Privacy Policy

Last updated: December 31, 2019

Thank you for your interest in Project Applecart LLC. We are a data science company which helps our customers find the right audience for their messages. Our services include assisting political campaigns and commercial businesses improve their marketing strategies.

We are committed to protecting your privacy and, for that reason, we have adopted this Privacy Policy to explain our data collection, use, and disclosure practices for the Applecart services (including its website, and any other tools, products, or services provided by Applecart that link to or reference this Privacy Policy) (collectively, the “Services”). The Services are owned and operated by Project Applecart, LLC, a Delaware limited liability company (“Applecart”, “we”, “us”, or “our”).

If you reside in the State of California, please click here to learn more about your privacy rights. To the extent that there is a conflict between this Privacy Policy and the Privacy Notice for California Residents, the Privacy Notice for California Residents will prevail with respect to California Residents (as defined below) only.

This Privacy Policy applies to information Applecart collects through the Services, as well as other information provided to us online or offline by third parties; however, it does not apply to information collected from our employees, contractors, or vendors. You acknowledge and agree that Applecart is not responsible for the data collection or use practices of any third party utilized in providing the Services.

This Privacy Policy describes, among other things:

1. Location

Information gathered through the Services may be transferred, used, and stored in the United States or in other countries where our service providers or we are located. You understand that all transactions relating to the Services or Applecart are deemed to occur in the United States, where our servers are located.

2. Collection of Your Personal and Other Information

We collect Personal Information from a variety of sources, including (a) publicly available government records, (b) information made freely available by individuals via a variety of online platforms, including social media websites (c) information we acquire and gain rights to use through our contracted service providers, (d) off-line freely available sources such as books and periodicals, and (e) information provided to Applecart by our customers. By “Personal Information” we mean information that can identify or reasonably be linked to an individual, such as:

As mentioned above, our Services gather information which individuals make freely available on online platforms, including social media websites. This collected information may include, but is not limited to, your name, email address, demographic information from your profile, friend lists, postings or other content, and your profile picture. Applecart is not responsible for the data collection or use practices of any such connected online platform. You should read each online platform’s privacy policy before uploading your information to that platform.

We also collect non-Personal Information relating to the Services, that is, information that does not personally identify an individual. The non-Personal Information we collect includes how you interact with our website, information generally collected or “logged” by Internet websites or Internet services when accessed or used by users, and information about your web browser or device accessing or using our website.

Examples of the non-Personal Information we collect are:

We will not use non-Personal Information to try to identify you, and if we associate any non- Personal Information with information that personally identifies you, then we will treat it as Personal Information. As discussed in more detail below, we sometimes use cookies and other automatic information gathering technologies to gather non-Personal Information.

Information collected by the Services may be collected by us or one of our service providers acting on our behalf, but in either case, this Privacy Policy will govern the collection, use, and sharing of the information.

3. Use of Your Information

We may use the information we collect to:

4. Disclosure of Your Information

We may disclose your Personal Information to third parties as described below.

We may disclose Personal Information and non-Personal Information to companies, agents, contractors, service providers, or others engaged to perform functions on our behalf (such as processing of payments, provision of data storage, hosting of our website, marketing of products and services, political messaging, conducting audits, and performing web analytics). We may license third party software to include in or use with the Services, in which case we may disclose Personal Information and/or Non- Personal Information to the licensor.

Our customers may provide you with special offers, political messaging, or advertise products or services to you.

We may also disclose your Personal Information to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) comply with legal or regulatory requirements or an enforceable governmental request, (b) protect the rights, property or safety of us, our customers or other third parties, (c) prevent a crime or protect national security, or (d) detect, prevent or otherwise address fraud, security or technical issues.

Finally, we reserve the right to transfer information (including your Personal Information) to a third party in the event of a sale, merger, or transfer of all or substantially all of the assets of our company relating to the Services, or in the unlikely event of a bankruptcy, liquidation, or receivership of our business. We will use commercially reasonable efforts to notify you of such transfer, for example via email or by posting notice on our website.

Lastly, we may also disclose non-Personal Information, to our clients, business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications.

