Privacy Policy

California Notice at Collection: See the California privacy rights section below for important information about your rights under California privacy laws.

Introduction

This Privacy Policy describes how Talentberg, LLC and its brand, "DealSurge" process personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including, as applicable, our website, social media pages, marketing activities, and other activities described in this Privacy Policy, collectively the "Service").

DealSurge may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. DealSurge provides various services – including a business representative-to-business representative ("B2B") lead database – designed to help enterprise customers scale their email outreach campaigns. For data processing activities where we act at the direction of, and on our relevant customer's behalf, this Privacy Policy does not apply to such personal information. Our use of personal information that we process on a customer's behalf may be governed by our agreements with that customer. If you have questions regarding personal information that we process at the direction of and on behalf of an enterprise customer, please direct your inquiry to that customer. For example, the management of email validity and deliverability (e.g., invalid email addresses, bounced emails) is governed by our agreements with such customers.

Our websites, products, and services are designed for enterprise customers and their representatives. Further, our B2B lead database processes business contact information. We do not offer products or services for use by individuals for their personal, family, or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as representatives of a business (our customer or prospect) or in their professional capacities, and not in their individual consumer capacities.

Notice to European Users: Please see the "Notice to European Users" section below for additional information specific to individuals located in the European Economic Area or United Kingdom.

Index

Personal Information We Collect

We may collect personal information from or about you from a variety of sources. Below, we describe the various ways in which we may collect such personal information. We may combine personal information that we obtain from various sources.

Information you provide to us or that we generate about you.

Personal information you may provide to us through the Service or that we may generate about you includes:

• Contact data: such as your first and last name, email address, billing and mailing addresses, professional title and company name, and phone number.
• Demographic data: such as your city, state, country of residence, and postal code.
• Account data: such as the username and password that you set to establish an online account on the Service, information about where you found us, the email address(es) from which you conduct outreach campaigns, and any other information you add to your account profile.
• Communications data: information based on our exchanges with you, including when you contact us through the Service or communicate with us via chat, social media, or otherwise.
• Transactional data: information relating to or needed to complete orders or transactions you make on or through the Service, including order numbers and transaction history.
• Marketing data: such as your preferences for receiving our marketing communications and details about your engagement with them (e.g. whether you opened an email).
• User-generated content data: such as reviews, comments, questions, messages, or other content that you generate, transmit, or otherwise make available on the Service, as well as associated metadata (e.g. how, when, where, and by whom the content was created or edited). Metadata may include information added to the content by you or others, such as keywords, location information, or other data.
• Financial data: such as your financial account numbers or payment card information (including corporate payment card information) that you provide for payment purposes.
• Other data: personal information not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources.

We may obtain personal information about you from other sources, such as:

• Public sources: e.g. government agencies, public records, social media platforms, and other publicly available sources.
• Private sources: e.g. data providers (including licensors) and social media platforms.
• Customers: our enterprise customers may provide us with personal information (for example, a business client might share contact information for individuals they want to reach using our Service).
• Service providers: companies that provide services on our behalf or help us operate the Service or our business.
• Marketing partners: such as joint marketing or event partners.
• Parties to corporate transactions: we may receive personal information as part of a corporate transaction or proceeding (for example, in a merger, financing, acquisition, bankruptcy, dissolution, or sale of all or part of a business or assets).

Automatic data collection.

We, our service providers, and our business partners may automatically log information about you, your device, and your interaction over time with the Service, our communications, and other online services. This automatic data collection may be combined with information collected from other sources. The information collected automatically may include:

• Device data: such as information about your computer or mobile device (operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage), device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising), language settings, mobile device carrier, network information (e.g., Wi-Fi, LTE, 3G), and general location information (city, state or geographic area).
• Online activity data: such as the pages or screens you viewed, how long you spent on a page or screen, the website you visited before navigating to the Service, your navigation paths between pages or screens, information about your activity on a page or screen, the times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data: such as your interactions with our emails or texts (e.g., whether you open, forward, or click links in our emails). We may collect this via pixel tags or clear GIFs embedded in our communications.
• Cookies: Some of our automatic data collection is facilitated by cookies and similar technologies. For more details, see our Cookie Notice. (We also store a record of your preferences regarding the use of cookies and similar technologies in connection with the Service.)

