Privacy Policy

Disclaimer: This summary is intended solely for informational purposes and is not intended to constitute legal advice for the reader of this summary. Capital Audience does not individually review the privacy policies of our data partners. It is our partners' responsibility to provide us with data that is legal and compliant, which we transfer to our customers. 


Purpose. The purpose of this Privacy Policy is to describe how Merchant Protocol LLC dba Capital Audience collects, uses and shares information about you through our website and related services (collectively referred to herein as the "Service"). Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us or as described at the end of this Policy. 

Our Privacy Policy explains: 

Information That We Collect 

How We Use and Share Your Information

Use and Processing of Your Personal Information

Access to Your Information and Choices 

Your Opt-Out Choices

Security of Your Information 

California Privacy Rights 

Consent to Processing of Personal Data in United States 

Changes to Our Privacy Policy 

Questions and How Contact Us 

Scope; Third Party Services. This Privacy Policy applies only to information we collect at and through the Service. Our Service also contains links to third party sites that are not owned or controlled by the Company. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Service and to read the privacy statements of each and every website that collects personal information. 

Terms of Use. Please note that your use of our Service is also subject to our Terms of Use. 


Information You Provide to Us 

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 in our database includes various identifying information, such as:  

  • Personal email
  • Professional email
  • Information and actions associated with an email, such as whether an email has recently been in use, and amount and type of marketing or “email open” activity associated with an email
  • IP address
  • A cookie or device identifier, which uniquely identifies your browser or device
  • Usage data related to your email interactions, such as whether you receive, open or respond to an email, and related information
  • Usage data related to your website interactions, such as whether you visit or log in to a website, page visits and related information
  • Demographic information, such as inferred income or age range, household size, or home ownership
  • Information regarding consumer interests, such as what type of products you may be interested in, or what types of hobbies you might have, such as whether you are a likely pet owner or a sports or art enthusiast

Some of the above information may be inferred – for instance, if a household is in a particularly wealthy area, we might infer a particular income range.

We may combine any of the points of Information we collect or receive with other Information.

Information We Collect Automatically Through Your Use of Google Analytics 

("Google") to collect certain information relating to your use of the Site. Google Analytics uses "cookies", which is a small piece of data sent from a website and stored on the user's computer by the user's web browser while the user is browsing. You can find out more about how Google uses data when you visit our Site by visiting "How Google uses data when you use our partners' sites or apps", (located at We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites ( and Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. 

Information Collected Through Cookies and Similar Technologies 

We and our service providers use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Site through your computer or mobile device including but not limited to your click-activity, referring website, device, and a date/time stamp for your visits. A "cookie" is a small piece of data sent from a website and stored on the user's computer by the user's web browser while the user is browsing. When you visit the Site again, the cookie allows the Site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Site features or services may not function properly without cookies. We use cookies to improve the quality of our service, including for storing user preferences, and tracking user trends. 

No Information from Children Under Age 13 

If you are under the age of 13, please do not attempt to register with us at this Service or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 13, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 13, please Contact Us. 


To Provide Products, Services, and Information. We collect information from you in order to provide our Service to you to: 

  • 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. We also help our customers identify and understand their customers better, by providing insights about them. Our customers include (but are not limited to) small and medium-sized businesses, ad and media agencies, brands and marketing data platforms that help their customers to market and advertise to their own customers (and prospective customers). Our customers also may include other data compilers, who work with their own customers.
  • Retargeting Services.  We sometimes help our customers to “retarget” marketing content to website visitors. In particular, our Services help customers send emails to people who visited or logged in to their websites by cross-referencing information such as cookie identifiers and emails for those purposes.
  • Additional Marketing Services. Other Services we may provide to our customers (or help them to provide to their own customers), which may supplement the above Services, may involve (a) assisting customers to target and optimize email campaigns, display, or other 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) helping customers to detect and prevent fraud and provide “validation” or data hygiene services, e.g., by verifying or removing or correcting old, incorrect or outdated information or evaluating whether an email address recently has been active.

Sharing with Third Parties. We may provide information to third party service providers that help us operate and manage our Service, process orders, provide advertising for us, and fulfill and deliver products and services that you purchase from us. These service providers will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service. 

Transfer in the Event of Sale or Change of Control. If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Service to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently. 