5. Cookies and Automatic Information Gathering Technologies

Every time you use our website, we collect non-Personal Information (discussed above in Section 2) regarding that use. For example, to improve our website, we collect how, when, and which parts of the website or its features you access. Also, we may use your device’s unique identifier (UDID), media access control address (MAC Address), or other unique identifiers to assist us in collecting and analyzing this data.

To assist us in collecting and storing this non-Personal Information, we may employ a variety of technologies, including “Cookies,” local browser storage, and “Web Beacons.” A “Cookie” is a small amount of data a website operator, or a third party whose content is embedded in that website, may store in your web browser and that the website operator or, as applicable, the third party, can access when you visit the website. A Cookie may also refer to web-browser-based storage provided by Adobe’s Flash plugin (a “Flash Cookie”). A “Web Beacon” is a small, usually-transparent image placed on a web page that allows the operator of that image, which may be the operator of the website you visit or a third party, to read or write a Cookie.

Your operating system and web browser may allow you to erase information stored in Cookies, Flash Cookies, and local browser storage. You may also be able to set your browser to refuse all website storage or to indicate when it is permitted. We may use Cookies to collect information about how you use our website.

More information about managing Cookies is available here. Cookie management tools provided by your browser may not affect Flash Cookies. More information about managing Flash Cookies is available here. To learn how to manage privacy and storage settings for your local browser storage, please refer to the end user documentation for your browser.

To help us collect this information, we use third-party software and services. These third parties’ collection and use of non-Personal Information are subject to their own privacy policies, which you can read here: Google Analytics

6. Transparency and Choice; Do Not Track Signals

You may request access to your Personal Information by sending an email to privacy@applecart.co. We will try to locate and provide you with your Personal Information and give you the opportunity to correct this data, if it is inaccurate, or to delete it, at your request. But, in either case, we may need to retain it for legal reasons or for legitimate business purposes. However, we (and you) are not able to control information that has already been made available to third parties through the Services.

We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, requests concerning information residing on backups), or relate to information that is not associated with your Personal Information. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Please be aware that if you request us to delete your Personal Information, we may still need to retain certain information to satisfy our legal, audit and/or dispute resolution requirements.

We may use third-party service providers that collect information for interest-based advertising purposes (advertisements that are tailored to your likely interests, based on categories in which you have shown an interest). To learn more about these third parties and the choices they offer users, please visit the Network Advertising Initiative’s choices page or the Digital Advertising Alliance’s choices page. If you are reading this Privacy Policy from a mobile device, you can learn more about the DAA's mobile choices program here.

We support the development and implementation of a standard "do not track" browser feature that provides customers with control over the collection and use of information about their web-browsing activities. Once a standardized "do not track" feature is released, we intend to adhere to the browser settings accordingly.

7. Children

We do not knowingly collect Personal Information of individuals under 18 years of age.

8. Information Security

We utilize reasonable information security measures to safeguard Personal Information against unauthorized access, modification, or destruction. For example, we utilize Secure Socket Layer (SSL), Transport Layer Security (TLS), or similar encryption technology when sensitive data is transmitted over the Internet, and use firewalls to help prevent external access into our network. However, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its security.

We restrict access to Personal Information to our employees, contractors, and agents who need to know that information in order to operate, develop, improve or support our Services. If we share Personal Information with service providers, we require that they also use reasonable information security measures to safeguard your Personal Information, comply with any applicable laws or regulations with respect to information security, and only use your Personal Information for the purposes for which we share it with them.

9. Changes to this Policy

We may modify or update this Privacy Policy periodically with or without prior notice by posting the updated policy on this page. You can always check the “Last Updated” date at the top of this document to see when the Privacy Policy was last changed. If we make any material changes to this Privacy Policy, we will notify you by reasonable means, which may be by posting a notice of the changes on our website prior to the changes becoming effective. We encourage you to check this Privacy Policy from time to time.

10. Questions

To ask questions about our Privacy Policy or to lodge a complaint, contact us at:

Project Applecart, LLC

234 W 39th Street, 5th Floor, New York, NY 10018

Email: privacy@applecart.co