Privacy Policy

Scrubbd ("Scrubbd," "we," "us," or "our") provides political donor data, scoring, enrichment, and related analytics services (collectively, the "Services") to political campaigns, political action committees, party committees, consultants, nonprofits, advocacy organizations, and similar entities (collectively, "Clients" or "you").

This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website (the "Site"), create an account, place an order through our build wizard, receive marketing communications from us, or otherwise interact with the Services. By using the Services you acknowledge that you have read and understood this Privacy Policy.

This Privacy Policy applies to (a) personal information of Site visitors, prospective Clients, and Clients ("Client Data"); and (b) personal information about individual donors and prospective donors contained in our donor universe and delivered to Clients ("Donor Data"). Different sections describe practices unique to each category.

2.1 Information you provide to us

• Account & contact details: name, business or committee name, role, email address, telephone number, and mailing address provided when you create an account, request a quote, or place an order.
• Order configuration: selections you make in our build wizard, including budget range, geographic scope, ideology profile, donation history filters, channel preferences, and requested data fields.
• Payment information: processed by our PCI-DSS compliant third-party payment processors. Scrubbd does not store full payment card numbers on its own systems.
• Communications: records of correspondence with our team, including support tickets, sales inquiries, and feedback.

2.2 Information collected automatically

• Device & usage information: IP address, browser type and version, operating system, device identifiers, referring URL, pages viewed, time spent on pages, and interaction events.
• Cookies and similar technologies: as described in Section 10 below.
• Server logs: automatically generated logs necessary for security, fraud prevention, and service operation.

2.3 Donor Data

We compile, clean, deduplicate, score, and enrich Donor Data drawn from publicly available sources and lawfully licensed datasets. The types of Donor Data fields we may process include name, residential and mailing address, contribution history, contribution amounts, recipient committees, employer and occupation (where publicly disclosed), demographic indicators, modeled propensity-to-give scores, and modeled ideology scores. Where additional contact channel data (email address, telephone number) is included in a Client deliverable, that data is sourced from licensed contact-data partners and is delivered subject to the use restrictions in our Terms.

The donor universe we maintain is built primarily from publicly available campaign-finance disclosures filed with federal, state, and local election authorities, supplemented by lawfully licensed third-party datasets (including consumer demographic, voter file, and contact-information providers).

We do not represent that any individual record originates from a single named source. We continuously refresh, normalize, and rescore the underlying data to reflect changes in giving behavior, ideological alignment, and political affiliation. The combined dataset, together with our scoring and enrichment models, is proprietary to Scrubbd.

We use Client Data to:

• provide, operate, secure, and improve the Services;
• process orders, deliver Donor Data, and provide customer support;
• process payments and prevent fraud;
• communicate with you about your account, transactions, security updates, and material changes to the Services;
• send marketing communications (subject to your opt-in or opt-out choices and applicable law);
• conduct research, analytics, model training (using only Client Data we are permitted to use for such purposes), and product development;
• comply with legal obligations, enforce our Terms, and protect the rights, property, or safety of Scrubbd, our Clients, or others.

We use Donor Data to:

• build, maintain, score, and enrich our donor universe;
• generate and deliver custom donor lists requested by Clients in accordance with their lawful political fundraising and outreach purposes;
• improve the accuracy, freshness, and predictive value of our scoring models.

For visitors and Clients located in the European Economic Area, the United Kingdom, or Switzerland, we process personal information under one or more of the following legal bases:

• Performance of a contract — to provide the Services you request and to administer your account;
• Legitimate interests — to operate, secure, and improve the Services, prevent fraud, and conduct business analytics, where those interests are not overridden by your rights and freedoms;
• Consent — for marketing communications, certain cookies, and other processing where consent is required;
• Legal obligation — to comply with applicable law, regulation, or lawful process.

The Services and Donor Data are intended for political activity in the United States and are not directed at individuals located in the EEA, UK, or Switzerland.

Disclosure required by California, Colorado, Connecticut, Virginia, Utah, Texas, and similar US state privacy laws. Scrubbd's core business involves licensing Donor Data to Clients for political fundraising and outreach. Under the broad statutory definitions used by these laws, this activity may constitute a "sale" or "sharing" of personal information.

