PRIVACY POLICY

Last revised: July 1, 2026

Giant Partners, Inc. respects your privacy and is committed to handling personal information in accordance with applicable law. This Policy explains how we collect, use, disclose, sell, share, retain, and protect personal information.

Nothing in this Policy may be construed to create any obligations for the Company beyond what is required by applicable law.

California residents CLICK HERE to access our California Consumer Privacy Act (CCPA) Notice.

Disabled users who need these disclosures presented in an alternate medium may contact us at the email address or telephone number listed further below.

1. The following Privacy Policy (the “Policy”) describes how Giant Partners, Inc. (“Company”), which owns and operates the website(s) GiantPartners.com, ListGiant.com and Via.Tools, collects, uses, discloses, sells, shares, and protects personally identifiable information and non-personally identifiable information through the website and mobile applications it operates (collectively, the “Sites”) and the services, features, or content we offer (collectively with the Sites, the “Services”). This Policy supplements the Terms of Use posted elsewhere within the Sites. You should read the Policy and the Terms of Use before you use the Sites. If you do not understand and agree with this Policy, please do not use the Services. This Policy is intended to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), and other applicable U.S. state privacy laws in Alabama, California, Colorado, Connecticut, Delaware, District of Columbia, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oklahoma, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and other states where applicable.

2. Changes to this Policy. We may change the Policy at any time by posting revisions to the Policy on the Sites. Therefore, you should review the Policy from time to time. If you do not accept all of the terms, conditions and notices set forth in the Policy, you should not use the Sites or Services. When we update this Policy, we will revise the “Last revised” date above.

3. Collection of Information from Children. We do not intentionally collect information from or regarding minors. The Sites are not directed to, or intended for use by, children under the age of 18. Children may not use or submit information through the Sites or Services. If you are under the age of 18, you may not use our Sites or Services. If a child under 18 submits information through any part of the Services, and we become aware that the person submitting the information is a child, we will attempt to delete this information as soon as reasonably possible, unless retention is required or permitted by law.

4. Type of Information Collected. We may collect, receive, license, purchase, compile, process, and use information from a variety of lawful sources, including the Sites and Services, customers, vendors, data providers, partners, affiliates, public sources, and other lawful sources. We may collect two general types of information:

a. Personally Identifiable Information and personal information (“PI”), which may include your first and last name, home or other physical address, telephone number, mobile number, email address, user ID, social media interactions, online identifiers, IP address, device identifiers, business contact information, or other identifiers that permit physical or online contact with you.

b. Non-personally identifiable information (“non-PII”), which may include browser type, operating system, browsing activity, referring websites, IP address, device-specific data, general usage information, and information that does not directly identify a specific individual.

We may also collect or receive other categories of personal information, including demographic information, commercial information, internet or electronic network activity information, general location information, professional or employment-related information, and inferences used for lawful marketing, advertising, analytics, data enhancement, lead generation, and related purposes.

We do not collect, sell, rent, or distribute sensitive personal information such as financial account information, medical information, government-issued identification numbers, biometric information, data collected by smart TVs and similar devices, or precise geolocation information.

Additionally, Giant Partners collects and manages data from a network of trusted partners, affiliates, vendors, data providers, customers, and publicly available sources. These partners are expected to collect and provide information in accordance with applicable law.

We may also collect, receive, purchase, license, or otherwise obtain data from vendors, data providers, partners, affiliates, customers, public sources, and other lawful sources. Public sources may include public records, business directories, census-related information, publicly available filings, government sources, publicly available websites, and similar lawful sources.

All data collection and use is intended to comply with applicable law and is used for lawful marketing, advertising, data enhancement, lead generation, analytics, business, compliance, and related purposes.

5. Cookies. In general, a cookie is a small amount of data sent to your browser from a web server and stored on your computer or device, where it can be used to identify your browser or device. Cookies can be used to measure website usage, improve navigation around websites, personalize a returning visitor’s experience, support analytics, and assist with advertising and marketing. In most cases, you can set your browser to turn off cookies or to notify you before you receive one so that you can decide whether to accept it. If you block or reject cookies, some features of the Sites may not work properly. You can refer to the instructions for your browser to learn more about these functions.

6. Web Beacons. We, our third-party service providers, advertisers and partners may use “web beacons,” pixels, tags, scripts or similar technologies. These technologies are small strings of code placed on a web page or in an email to collect data about how visitors use the Sites or interact with our communications. For example, web beacons may be used to count the number of users who visit the Sites, measure email engagement, deliver a cookie to a browser, or support advertising and analytics. If you set your browser to turn off cookies, web beacons and similar technologies may still detect certain visits to the Sites, but they may not associate your activity with information that otherwise would be stored in cookies. We do not control tracking technologies used by third parties.

