer records statute such as your name, mailing address (both personal and professional), email address (both personal and professional), phone number (both personal and professional), education, and employment history Both Members Provision of Services
Professional or employment information, including, but not limited to your current employer, title, level of seniority, employment history, publicly available education information (such as institutions attended, degrees obtained, and majors), and information about your current employer Both Members Provision of Services
Internet and other network activity such as browsing history, search history, and information regarding an Individual’s interaction with an internet website, advertisement, cookie, or our Pixel, JSON headers (device and browser level data), timestamps, and other visible traffic in the Member’s network Both Members Provision of Services
Geolocation data*, namely, latitude and longitude data about you is collected as part of digital ad placement data that Five by Five receives from its Members Both Members Provision of Services
Inferences drawn from any of the information identified above including behavioral and intent data* (i.e., comparison shopping, ready to purchase) Both Members Provision of Services
Characteristics of protected classifications such as gender, age, date of birth Both Members Provision of Services
Any other information Members choose to contribute to us, such as your marital status, family information, and socioeconomic status Both Members Provision of Services

 

In addition, in the past 12 months, we have sold or shared your ethnicity data*.

4. How Can You Exercise Your Privacy Rights?

If you would like to opt-out of receiving any promotional email that we send you, please click on the unsubscribe link at the bottom of any such email.

We do not control Members’ collection or use of your PI including, but not limited to, serving interest-based advertising. However, our Members may provide you with ways to choose not to have your PI collected or used in this way. You can opt out of receiving targeted ads from Members who are part of the Network Advertising Initiative (“NAI”) on the NAI’s website.

To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections, or removing PI.

5. How We Store, Protect, and Retain Your PI

A. After receiving PI, we will store it on our servers for future use. We have physical, electronic, and managerial procedures in place to safeguard, help prevent unauthorized access, maintain data security, and correctly use the PI we collect directly or collect from Members. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, we cannot ensure or warrant the security of any PI that is transmitted to or received by us or that we store on our or our service providers’ systems. Similarly, our Members access and use the Products, which potentially includes access to your PI, and we cannot ensure or warrant the security or handling by our Members of such PI, whether on the Members’ systems, or as part of their respective Use Cases.

B. If a Member is accessing the Service from outside of the United States, or if you are accessing the Site from outside of the United States such connection will be through and to servers located in the United States, and the PI provided will be securely stored in our servers and internal systems located within the United States.

C. We store your PI until the earlier of:

  1. it no longer being necessary to fulfill our business purposes or the purposes for which it was provided. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security, and integrity, or protect ourselves, including our rights, property, or products.
  2. our receipt of your request to opt out or delete your PI. We will use commercially reasonable efforts to remove the affected PI from our Products and/or system as soon as practicable.
6. How We Use Cookies and Other Network Technologies

A. We, our service providers, and our Members, may also use “pixel tags,” “web beacons,” “clear GIFs,” or similar means (collectively, “Pixel Tags”) in connection with some Five by Five Products and the Service, including the Pixel, on web pages and email messages formatted to, among other things, compile aggregate statistics and response rates. A Pixel Tag is an electronic image, often a single pixel (1×1), that is ordinarily not visible to website visitors and may be associated with cookies on visitors’ devices. Pixel Tags allow us to count users who have visited certain pages, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in formatted email messages, Pixel Tags can inform the sender whether and when an email has been opened.

B. As you use the internet, you leave a trail of electronic information at each website you visit. This information is sometimes referred to as “clickstream data” and can be collected and stored by a website’s server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to our website or a website of a Member. Clickstream data may be used to determine how much time visitors spend on each page of a website, how visitors navigate through a website, and how those web pages may be tailored to better meet the needs of visitors.

7. Collection of PI by Others

Our website may provide links to certain third-party websites. When you leave our website, please check the privacy policies of these other websites to learn how they collect, use, store, and share PI. We are not responsible for the privacy practices of such other sites and/or any third parties.

8. General Privacy Rights

Depending on where you reside, you may have the rights listed below in relation to PI that we have collected about you. However, these rights are not absolute and, in certain cases, we may decline your request as permitted by law.

A. Right to Know. You may have a right to request the following information about our collection, use, and disclosure of your PI:

  • Categories of PI we have collected, disclosed for a business purpose, sold, or shared
  • Categories of sources from which we collected PI
  • The business or commercial purposes for collecting, selling, or sharing PI
  • Categories of third parties to whom the PI was disclosed for a business purpose, sold, or shared
  • Specific pieces of PI we have collected

B. Right to Access. You may have a right to request that we confirm whether we process information about you and give you access to that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment.

C. Right to Delete. You may have a right to request that we delete PI we maintain about you.

D. Right to Correct. You may have a right to request that we correct inaccurate PI we maintain about you.

E. Right to Opt-Out of Targeted Advertising, Selling, or Sharing. You may have the right to opt-out of the processing of your PI for the purposes of targeted advertising or direct us not to sell or share your PI. To exercise this right, please fill out the “Do Not Sell or Share My Personal Information” form, available at https://5x5data.com/opt-out-preferences/.

You may exercise any of these rights by contacting us at privacy@5x5coop.com with the subject line “Privacy Rights Request” from the email address connected to the information you are inquiring about. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity and validate that you are the owner of the email address from which you are emailing before providing a substantive response to the request. You may designate, in writing, or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. You may also have the right to appeal our decision regarding a request related to the above rights by contacting us at privacy@5x5coop.com. When you submit or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfill your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

In addition to the above rights, California law permits residents to request certain details about how their “personal information” (as defined in California Civil Code Section 1798.83) is disclosed to third parties for their direct marketing purposes. We may, from time to time, elect to disclose certain PI about you to third parties for those third parties’ direct marketing purposes. California residents may, under certain circumstances, obtain the categories of PI disclosed and the names and addresses of all third parties that received PI for their direct marketing purposes during the immediately prior calendar year. To make such a request, please contact us at privacy@5x5coop.com. Please note that we are only required to respond to one request per resident each year.

9. Changes to this Privacy Policy

Because our business needs may change over time, we reserve the right to update this Privacy Policy. If at any time in the future we plan to use your data in a way that is materially different than as described in this Privacy Policy, we will revise this Privacy Policy as appropriate. If we do change this Privacy Policy, we will post the updated policy on our website (https://5x5data.com/)) and take any other steps required by law. Please refer to the “Effective Date” above to see when this Policy was last updated.

10. Our Contact Information

If you have any questions or concerns about this Privacy Policy:

5×5 US, LLC 1800 E 4th St

Austin, Texas 78702

privacy@5x5coop.com

512-827-9312

Copyright © 5×5 US, LLC. All rights reserved. The Site is the property of Five by Five, and is protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Site, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.