Categories of personal information we may "sell" or "share" (as those terms are defined under applicable state law) include: identifiers (name, mailing address, email address, telephone number); commercial information (donation history); demographic characteristics; inferences drawn from the foregoing (propensity and ideology scores); and professional or employment information (where publicly disclosed).

Recipients are limited to political committees, candidates, party organizations, PACs, consulting firms, nonprofits, and advocacy organizations, and are contractually restricted to lawful political fundraising, advocacy, and outreach purposes consistent with our Terms.

We do not "sell" or "share" the personal information of consumers we know to be under 16 years of age.

To opt your personal information out of these activities, see Do Not Sell or Share My Personal Information below.

We engage trusted third-party service providers ("processors") to help operate the Services. Categories include cloud hosting and infrastructure providers, payment processors, email and SMS delivery providers, analytics providers, customer support platforms, and licensed data partners. Each processor is bound by contractual obligations to handle personal information consistent with this Privacy Policy and applicable law.

A current list of sub-processors is available on request by emailing privacy@scrubbd.app.

Commercial email we send complies with the CAN-SPAM Act of 2003, including:

• accurate "From," "To," and routing information;
• non-deceptive subject lines that reflect the message content;
• identification of the message as an advertisement where applicable;
• a valid physical postal address for Scrubbd;
• a clear and conspicuous unsubscribe mechanism that we honor within 10 business days of receipt.

You may unsubscribe at any time by clicking the link at the bottom of any marketing email or by emailing privacy@scrubbd.app. Transactional and account-related emails (order confirmations, security notices, billing) are not subject to opt-out and will continue while your account is active.

Express written consent. By providing your mobile telephone number and opting in to receive text messages from Scrubbd, you provide your prior express written consent under the Telephone Consumer Protection Act ("TCPA") to receive recurring automated marketing and transactional text messages from Scrubbd at the mobile number you provide. Consent is not a condition of purchase.

Program details

• Program name: Scrubbd Alerts
• Message frequency: recurring; frequency varies based on your account activity and stated preferences.
• Message and data rates: Msg & data rates may apply. Check your mobile plan.
• Supported carriers: all major US carriers, including AT&T, T-Mobile, Verizon Wireless, Sprint, U.S. Cellular, Boost, Cricket, MetroPCS, and others. Carriers are not liable for delayed or undelivered messages.
• Opt out: reply STOP to any Scrubbd text message at any time. You will receive a one-time confirmation message and no further messages will be sent.
• Help: reply HELP for help or contact us at support@scrubbd.app.

No third-party sharing of opt-in data

Mobile telephone numbers and consent records collected for the Scrubbd SMS program will not be sold, rented, or shared with any third party for their own marketing purposes. We share this information only with sub-processors that operate the messaging program on our behalf, who are contractually bound to use it solely for that purpose.

Donor Data telephone numbers

Telephone numbers contained in Donor Data delivered to Clients are a separate dataset and are subject to the use restrictions in our Terms. Clients are solely responsible for compliance with the TCPA, state-level robocall and robotext statutes, the National Do-Not-Call Registry, and any applicable carrier rules when contacting individuals from delivered lists.

We and our service providers use cookies, web beacons, pixels, local storage, and similar technologies to operate the Site, remember your preferences, measure performance, and understand aggregate usage patterns. Cookie categories include strictly necessary cookies, functional cookies, performance/analytics cookies, and (where applicable) advertising cookies.

You may control cookies through your browser settings. Disabling some cookies may impair Site functionality. Where required by law, we will request your consent before placing non-essential cookies.

We honor Global Privacy Control ("GPC") signals as a valid opt-out of "sale" and "sharing" for browsers and devices on which the signal is enabled, to the extent required by applicable law.

Scrubbd is based in the United States. If you access the Services from outside the United States, your personal information will be transferred to, processed, and stored in the United States and potentially other jurisdictions where our service providers operate. Where required, we rely on appropriate transfer mechanisms such as the European Commission's Standard Contractual Clauses or the UK International Data Transfer Addendum to safeguard such transfers.

We retain Client Data for as long as your account is active, as needed to provide the Services, and thereafter for legitimate business purposes such as compliance with legal obligations, tax and accounting requirements, dispute resolution, and enforcement of agreements. We retain Donor Data on an ongoing basis as part of our donor universe, subject to opt-out, deletion, and correction rights described below.