7. Flash Cookies. The Sites may use locally stored objects, sometimes called “Flash cookies,” if we use Adobe Flash Player or similar technologies to provide certain content. Flash cookies are managed differently than regular browser cookies and may need to be managed through Adobe’s website or the applicable technology provider’s tools.

8. Third-Party Advertising and Third-Party Web Sites. The Sites may allow advertising by third parties that provide links to third-party websites. Internet advertising companies and the third-party websites on whose behalf they advertise may use cookies, pixels, JavaScript, tags and other technologies to deliver advertisements, measure the effectiveness of advertisements, collect information about visits to the Sites, or customize advertising content. Third parties may automatically receive certain information from your browser or device, including cookie information, IP address, browser information, device information, and information about your interactions with the Sites. Third parties’ use of their own cookies and technologies is subject to their own privacy policies. For more information about certain interest-based advertising choices, you may visit industry opt-out resources such as the Network Advertising Initiative or other similar industry tools. When using a mobile application, your operating system or device may provide instructions on how to prevent the delivery of tailored in-application advertisements.

9. Third Party Links. Please note that the Sites may contain links to other websites that do not follow this Policy. For instance, clicking on an advertisement, link, or other element on the Sites may take you to a different website. Links to other websites may use our logo or style as a result of a co-branding or other relationship. These websites may send their own cookies to you, collect data, and use that data in ways that are different from this Policy. After you leave our Sites, this Policy will no longer apply to personal information or other data collected from or provided by you to another website. You should review the applicable privacy policy of any other website or service you visit.

10. How Information is Used and Shared. We use personal information for the purpose of conducting our business, providing our services, pursuing our legitimate business interests, and complying with applicable law. For example, we may use personal information to:

a. Facilitate communication from third parties to you at your request;

b. Create and manage your account;

c. Provide the products and services you request;

d. Enroll you in programs or other offers you request;

e. Tell you about other products and services that may be of interest to you;

f. Process payment for purchases you have made;

g. Protect against or identify possible fraudulent transactions;

h. Analyze the use of our Sites;

i. Develop new products and services;

j. Understand how you arrived at the Sites;

k. Manage the Sites and Services;

l. Provide data, marketing, advertising, lead generation, analytics, and data enhancement services;

m. Create, maintain, enhance, verify, append, and update data records;

n. Help customers reach relevant audiences;

o. Process customer files for suppression, matching, modeling, or enhancement;

p. Create lookalike audiences and marketing segments;

q. Respond to consumer privacy requests;

r. Maintain opt-out, suppression, and deletion records;

s. Protect against fraud, unauthorized activity, security incidents, and legal claims;

t. Comply with applicable laws, regulations, legal processes, and government requests;

u. Enforce our Terms of Use; and

v. Enforce the terms of this Policy.

11. Use and Sale of Consumer Data.

How We Collect and Use Consumer Data

Giant Partners collects, processes, licenses, enhances, aggregates, and resells consumer and business data obtained from trusted partners, affiliates, vendors, data providers, customers, and publicly available sources. The data we compile is intended to be legally obtained and used for lawful marketing, advertising, business, data enhancement, lead generation, analytics, and related purposes.

As a data provider and broker, Giant Partners may collect, aggregate, process, enhance, license, disclose, sell, share, and resell data in compliance with applicable data privacy laws and regulations.

The permitted uses of this data include, but are not limited to:

Marketing and Advertising – Delivering targeted offers, promotions, and communications to relevant audiences on behalf of our customers and partners.

Data Enhancement – Verifying, improving, appending, and updating data to support accuracy, relevance, segmentation, suppression, and outreach.

Business-to-Business Services – Supplying businesses with legally obtained data to support sales, lead generation, customer outreach, marketing, and operational insights.

Analytics and Modeling – Creating audience segments, lookalike models, marketing insights, and related data products.

Responsible Data Practices and Compliance

We prioritize responsible data use and compliance with applicable laws, including:

California Consumer Privacy Act and California Privacy Rights Act – Providing California residents with applicable rights to access, delete, correct, limit, or opt out of the sale or sharing of their personal information.

TCPA and CAN-SPAM Act – Supporting compliance with applicable telemarketing and email marketing laws.

State Privacy Laws – Responding to consumer privacy rights requests where required by applicable state law.

Consumer Rights and Opt-Out Options

Consumers may have the right to opt out of certain data sharing or sale, request deletion, request correction, request access, or exercise other rights in accordance with applicable privacy laws.