How We Use Your Personal Information

We may use your personal information for the following purposes, or as otherwise described at the time of collection:

• Service delivery and operations: We use personal information to provide and operate the Service and our business. This includes establishing and maintaining your user account; enabling security features of the Service (for example, sending you security codes via email or SMS); communicating with you about the Service (service-related announcements, updates, security alerts, and support or administrative messages); and providing support and responding to your requests, questions, and feedback.
• Service personalization: We use personal information to understand your needs and interests, remember the devices from which you have previously logged in, personalize your experience with the Service and related communications, and remember your preferences as you navigate our online properties.
• Research and development: We use personal information for research and development purposes, including to analyze and improve the Service and our business, and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from the personal information we collect. We remove information that makes the data personally identifiable to you. We may use and share this aggregated or de-identified data with third parties for lawful business purposes, including to analyze and improve the Service and promote our business, and we will not attempt to reidentify such data.
• Marketing and advertising: We, our service providers, and our third-party advertising partners may collect and use personal information for marketing and advertising purposes. This includes:
  • Direct marketing: We may send you direct marketing communications and tailor these messages to your interests. You may opt out of our marketing emails as described in the Opt-out of communications section below.
  • Interest-based advertising: Our third-party advertising partners may use cookies and similar technologies to collect information about your interactions over time (including the data described in the "Automatic data collection" section above) with the Service, our communications, and other online services, and use that information to serve online ads that they believe will interest you. This is called interest-based advertising. We may also share general information about our users with these companies to facilitate interest-based advertising on other platforms. (See the Your Choices section of our Cookie Notice for information about how to limit interest-based advertising.)
• Service improvement and analytics: We use personal information to analyze usage of the Service, to improve the Service and our other business activities, to understand which pages or features are most popular (or which are least used), to gauge how users navigate the Service, to assess interactions with our emails, and to develop new products and services. For example, we use Google Analytics to help understand how users engage with our websites. (Learn more about Google Analytics and how to opt out of it here: https://tools.google.com/dlpage/gaoptout.)
• Compliance and protection: We may use personal information to comply with applicable laws, lawful requests, and legal processes (such as responding to subpoenas or requests from government authorities). We may also use personal information to protect our rights and property, and the rights, privacy, safety, or property of you or others. This includes making and defending legal claims; auditing our internal processes for compliance with legal and contractual requirements and internal policies; enforcing the terms and conditions that govern the Service; and preventing, identifying, investigating, and deterring fraudulent, harmful, unauthorized, unethical, or illegal activity (including cyberattacks or identity theft).
• Data sharing in corporate events: We may use and share certain personal information in connection with actual or prospective corporate transactions. (See How We Share Your Personal Information below for more information.)
• With your consent: In some cases, we may ask for your consent specifically to collect, use, or share your personal information, such as when required by law. If we ask for your consent, we will use your personal information for the purposes explained at that time.
• Retention: We generally retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for processing, whether those purposes can be achieved by other means, and applicable legal requirements. When we no longer need the personal information we've collected, we will delete it, anonymize it, or isolate it from further processing.

How We Share Your Personal Information

We may share your personal information with the following parties (and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection):

• Affiliates: Our corporate parent, subsidiaries, and other corporate affiliates.
• Service providers: Third parties that perform services on our behalf or help us operate the Service or our business (for example, hosting providers, information technology companies, customer support and online chat providers, email delivery services, marketing and consumer research providers, and website analytics companies).
• Payment processors: Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors (e.g., Stripe). Those processors may use your payment data in accordance with their own privacy policies (for example, see Stripe's policy at stripe.com/privacy).
• Advertising partners: Third-party advertising companies for the interest-based advertising purposes described above in Marketing and advertising.
• Subscribers and other private parties: We may share your personal information with subscribers to our Services (i.e. our enterprise customers) and with other third parties who purchase personal information from us through our lead-generation services. For example, if you enroll in our email warmup service, your personal information – such as your name, email address, and contact details as displayed in your email signature – will be shared with other participants in the email warmup service. We do not control how our subscribers or other third parties may use your personal information. In addition, certain user-generated content that you post may be publicly displayed and include your personal information. For example, if you leave a comment on our website, your name may be displayed alongside your comment.
• Data providers: We may share your personal information with data providers (for example, to maintain accurate information about you in our own and our partners' databases). We do not control how these data providers use your personal information once it is in their hands.
• Third parties designated by you: We may share your personal information with third parties when you instruct us to do so or when you consent to such sharing.
• Professional advisors: We may share personal information with professional advisors (such as lawyers, auditors, bankers, and insurers) as necessary in the course of the professional services they provide to us.
• Authorities and others: We may share personal information with law enforcement, government authorities, or other third parties if we believe in good faith that such disclosure is necessary or appropriate to comply with the law, respond to legal requests, or protect the rights, privacy, safety, or property of our company, you, or others. (This aligns with the Compliance and protection purposes described above.)
• Business transferees: We may disclose personal information in connection with actual or potential business transactions involving DealSurge. For example, personal information may be disclosed during due diligence for an investment or financing, a public stock offering, or a sale, transfer, or merger of all or part of our business, assets, or shares. Personal information may be shared with prospective counterparties and their advisors, and may be transferred to an acquirer, successor, or assignee if DealSurge is involved in a merger, acquisition, sale of assets, or similar transaction. In the event of insolvency, bankruptcy, or receivership, personal information may be transferred as a business asset to one or more third parties.

