Privacy Policy

Nebula Capital ("We," "Our," "Nebula Capital") provides a variety of data marketing and consumer analytics products (the "Services") designed to help for- profit and not-profit organizations, and companies that work with them, to market their goods and services in a relevant and efficient way. Our solutions, many of which are described on this website, are used through direct mail, email, online, connected-TV and other marketing channels. We take seriously the privacy interests and consumer choices of the individuals whose information we handle and maintain in our database. This Privacy Policy describes how we collect, use and manage information, and what rights consumers have to control how their information is used in marketing. To review the "Addendum" we have created specifically to address disclosures required under the California Consumer Privacy Act, please see our "CCPA PRIVACY NOTICE."

1. Information That We Collect and Use in Our Services

In order to provide our Services, we receive data, including personal information, from a variety of sources, including from websites and apps that collect the information, public sources, and other data compilers. We refer to the information that we collect and process throughout this Privacy Policy as "Information" or "the Information." The Information often includes various contact information, such as name, address, email address and telephone number. It also includes demographic information about individuals. It may also include information (on the individual, household, or wider (e.g., zip code) level), such as: Professional information, including occupation and job title or job history, Particular interests, such as (for instance) home improvement, music, online shopping, health and beauty sport, or travel, or political leanings, Demographic information, such as gender, age or age range, level of education or likely income range. Geolocation information, such as location coordinates tied to a device or wifi identifier. Online identifiers (such as cookie or mobile ad IDs), and IP addresses This type of information may be inferred – for instance, if a household is in a particularly wealthy area, we might infer a particular income range. Nebula Capital also receives information through this website (and any other website we operate), and through corporate interactions and events.

2. How We Use the Information

Nebula Capital uses the Information for a range of purposes, including the following:

As Part of Our Services:

  • Data Marketing Services. Our Services include providing marketing information to our customers, generally regarding which customers or prospective customers are most likely to be interested (or disinterested) in certain offers. When we provide these Services, consumers may be identified (and their information shared) in various ways, such as by household, email address, or device identifier. Similarly, we help our customers identify and understand their customers better, by providing insights about them.
  • Online Targeting. We sometimes create defined audience segments ("Audience Segments") based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., households with tech professionals, or with an interest in winter travel). When we do this, we may work with a data partner that "matches" our Information through de-identification techniques (such as through coded data "hashing") with online cookies and other identifiers, in order to target and measure ad campaigns online across various display, mobile and other media channels.
  • Email Targeting. We use the infrastructure and technology of either our Customers or our own service providers to help our Customers send and target (and measure and analyze) their email campaigns.
  • Additional Services. Other Services we may sometimes provide to our customers (or that they may provide to their own customers), which may overlap with or supplement the above, may involve (a) help with targeting and optimizing direct mail, email campaigns, display, social and mobile marketing; (b) measuring how effective marketing campaigns have been, by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases; (c) analyzing and optimizing our customers' (or their service providers') proprietary databases; (d) providing "validation" or data "hygiene" services, which is how companies update and/or correct their databases by verifying or removing or correcting old, incorrect or outdated information or (e) providing fraud prevention and identity verification purposes.

To Operate Our Services. We also use the Information for our own internal purposes – such as to improve, test, update and verify our own database; develop new products; operate, analyze, improve and secure our Services and our databases and servers.

3. How We Share Information with Third Parties, including Service Providers

Nebula Capital may share the Information with customers, marketing services and platforms, as well as service providers that help us to provide the Services we've described above (or other services we may add in the future). This includes sharing in the following ways:

  • With Our Customers: Our customers include (but are not limited to) brands and agencies and various marketing data platforms that help them to market and advertise to their own customers (and prospective customers); our customers also include other data compilers, who work with their own customers. We license the Information in various ways to our customers (and something to partners and resellers, who license the Information to their customer), when we provide our Services.
  • With Email Platforms: We share our Customers' data (but sometimes our own) with email platforms, for the purpose of targeting, measuring, sending and analyzing email campaigns.
  • With Our Partners: We may also share the Information, including personally identifiable information (such as contact information) and Audience Segments, with business and data partners to help to tailor marketing and advertising campaigns and other communications.
  • With Our Service Providers: We share the Information with a variety of service providers in order to operate, protect and advertise our Services and maintain our website(s). For instance, we may share the Information with hosting providers, tech and customer support providers, marketing and advertising solution vendors, other data providers (such as to enhance or verify our Information), security providers, billing and payment vendors (as to our business to business information), and other companies that help us operate, improve or develop the Services.
  • Corporate transfers: If Nebula Capital, its stock or its significant assets are acquired by or merged into another entity, our information will be transferred to that entity, and may be shared during due diligence in anticipation of any such transaction.
  • As required by law or to protect any person or entity: Nebula Capital may disclose Information if we believe that such disclosure is necessary to (a) comply in good faith with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or safety of Nebula Capital, our customers, or any other person or entity.