When personal information is no longer needed, we will delete or de-identify it in accordance with our retention schedule and applicable law.

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, or destruction. These include encryption of data in transit (TLS) and at rest, role-based access controls, network segmentation, monitoring and logging, regular security assessments, vendor due diligence, and employee training.

No system is perfectly secure. In the event of a confirmed personal data breach affecting your information, we will notify you and the appropriate regulators in accordance with applicable law.

Depending on where you reside, you may have some or all of the following rights with respect to your personal information:

• Right to know / access — request the categories and specific pieces of personal information we have collected about you.
• Right to delete — request that we delete personal information we have collected from you, subject to legal exceptions.
• Right to correct — request that we correct inaccurate personal information.
• Right to portability — receive a copy of your personal information in a portable format.
• Right to opt out of "sale" or "sharing" — direct us not to sell or share your personal information.
• Right to limit the use of sensitive personal information — direct us to limit the use of sensitive personal information to what is necessary to perform the Services.
• Right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.
• Right to non-discrimination — we will not deny goods or services, charge different prices, or provide a different level or quality of service because you exercised your privacy rights.
• Right to appeal — if we deny your request, you may appeal that decision in jurisdictions that provide such a right.
• GDPR/UK additional rights — restriction of processing, objection to processing, withdrawal of consent, and the right to lodge a complaint with a supervisory authority.

These rights apply under the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), the Colorado Privacy Act, the Virginia Consumer Data Protection Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, the Texas Data Privacy and Security Act, and similar laws in other US states; the EU and UK General Data Protection Regulations; and applicable Canadian provincial privacy laws.

To submit a privacy request, choose any of the following:

• email privacy@scrubbd.app with the subject line "Privacy Request"; or
• mail a written request to the postal address in Section 21.

We will verify your request using reasonable means, which may include matching information you provide with information we maintain or requesting additional documentation. We will respond within the timeframe required by applicable law (typically 45 days under US state laws, with one extension where permitted; one month under GDPR/UK GDPR).

Authorized agents. You may designate an authorized agent to submit a request on your behalf. We will require written authorization signed by you, verification of the agent's identity, and verification of your identity. For requests under the CCPA/CPRA, authorized agents must comply with applicable California regulations.

You have the right to direct Scrubbd not to "sell" or "share" your personal information as those terms are defined under applicable state law. To submit an opt-out request:

• email privacy@scrubbd.app with the subject line "Do Not Sell or Share";
• provide first and last name, residential address, email address, and any telephone numbers associated with the records you wish to suppress; and
• indicate whether the request applies to all categories of personal information.

We will process verified opt-out requests within 15 business days and will instruct downstream recipients to honor the opt-out where required by applicable law. We honor Global Privacy Control signals as described in Section 10.

Some categories of personal information processed by Scrubbd may be considered "sensitive personal information" under state law, including precise geolocation (where derived), and inferences relating to political opinions or beliefs derived from publicly available campaign finance contributions. We use sensitive personal information only for the purposes disclosed in this Privacy Policy and as permitted by applicable law. Residents of jurisdictions that provide a right to limit the use of sensitive personal information may submit a request as described above.

The Services are not directed to children under the age of 16, and we do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from a child under 16 without verifiable parental consent, we will delete it promptly. Parents or guardians who believe their child has provided personal information to us may contact privacy@scrubbd.app.

The collection, processing, and dissemination of information about political contributions and political activity is protected activity under the First Amendment to the United States Constitution and is expressly permitted by federal and state campaign finance disclosure regimes. Scrubbd is not a "consumer reporting agency" within the meaning of the Fair Credit Reporting Act ("FCRA"), and Donor Data may not be used by Clients for any purpose covered by the FCRA, including credit, employment, insurance, housing, or other eligibility decisions. See our Terms for additional restrictions.

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date at the top of this page. Material changes will be communicated through prominent notice on the Site or by email to registered Clients. Your continued use of the Services after the effective date constitutes acceptance of the updated Privacy Policy.

For privacy questions, requests, or concerns, please contact:

Scrubbd — Privacy Office
Email: privacy@scrubbd.app
Mailing address: 1209 Orange Street, Wilmington, DE 19801, United States

For EU/UK matters, our designated representative may be contacted at the same email address; please mark your message "GDPR Request" or "UK GDPR Request" so it is routed appropriately.