Your Choices

In this section, we describe the rights and choices available to all users. Users in California and Europe can find additional information about their rights in the sections specific to those jurisdictions below.

• Access or update your information: If you have registered for an account with us, you may review and update certain account information by logging into your account at any time.
• Opt-out of communications: You may opt out of marketing-related emails by following the unsubscribe instructions at the bottom of the email or by contacting us. Note that if you opt out of marketing emails, we may still send you service-related or other non-marketing communications (such as important account notices).
• Cookies and other tracking technologies: For information about the cookies and similar tracking technologies employed by the Service, and how to control them, see our Cookie Notice.
• Blocking images/clear GIFs: Most web browsers and email clients allow you to prevent images (including clear GIFs/pixel tags) from loading. Consult your browser or device settings for instructions on how to do this.
• Do Not Track: Some Internet browsers may be configured to send "Do Not Track" (DNT) signals to websites. Currently, we do not respond to DNT signals. To learn more about "Do Not Track," you can visit allaboutdnt.com.
• Declining to provide information: If you choose not to provide information that we require to provide certain services (for example, if information is marked as required in a form and you do not provide it), we may not be able to provide those services to you.

Other Sites and Services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. Our content may also be integrated into pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or an affiliation with, any third party. We do not control third-party websites, applications, or online services, and we are not responsible for their actions. We encourage you to read the privacy policies of any third-party websites or services that you use.

Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, please note that no security measures are foolproof – there is always some risk inherent in transmitting information over the internet. Therefore, we cannot guarantee absolute security of personal information.

International Data Transfers

We are headquartered in the United States, and we may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country of residence. (If you are in Europe, please see the Notice to European Users below for additional information on transfers of personal data outside of Europe.)

Children

The Service is not intended for use by anyone under 18 years of age. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe that your child has provided us with personal information in violation of applicable law, please contact us. If we learn that we have collected personal information from a child without the required consent of a parent or guardian, we will delete that information in accordance with applicable law.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will notify you by updating the date of this Privacy Policy and by posting the updated Privacy Policy on the Service (or through other appropriate means). Any modifications will be effective when posted (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of the updated Privacy Policy constitutes your acknowledgment of the changes and your agreement that the new Privacy Policy applies to your interactions with the Service and our business.

How to Contact Us

• Email: info@dealsurge.ai
• Mail: Talentberg, LLC, 2500 CityWest Blvd, Ste 150, Texas, United States 77042

Talentberg, LLC is a business registered in the State of Texas, USA.

California Privacy Rights Notice

This section applies only to residents of California. It describes how we collect, use, and share Personal Information of California residents and the rights that California residents have under California law. For purposes of this section, "Personal Information" (PI) has the meaning given in the California Consumer Privacy Act ("CCPA") (as amended by the California Privacy Rights Act and other applicable laws) and does not include information exempt from the CCPA's scope. In some cases, we may provide a different privacy notice to certain California residents (for example, job applicants); that notice will apply instead of this section. (References in this section to "Personal Information" include analogous terms defined under other state privacy laws, as applicable.)