4. Your Marketing and Opt-Out Choices

There are multiple ways that you can opt-out of having the Information used to market to you:

Contact Us Directly:

You may contact us directly to have your personal information removed from our database. When you do this, please provide your current address, your email address, and any prior home or email addresses you would like "opted out" of our marketing databases. Or if you prefer, you can contact us directly by Email or mail, at:

Attn: Privacy Officer
300 N Gould Ste R
Sheridan, Wyoming 82801
Email: legal@nebulacapital.io
Toll Free: (800) 579-6218

We will then in most cases remove your personal information from our active marketing databases within 30 business days, from the time we received the opt- out request. We may in certain cases (but not in most cases) require that you verify any of the information that you submit, such as through a verified email response or another verified response.

Other Opt-Out Methods:

If you would like to opt-out of direct mail advertising in general, we recommend that you visit the DMA Choice website, at dmachoice.thedma.org. The DMA Choice service is run by the Direct Marketing Association and allows you to follow few easy steps to ensure that your marketing preferences are honored.

If you wish to opt out of online targeted ads (sometimes referred to as "interest- based" or "personalized" advertising), you can also visit the opt-out portals operated the industry groups the National Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA), and you can learn more about how those opt-outs work on those linked web pages. Please note that these online opt-outs are cookie- based (unlike Nebula Capital's direct opt-out). Thus, if you browse the web from multiple browsers or devices, you will need to opt out from each browser and/or device, and for the same reason, if you change browsers or clear your browser cookie cache, you will need to perform this opt-out function again. Opting-out in this way will not prevent you from seeing all types of online ads; it generally will prevent targeted ads customized to what advertisers think may be most likely to be relevant and of interest to you.

If you wish to opt out of Hashed Email you can visit the opt-out portal https:// optout.networkadvertising.org/optout/email.

To adjust your advertising preferences in iOS (version 12.4 and earlier), visit Settings > Privacy > Advertising > Limit Ad Tracking or Settings > Privacy > Advertising > Reset advertising ID. For version 14.5 and later, please visit Apple Support here.

To adjust your advertising preferences in Android, visit Settings > Google > Ads > Opt out of interest-based ads or Settings > Google Services & Preferences > Ads > Opt out of Ads Personalization.

Additionally, visit https://youradchoices.com/appchoices to download the AppChoices Tool to control interest-based advertising on apps on your mobile device and https://thenai.org/opt-out/mobile-opt-out for more information and instructions on opting out on mobile device.

If we market to you by email, in our corporate capacity – such as if you are a customer or prospective customer of ours and we send information about our Services — you may "unsubscribe" from our marketing emails through a link placed in your emails.

5. Cookies and Similar Technologies

Cookies and How We Use Them

Nebula Capital and its business partners use certain industry-standard technologies, including cookies and similarly functioning technologies, which we describe below. (We and/or our service providers use these technologies on our website, for instance, and our partners may use these technologies in their own marketing services.)

We may work with third parties or service providers to provide or enhance our services (e.g. for purposes of tailoring ads, or placing browser cookies), or to offer marketers ways to access or use our Information, often in de-identified form. These partners may set and access their own cookies, pixel tags and similar technologies on your device, which may have cookies with varying expiration periods. Those partners may, likewise, collect various types of information about your browser, device, or browsing activities through use of these cookies.

Cookies, in turn, are small data files that contain a string of characters, such as a unique browser identifier. Cookies are stored on your computer or other device and act as tags that identify your device. Our (or other companies') servers send your device a cookie when you visit a website. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access web pages (such as the website of a marketer), pixel tags may generate a generic notice of the visit and permit our partners (or sometimes, us) to read the cookies that a respective company or server has deployed. Pixel tags are used in combination with cookies to track the activity on a site by a particular device. When you turn off cookies, pixel tags simply detect a given website visit.