In addition to the specific situations discussed elsewhere in this Policy, we disclose personal information in the following situations:

  1. With Our Customers: As described above, 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. We may sometimes share the Information with those Customers’ service providers (for instance, a provider that prints or sends mailings for a Customer).
  2. With Our Partners: We also may share the Information, including personally identifiable information and Audience Segments, with business and data partners to help provide more tailored targeted marketing, advertising and communications. Likewise, we may do so for analytical purposes, including to help these other parties measure campaign performance, inform future campaigns, or to handle, analyze, or segregate this Information on our or our customers’ behalf.
  3. 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 our tech, hosting and customer support providers, marketing and advertising providers, other data providers (such as to enhance or verify our Information), security vendors, payment vendors (as to our business to business information), and other companies help us deliver, secure or develop our Services.
  4. Corporate transfers: If Capital Audience, 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.
  5. Affiliates, parent companies and subsidiaries: Capital may share some or all of the Information in our possession with any affiliated or subsidiary companies (if we ever have any).
  6. As required by law or to protect any person or entity: 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, our customers, or any other person or entity.


  • To identify you when you visit our websites or our stores.
  • To provide the products and services you request, or to process returns.
  • To improve our services and product offerings.
  • To improve your online shopping experience by reminding you of products left in your shopping cart by utilizing cookies as described in the “Type of Information We Collect” section above.
  • To streamline your checkout process.
  • To conduct analytics (e.g., to enhance user experience on our website).
  • To respond to your inquiries related to support, employment opportunities, or other requests.
  • To send marketing and promotional materials, including information relating to products, services, sales, or promotions.
  • For internal administrative purposes, as well as to manage our relationship with you.
  • To detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity, including attempts to manipulate or violate our policies, procedures, or terms and conditions.
  • To comply with legal obligations, to establish or exercise our rights, to defend against a legal claim, and to investigate, prevent, or take action regarding possible misconduct.


  • If you would like to opt-out of email marketing from a particular brand (such as a customer of ours), click on the “opt out” or “unsubscribe” link in the footer (at the bottom) of the marketing email you have received.
  • While we generally do not engage in “direct mail” marketing, some of our customers and partners may. If you are interested in opting our of this type of marketing — i.e., materials received in your physical mailbox — we recommend that you visit the DMA Choice website, at 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.
  • To opt out of our Retargeting Services described in section 2, go to and click on the “Opt Out” bar on that page. You will need to do that from each browser that you use (because the retargeting and thus the “opt out” are cookie-based), and if you clear your browser cookies you will need to opt out again.
  • 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.


We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails and other communications you send to us through our Service are not encrypted, and we strongly advise you not to communicate any confidential information through these means. 

Upon account cancellation, we reserve the right to purge all data from a user account 30 days after account closure. We do not share account data with third parties.


The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Policy applies if you are a natural person who is a resident of California (“California Consumer”) and uses our Services. This supplements the information in the Privacy Policy. However, this  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.

In the below tables and sections, we describe (as required by the CCPA):

  1. Our Collection of Personal Information— the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from,
  2. Our Disclosure and Sale of Personal Information— the types of recipients to whom we disclose or sell Personal Information.
  3. Our Business Purposes —  our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.
  4. Your California Privacy Rights and Choices— what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.

The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ 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.


Categories of Sources

Identifiers, e.g., name; alias; postal address; mobile ad or cookie identifiers; IP address; telephone number; email address; social network handles

  • Data compilers and consumer data resellers, informational and retail websites (“Commercial Source Categories”)
  • Public records and other publicly available sources
  • Government entities
  • Social networks

Commercial or transactions information

E.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  • Commercial Source Categories
  • Public records and other publicly available sources

Internet or other electronic network activity information

E.g., browsing history; online interests.

  • Commercial Source Categories

Professional or employment-related information

E.g., current or past job history or job title.

  • Public records and other publicly available sources
  • Commercial Source Categories

Inference Data

E.g., consumer information or preferences.

  • Commercial Source Categories

We will share the information collected from and about you as discussed above for various business purposes, with service providers and with third parties including our customers. The chart below how and with whom we share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.


Categories of Third Parties We Share With

Whether We “Sold” This Category of Personal Information in the Last 12 Months (YES)

Identifiers, e.g., name; alias; postal address; mobile ad identifiers; IP address; telephone number; email address; social network handles

  • Data compilers and consumer data resellers, consumer goods retailers, informational and retail websites, content publishers, non-profit organizations, business-to-business services and organizations, consumer surveys and survey companies, affiliate networks (“Commercial Recipient Categories”)
  • Advertising networks and media platforms, political campaigns, internet service providers, data analytics providers
  • Social networks

Commercial or transactions information (YES)

E.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  • Commercial Recipient Categories
  • Advertising networks and media platforms, political campaigns, internet service providers, data analytics providers
  • Social networks

Internet or other electronic network activity information (YES)

E.g., browsing history; online interests.

  • Commercial Recipient Categories
  • Advertising networks and media platforms, political campaigns, internet service providers, data analytics providers, and social networks

Inference Data (YES)

E.g., consumer information or preferences.

  • Commercial Recipient Categories
  • Advertising networks and media platforms, political campaigns, internet service providers, data analytics providers
  • Social networks

Inference Data (YES)

E.g., consumer information or preferences.