Your California Privacy Rights

As a California resident, you have the following rights, subject to certain limitations or exceptions under the law:

• Right to Know/Information: You have the right to request that we disclose certain information about our collection and use of your Personal Information over the past 12 months, including: the categories of Personal Information we have collected; the categories of sources from which the Personal Information was collected; the business or commercial purpose for collecting and/or selling Personal Information; the categories of third parties with whom we share Personal Information; the categories of Personal Information that we sold or disclosed for a business purpose; and the categories of third parties to whom Personal Information was sold or disclosed for a business purpose.
• Right to Access: You have the right to request a copy of the Personal Information that we have collected about you in the past 12 months, in a portable and, to the extent technically feasible, readily usable format.
• Right to Correction: You have the right to request that we correct any inaccurate Personal Information that we maintain about you.
• Right to Deletion: You have the right to request that we delete Personal Information that we have collected from you, subject to certain exceptions (for example, we may retain information as required or permitted by law).
• Right to Opt-Out of Sale/Sharing: You have the right to opt out of the "sale" of your Personal Information or the sharing of your Personal Information for cross-context behavioral advertising (also known as targeted advertising) if we engage in those activities. Note: We do not have actual knowledge that we sell or share the Personal Information of California residents under 16 years of age.
• Right to Limit Use of Sensitive Personal Information: You have the right to limit our use of sensitive Personal Information (as defined under the CCPA) if we were to use it for purposes not allowed by the CCPA. (At this time, we do not use sensitive Personal Information for purposes that California law affords a right to limit.)
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of your privacy rights. We will not deny goods or services, charge different prices, or provide a different level of quality of goods or services just because you exercised your rights under the CCPA, except to the extent permitted by law.

Exercising Your Rights to Know, Access, Correction, or Deletion

You (or your authorized agent) may exercise your rights to know, access, correct, or delete your Personal Information by submitting a request through our online Privacy Request Manager or by contacting us using the information in the How to Contact Us section above. We will need to verify your identity (and authority, if you are an agent) before processing your request. Verification may require you to provide information such as government identification, a signed declaration, or other information. If we cannot verify your identity or authority to a reasonable degree of certainty, we will not be able to fulfill certain requests.

Exercising Your Right to Opt-Out of Sale/Sharing

To opt out of the "sale" of your Personal Information or the sharing of your Personal Information for targeted advertising, you may submit a request through our Privacy Request Manager (or by using the "Do Not Sell or Share My Personal Information" link on our website, if available). You may also broadcast the Global Privacy Control (GPC) signal from your browser to opt out of cookie-based sharing/sales – if our website detects a GPC signal, we will honor it by opting that browser out of cookies that result in a sale or sharing of your Personal Information. (Learn more about GPC at globalprivacycontrol.org. Note that you must enable the GPC signal on each browser or device you use to visit our site for it to be effective.)

Verification of Identity and Authorized Agents

When you submit a request, we may need to verify your identity (and, if applicable, your authorized agent's identity and authority) to protect your privacy and security. As mentioned above, this may involve asking you (or your agent) for additional information or documentation. Under the CCPA, an authorized agent can make a request on your behalf, but we will require proof that you gave the agent permission to submit the request (such as a valid power of attorney or other written authorization) and we may still ask you to verify your identity directly.

Deidentification

We may deidentify your Personal Information so that it can no longer be associated with you, and may use and share such deidentified information as permitted by law. We commit not to reidentify any data that we deidentify, except as allowed by law.

Categories of Personal Information Collected, Used, and Disclosed

The chart below summarizes the categories of Personal Information we collect, the sources of that information, the purposes for which we use it, and the types of third parties with whom we share or disclose it. (See the "Personal Information We Collect" section above for more details on each category). This summary covers our data practices in the 12 months preceding the effective date of this Privacy Policy. (Note: If you provide information via free-form text fields or documents, it may contain additional categories of Personal Information beyond those listed below.)