We or our service providers, and other online marketing platforms that we or they work with, may use cookies to, among other things, "remember" you, determine visitor patterns and trends, collect information about your activities on our clients' sites, or interact with the advertising you see. Cookies are used in this way to provide relevant content to you and replace non-relevant communications with ads that better match your interests.

Sometimes, we work with companies that link our Audience Segments to cookies (as also described in Section 2), in order to help companies better target (or suppress) advertisements to consumers. This is one of type of the various categories of advertising that are often referred to as "personalized" or "interest- based" advertising" or "Interest-Based Advertising." You can opt out of this type of advertising through the industry opt-out methods described in Section 3, which are cookie-based.

Disabling Cookies

Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of our website and other services may be difficult to use or become inoperable.

6. Data Collected Through Our Corporate Website

Information Collected

Nebula Capital collects information from users of our website(s) (including any page on which this Privacy Policy is posted), including:

  • The domain name and IP address of a user's web browser, along with a timestamp and other information about a user's browser or device.
  • Information about what content and pages users access, utilize or visit on our website, or how they interact with our content – for instance, if they spent a certain amount of time reviewing a particular blog post or description of particular services.
  • Information, including personally identifiable and contact information that you provide, which could include (for instance) survey information, sign-up information (e.g., if you sign up for events or newsletters), requests for information, mailing addresses and email addresses.

How We Use the Information We Collect Through Our Website

  • Create and manage your unique user account.
  • Provide Services to you.
  • Respond to and communicate with you (including regarding news and updates about our services).
  • Send you offers and ads for our products and services, when you browse the website(s) or other companies' websites on the Internet (such as to "retarget" you with information about our services).
  • Send you offers and ads for products and services of partner brands, or other offers we believe may be of interest to you, such as invitations to events and webinars.
  • Perform data analysis (including market research).

We may combine the Information with other information we obtain from third parties, publicly available sources, and any other product or service we provide to further improve the relevance and effectiveness of products, and advertisements offered, including (but not limited to), those provided on or through our services.

We may use IP addresses to help diagnose problems with our servers and to administer our website(s). We also may use IP addresses to help identify visitors to our website(s) for the duration of a session and to gather demographic information about our visitors.

How We Share Information We Collect Through Our Websites

  • We may share the Information with service providers who help us deliver the services you request or we provide. For instance, we share the Information with tech and customer support providers, marketing and advertising providers, other data providers (such as to enhance or verify our Information), security and data hygiene vendors, payment vendors (as to our business to business information), and other companies that may help us deliver or develop Services.
  • We may share the Information to communicate with you and market to you, including through email, direct mail or display media.
  • We will disclose your PII (or other Information) if we believe in good faith that we are required to do so by law, regulation or other government authority or to protect the rights, safety or property of ourselves or any person or entity. We may also cooperate with law enforcement agencies in any official investigation and we may disclose any Information to the requesting agency in doing so.
  • If we or all or substantially all of our assets are purchased by another company (such as in a merger, consolidation, restructuring, the sale of stock and/or assets, or other corporate change or financing transaction), the Information in our possession will likely be transferred to the successor entity. We also may share the Information during the course of any due diligence process leading up to any such transaction.
  • Our website(s) use cookies and similar technologies, both for its internal and operational purposes and to market to you (such as to retarget ads to you when you visit other sites across the Internet).

7. Links

This website may provide links to other websites that Nebula Capital thinks users will find interesting or useful. Nebula Capital is not responsible for the privacy practices of these other sites or companies.

8. Security and Data Integrity

Nebula Capital takes steps to help ensure that the data we possess is housed and transmitted securely. This may include various types of physical and electronic security, including firewall protections, encryption, hashing or truncation of data, and access controls to personal information. While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we employ efforts that are designed to ensure that this does not occur.

9. Changes to this Privacy Policy

From time to time, we may update this Privacy Policy. Any changes to it will become effective when it is posted to our website, unless we indicate a later effective date. Please check back to learn of any changes to this Privacy Policy.

