EU-U.S. Privacy Shield Framework: Active

Original Certification Date: 5/13/2019
Next Certification Due Date: 4/23/2021
Data Collected: NON-HR

Purpose of Data Collection

We process Personal Data to operate, improve, understand and personalize our Services. We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services. Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following: • First and last name • Email address • Telephone number • Employer Information we receive from third-party sources: Some third parties such as Crunchbase and Clearbit provide us with Personal Data about you, such as the following: • Account information for third-party services: If you interact with a third party service when using our Services, such as if you use a third-party service to log-in to our Services (e.g., Facebook Connect or Twitter OAuth), or if you share content from our Services through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service. • Information from our advertising partners: We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications. Publicly accessible sources: We use third-party providers to supplement data that you provide to us, using publicly accessible sources. For example, when you provide us with the name of your contact, we may use Clearbit to find your contact’s job title and a corresponding photo from publicly accessible sources (e.g. your contact’s company page). Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, such as the following: • Device identifiers • Web browser information • Usage information • Location information • Log data (e.g. access times, hardware and software information) We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below. We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include: • Payment processors • Fraud prevention service providers • Ad networks • Analytics service providers • Staff augmentation and contract personnel • Hosting service providers • Co-location service providers • Telecommunications service providers We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include: • Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services) • Social media services (if you interact with them through your use of the Services) • Third party business partners who you access through the Services • Other parties authorized by you We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected). We also share Personal Data when we believe it is necessary to: • Comply with applicable law or respond to valid legal process, including from law enforcement

Privacy Policy

Non-HR Data


Effective Date: 8/6/2018

Verification Method


Dispute Resolution

Questions or Complaints?

If you have a question or complaint regarding the covered data, please contact Affinity at:

Aaron Shaw
Director, Customer Support
Affinity 150 Columbus Ave San Francisco CA 94133
150 Columbus
San Francisco, California 94133

Privacy Shield organizations must respond within 45 days of receiving a complaint.

If you have not received a timely or satisfactory response from Affinity to your question or complaint, please contact the independent recourse mechanism listed below


Appropriate statutory body with jurisdiction to investigate any claims against Affinity regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy Federal Trade Commission