  • Commercial Recipient Categories
  • Advertising networks and media platforms, political campaigns, internet service providers, data analytics providers
  • Social networks

We also may share any of the personal information we collect as follows:

Sharing for Legal Purposes:  In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.

Sharing In Event of a Corporate Transaction:  We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.

Sharing With Service Providers:  We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.

Sharing of Aggregate Information:  We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, at our discretion.


Generally speaking, we collect and share the Personal Information that we collect for the following purposes, as we also have described in our Privacy Policy and/or our website.

Our Purposes for collecting, using and sharing Personal Information

Data marketing services, for example:

  • Generally, creating data marketing tools and products for our marketer clients, as more fully described in our Privacy Policy (and on our websites).   This includes our provision of datasets, data “appends” (connecting data across datasets), data “scoring” (providing inferences about potential identifiers), data hygiene services (helping customers to evaluate, validate and correct personal information they hold), and security and anti-fraud services (helping customers to identify potentially fraudulent activity).
  • Helping our Clients identify and understand their consumers better, by providing insights about them and managing loyalty programs, as well as providing financial and other scoring products.
  • Assisting our Clients through our Services to provide their current and prospective customers with better service, generally related to the above.
  • Creating “identity” graphs or associations between data points, to help locate users across various channels, such as based on common personal, device-based, or network-based identifiers (e.g., IP address, cookie or device identifiers, email address).

Additional marketing services, for example (which may overlap with “data marketing services” above):

  • Assisting in targeting and optimizing of direct mail and email campaigns, display, mobile, and social media marketing.
  • Measuring the effectiveness of online or offline ad campaigns 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.
  • Analyzing and optimizing our Clients’ (or their service providers’) proprietary databases, or helping Clients to identify and mitigate potential fraud.
  • Providing “hygiene” or “verification” services, which is how companies update and/or “clean” their databases by either verifying or removing or correcting old, incorrect, or outdated information.

Operating our Services, for example:

  • Testing, improving, updating and verifying our own database.
  • Developing new products.
  • Operating, analyzing, improving, and securing our Services.

Other internal purposes, for example:

For internal operations, auditing, research, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance.

We sometimes use the information collected from our own website,  from social networks, from other “business to business” interactions (such as information we collect at trade shows) or from data compilers for the above, as well as for our own marketing purposes.

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. This section describes how to exercise those rights and our process for handling those requests (to the extent permitted by applicable law, we may charge a reasonable fee to comply with your request).

Sometimes, we act only as a “service provider” to our clients (for instance, if they provide information to us for analytics, processing or other data management services), in which case any consumer requests for opt-out, deletion or access to data must be made through that client: we therefore will forward any such requests to a named client, as feasible, such as where a client has been identified.

1. Right to request that we “do not sell” your personal information

You may request that we not “sell” your personal information. If you wish to make such a “do not sell” (also called an “opt out” request), please contact us by email at support[at]

2. Right to request deletion of your personal information

You may request that we delete any personal information that we collected from you, such as if you have been a customer of ours (Note that this is different from your right to “opt out” of us selling your personal information, which is described above; also note that we do not generally collect personal information directly from consumers).  You may make a deletion request by emailing us at support[at] In our discretion, we may interpret your “deletion” request as a “Do Not Sell” request (and thus place it on a suppression list, as described above), if we in good faith believe that is what you are requesting.

However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. Additionally, we need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.

3. Right to request access to your personal information

California residents also have the right to request that we disclose what categories of your personal information that we collect, use, or sell. As a California resident, you may also request the specific pieces of personal information that we have collected from you. You may make such an “access” or “right to know” ce: We may withhold some personal information where the risk to you or to others’ privacy rights is too great to disclose the information.

For security purposes (and as required under California law), we will verify your identity — in part by requesting certain information from you — when you request to exercise your California privacy rights.  For instance, if you request specific pieces of personal information we have received about you, you may need to confirm your possession of an identifier (such as an email address) that reasonably confirms you are the person you claim to be.

4. Right to nondiscrimination

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

5. Right to “opt-out” of the sale of your personal information

California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” — including in the definition making available a wide variety of information in exchange for “valuable consideration.”

6. 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 (or to obtain legally required consent).

7. Authorized agents

You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a legally sufficient power of attorney. We likewise may require that you verify your own identity, depending on the type of request you make.


This Service and Services are not intended for and are not directed to residents of the European Union. By using and accessing our Service, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.


We reserve the right to change this Privacy Policy at any time without notice other than posting the modified policies on our website.  We encourage you to review our Privacy Policy whenever you visit our website so you’ll always understand how your information may be used.


If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please Contact Us, email us support[at]