10. Storage of Information in the United States

If you are accessing our website from outside of the United States, your connection likely will be through and to servers located in the United States and all Information you provide will likely be processed and securely maintained in our web servers and internal systems located within the United States. (We generally store the Information used in our Services in the United States.) Thus, you should be aware that in accessing this website or otherwise communicating with us, the information we collect or receive from you may be subject to laws with lesser or different privacy standards than those in your own country (such as if you are in a country located in the European Union).

11. CAN SPAM, CalOPPA, CASL Acts and Your Choices and Access Rights

The CAN-SPAM Act of 2003

Nebula Capital upholds and adheres to The CAN-SPAM Act of 2003 which establishes regulations for commercial email, including what information must be included in an email message, the types of messages that are prohibited, and how to unsubscribe from commercial emails. The CAN-SPAM Act was passed in response to concerns about the increasing amount of spamming and other deceptive marketing practices. The law establishes requirements for commercial messages, gives recipients the right to have Email Marketers stop emailing them. CAN-SPAM contains seven requirements that Nebula Capital adheres to in order to avoid unsolicited email spamming:

  • Be honest and transparent in your header (including from, to, and routing information)
  • Do not be deceptive in your subject lines
  • Disclose the email as an advertisement
  • Provide your physical postal address in the body
  • Give instructions for opting out
  • Honor opt-out requests within ten business days
  • Ensure processors or third parties comply with CAN-SPAM

CalOPPA

Nebula Capital upholds and adheres to CalOPPA and requires that any person or company whose website collects personally identifiable information from Californian consumers must feature a conspicuous Privacy Policy stating exactly what information is collected and with whom it is shared. This includes tracking of online visits for marketing purposes. The law applies to email marketing because it requires: A Privacy Policy, and Transparency about what kinds of personal data your app or website collects. To comply with the law's requirements, it's necessary to include a statement within our Privacy Policy that we collect email addresses and whether we share them with third parties or not. Nebula Capital ensures that we provide subscribers with a means of opting out of email marketing campaigns.

CASL

Nebula Capital upholds and adheres to CASL, or Canada's anti-spam legislation, protects consumers and businesses from misusing digital technology, including spam and other electronic threats. It also aims to help companies stay competitive in a global, digital marketplace. CASL covers "Commercial Electronic Messages" (CEM), which is a bit broader than simply applying to emails. For example, it also covers instant messages, text messages, and social media messages that are related to commercial activities. CASL, like the GDPR, touches on consent. Nebula Capital adheres to the requirements for implied consent, such as (making a purchase, donation, gift, providing volunteer time or resources, providing an email address, or publishing an email address). If Nebula Capital do not meet the conditions of implied consent, Nebula Capital obtains express consent from subscribers. This requires either a written agreement or an oral agreement from the subscriber stating that they consent to receive digital communications from our or our client's business. If you wish to opt out of email marketing campaigns, please contact us.

12. Data Retention

Nebula Capital retains the non-personal user data we collect for all of our products and services for purposes of interest-based advertising for up to thirteen (13) months from the date of its collection. We will also only retain your personal data for as long as we believe it is up to date, i.e. as long as it is associated with a business that is included in our database. We verify our data periodically and if we learn that you are no longer involved with a business that is in our database, we will remove your data from our records.

Customer Data

We will retain this information for as long as needed to provide services to any one of our customers or as otherwise authorized, directed, or permissioned by our Customers. In addition, Nebula Capital will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In the event we are processing data for our Customer, we will take Client instruction.

Other Data

We will retain this information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in accordance with permitted applicable laws and regulation. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).

13. Children's Privacy

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at legal@nebulacapital.io. California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see the California rights section below for more information.

14. Your California Privacy Rights

If you are a resident of California, the California Consumer Protection Act (CCPA)/ California Privacy Rights Act (CPRA) provides certain rights of disclosure, access and deletion of your Information as described below in the "Addendum for California Residents" at the end of this Privacy Policy.