• Contact data
  • CCPA Category: Identifiers; Commercial information; Customer records (California)
  • Sources: You; Third-party sources
  • Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
  • Third Parties Disclosed To: Affiliates; Service providers; Payment processors; Advertising partners; Subscribers/other private parties; Data providers; Third parties you designate; Professional advisors; Authorities and others; Business transferees
  • Third Parties Sold/Shared With: Advertising partners (for interest-based advertising); Subscribers/other private parties; Data providers
• Demographic data
  • CCPA Category: Identifiers; Commercial information; Customer records (California)
  • Sources: You; Third-party sources
  • Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
  • Third Parties Disclosed To: Affiliates; Service providers; Payment processors; Advertising partners; Subscribers/other private parties; Data providers; Third parties you designate; Professional advisors; Authorities and others; Business transferees
  • Third Parties Sold/Shared With: Advertising partners (for interest-based advertising); Subscribers/other private parties; Data providers
• Account data
  • CCPA Category: Identifiers; Commercial information; Customer records (California)
  • Sources: You; Third-party sources
  • Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
  • Third Parties Disclosed To: Affiliates; Service providers; Payment processors; Advertising partners; Third parties you designate; Professional advisors; Authorities and others; Business transferees
  • Third Parties Sold/Shared With: Advertising partners (for interest-based advertising)
• Communications data
  • CCPA Category: Identifiers; Commercial information; Customer records (California); Internet or network activity
  • Sources: You; Third-party sources
  • Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
  • Third Parties Disclosed To: Affiliates; Service providers; Payment processors; Third parties you designate; Professional advisors; Authorities and others; Business transferees
  • Third Parties Sold/Shared With: None (we do not sell/share Communications data for targeted advertising)
• Transactional data
  • CCPA Category: Identifiers; Commercial information; Customer records (California); Financial information
  • Sources: You; Third-party sources
  • Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
  • Third Parties Disclosed To: Affiliates; Service providers; Payment processors; Third parties you designate; Professional advisors; Authorities and others; Business transferees
  • Third Parties Sold/Shared With: None
• Marketing data
  • CCPA Category: Identifiers; Commercial information; Customer records (California)
  • Sources: You; Third-party sources
  • Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
  • Third Parties Disclosed To: Affiliates; Service providers; Payment processors; Third parties you designate; Professional advisors; Authorities and others; Business transferees
  • Third Parties Sold/Shared With: None
• User-generated content data
  • CCPA Category: Identifiers; Commercial information; Customer records (California)
  • Sources: You; Third-party sources
  • Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
  • Third Parties Disclosed To: Affiliates; Service providers; Payment processors; Advertising partners; Subscribers/other private parties; Data providers; Third parties you designate; Professional advisors; Authorities and others; Business transferees
  • Third Parties Sold/Shared With: Advertising partners (for interest-based advertising); Subscribers/other private parties; Data providers
• Financial data
  • CCPA Category: Identifiers; Commercial information; Customer records (California); Financial information
  • Sources: You; Third-party sources
  • Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
  • Third Parties Disclosed To: Affiliates; Service providers; Payment processors; Third parties you designate; Professional advisors; Authorities and others; Business transferees
  • Third Parties Sold/Shared With: None
• Other data (any personal information not covered by the categories above)
  • CCPA Category: Identifiers; Commercial information; Customer records (California); Inferences; Protected classifications
  • Sources: You; Third-party sources
  • Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
  • Third Parties Disclosed To: Affiliates; Service providers; Payment processors; Advertising partners; Subscribers/other private parties; Data providers; Third parties you designate; Professional advisors; Authorities and others; Business transferees
  • Third Parties Sold/Shared With: Advertising partners (for interest-based advertising); Subscribers/other private parties; Data providers
• Data collected via cookies and similar technologies
  • CCPA Category: Identifiers; Internet or network information; Inferences
  • Sources: You (through your interactions); Your devices; Third-party sources
  • Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
  • Third Parties Disclosed To: Affiliates; Service providers; Advertising partners; Subscribers/other private parties; Data providers; Third parties you designate; Professional advisors; Authorities and others; Business transferees
  • Third Parties Sold/Shared With: Advertising partners (for interest-based advertising); Subscribers/other private parties; Data providers

CCPA Statistics

The following metrics reflect DealSurge's handling of CCPA consumer requests during the prior calendar year.

• Number of CCPA consumer rights requests DealSurge received: 0
• Number of CCPA consumer rights requests DealSurge complied with (in whole or in part): 0
• Number of CCPA deletion requests DealSurge received that it was not required to comply with (in whole or in part): 0
• Number of CCPA consumer rights requests DealSurge denied: 0
• Median number of days within which DealSurge responded to CCPA consumer requests: N/A (no requests received)
• Mean number of days within which DealSurge responded to CCPA consumer requests: N/A

Shine the Light Law

Under California's "Shine the Light" law (California Civil Code § 1798.83), California residents who have an established business relationship with us may request a notice describing what categories of personal information (if any) we have shared with third parties for those third parties' direct marketing purposes during the preceding calendar year, and the names and addresses of those third parties. To make such a request, please email us at info@dealsurge.ai with the subject line "Shine the Light Request" and include your name and mailing address. Please note that we will not accept Shine the Light requests via telephone, fax, or mail, and we are not responsible for requests that are not labeled or sent properly or that lack complete information.