15. Contact Us

Nebula Capital has a designated privacy contact. If you have questions related to this Privacy Policy, or regarding our products or services, please contact us:

Attn: Privacy Officer
Nebula Capital
300 N Gould Ste R
Sheridan, Wyoming 82801
Email: legal@nebulacapital.io
Toll Free: (800) 579-6218

ADDENDUM FOR CALIFORNIA RESIDENTS

CALIFORNIA PRIVACY RIGHTS NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] – CALIFORNIA CONSUMER PRIVACY ACT (CCPA)/CALIFORNIA PRIVACY RIGHTS ACT (CPRA)

Pursuant to the California Consumer Privacy Act ("CCPA"), California Privacy Act ("CPRA" and together with the CCPA, "CCPA/CPRA") and other California privacy laws, we are providing the following information to visitors, users, and other who reside in the State of California ("consumers" or "you). This Addendum supplements the information in the Privacy Policy. However, this Addendum is intended solely for, and is applicable only as to, California Consumers: if you are not a California Consumer (or a resident of California), this does not apply to you, and you should not rely on it.

1. OUR COLLECTION OF PERSONAL INFORMATION

Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.

  • Identifiers: e.g., name; alias; postal address; mobile ad identifiers; IP address; telephone number; email address; social network handles
  • Characteristics of protected classifications under California or US law: E.g., race; color; religion; sex/gender; pregnancy, marital status; military or veteran status; national origin; ancestry; age (over 40)
  • Commercial or transactions information: E.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other electronic network activity information: E.g., browsing history; online interests.
  • Geolocation data
  • Professional or employment-related information: E.g., current or past job history or job title.
  • Inference Data: E.g., consumer information or preferences.

2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION

We will share the information collected from and about you for various business purposes, with service providers and with third parties including our customers. Based on the CCPA/CPRA's definition of "sell," we have sold certain categories of information in the prior 12 months to advertising networks, media platforms, political campaigns, and data analytics providers.

3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION

Generally speaking, we collect and share the Personal Information that we collect for purposes including data marketing services, online targeting, marketing optimization, campaign measurement and analysis, database management, fraud prevention, and internal business operations.

4. YOUR CALIFORNIA RIGHTS AND CHOICES

Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf.

A. Right to "opt-out" of the sale of your personal information

California residents may opt out of the "sale" of their personal information. We may have sold certain categories of information about you in the last 12 months to commercial recipients and advertising networks as described above.

B. Right to request access to your personal information

California residents have the right to request that we disclose what categories of your personal information that we collect, use, or sell. You may also request the specific pieces of personal information that we have collected from you.

C. Right to request deletion of your personal information

You may request that we delete any personal information that we collected from you. However, we may retain personal information for certain important purposes, such as to protect our business and systems, address technical issues, comply with law enforcement requests, and exercise legal rights.

D. How to exercise your access, and (if applicable) deletion rights

Access: California residents may exercise their California privacy rights by sending an email to legal@nebulacapital.io or by contacting us at:

Privacy Officer
300 N Gould Ste R
Sheridan, Wyoming 82801
Toll Free: (800) 579-6218

We will verify your identity before responding to your request. Once we have verified your identity, we will respond to your request appropriately by providing categories of information collected or specific pieces of personal information as requested.

E. Right to non-discrimination

We do not deny to you, charge different prices for, or provide a different level of quality of goods or services to you, if you choose to exercise these rights.

F. Information about persons under the age of 16

We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database.

G. Authorized agents

You may designate an agent to make requests to exercise your rights under CCPA/CPRA as described above. We will take steps to verify the identity of the person seeking to exercise their rights and to verify that your agent has been authorized to make a request on your behalf.

H. NOTICE TO EMPLOYEES/APPLICANTS

As a California resident, we are serving notice that the Company collects and retains certain information about you. California's Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA") provides California employees and applicants with certain rights: Knowledge of information collected, Deletion of information collected, Opt-out of information collected, Opt-in of information collected, Correction of information collected, Right to go to court, Limit use of information collected, and right not to be discriminated against or retaliated against for exercising rights under the law.

Where We Get Your Information From: We collect information from you, prior employers and references, third-party demographic sources, background check companies, and claim administrators.

Sharing of Personal Information: We share your information with authorized service providers including payroll providers, benefit administrators, insurance carriers, recordkeepers, learning platforms, background screening services, and email providers.

Selling of Personal Information: The Company DOES NOT sell your personal information.

Data Retention: The Company retains the information it receives about you for a period of seven (7) years, unless a shorter or longer period is required by California or Federal law.

For Inquiries: Please contact legal@nebulacapital.io or the Privacy Officer at the address above.