12. Advertisements, Marketing Material and Other Offers. Unless you tell us that you do not want to receive these offers, and subject to applicable law, the Company or companies with which we have a commercial relationship may occasionally send advertisements, marketing material, promotional messages, or other offers that we think might be of interest to you. If you do not want to receive these advertisements, marketing material, promotional messages, or other offers, please contact us using the contact information found at the end of this Policy or follow the opt-out instructions provided in the communication. Where required by law, we will seek your consent before sending certain marketing communications. To the extent allowed by law, the provision of your email address and phone number to us may constitute your consent and electronic signature authorizing us to contact you at that email address and phone number, including through the possible use of an automatic telephone dialing system, artificial/AI or prerecorded voice, live calls, emails, and text messages, for promotional, marketing, informational, and other lawful purposes. You are not required to provide such consent in order to make a purchase, and you may contact us directly to arrange an alternate purchase method where applicable. By providing your telephone number to us, you certify that this is your own number that you own or are authorized to use, and not a line owned or used by another person. You agree to notify us if your number changes or is reassigned. You agree to indemnify us if this is not the case and if the future owner or user of the number makes a claim against us for contact at that number. You may opt out of such contact at any time and through any of the reasonable methods outlined herein. A copy of our internal, written Do-Not-Call Policy will be provided upon request.

13. Sale of Business or Assets. In the event that Company is considering a sale of its business, in its entirety or a component thereof, or substantially all of its assets are acquired, personal information and non-personal information may be one of the transferred assets and may be used by a third-party acquirer in accordance with this Policy and applicable law. Such use by a third party may include review of personal information, use of personal information to contact you either before or after such transfer or sale, use or transfer of non-personal information before or after such transfer or sale, or other purposes permitted by law.

14. Disclosure for Compensation. WE MAY DISCLOSE PERSONAL INFORMATION ABOUT YOU TO A THIRD PARTY FOR COMPENSATION.

15. Additional Sharing of Information. In addition, we may share your information as described below:

a. Information You Elect to Share: You may choose to share information with third parties by clicking on links to those third parties from within the Sites. In addition, you may elect to share information, including personal information, through services offered on the Sites, including by posting comments, submitting forms, or interacting with content. Some of your activity on the Sites, including content you have posted, may be public by default.

b. Third-Party Advertisers and Web Sites: We may share non-personal information with, or make non-personal information available to, third parties as described in the section above titled Third-Party Advertising and Third-Party Web Sites.

c. Information Disclosed to Vendors, Partners, Service Providers, Contractors, and Others for Business Purposes: We contract with vendors, service providers, contractors, and partners to provide services related to the Sites and our business. We may share personal information with such parties in order to provide products or services, maintain the Sites, process data, provide analytics, support marketing, improve our services, maintain security, or perform other lawful business purposes. We will share personal information in accordance with applicable law.

d. Information Disclosed for Protection of the Sites and Others: We may disclose personal information when required by law or to respond to legal process or lawful requests, including from law enforcement, regulators, courts, or government agencies. We may also disclose personal information when we believe it is necessary to prevent, investigate, or address possible illegal activities, fraud, security issues, violations of our Terms of Use, violations of this Policy, threats to the physical safety of any person, or to protect our rights, property, customers, users, or business.

e. Information Disclosed, Sold, or Shared for Marketing, Advertising, Data Enhancement, Lead Generation, Analytics, and Related Purposes: As a data broker and marketing services provider, we may disclose, sell, share, license, or otherwise make available personal information to customers, vendors, partners, service providers, contractors, and other third parties for lawful marketing, advertising, lead generation, analytics, data enhancement, business-to-business services, and related purposes.

The categories of personal information we may disclose, sell, or share may include identifiers, contact information, demographic information, commercial information, internet or electronic network activity information, general location information, professional or employment-related information, and inferences.

We do not knowingly sell or share the personal information of consumers under the age of 18.

16. Forums. The Sites may include forums, such as message boards, chat rooms, comment boards, reviews, or similar features that enable users to post a comment or communicate with each other. We are under no obligation to moderate or edit forums and will not be responsible for the content or use of any material posted on any forum within the Sites. We retain the right to delete at any time and for any reason any material posted within the Sites.

17. Information Security. We take information security seriously and use reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, or destruction. However, we have no control over the security of other websites on the Internet that you might visit. If you share your computer or use a computer accessed by the general public, remember to sign off and close your browser window when you have finished your session. This may help prevent others from accessing your personal information.

18. No System Can Be Completely Secure. Additionally, no system can be completely secure. Therefore, although we take commercially reasonable steps to secure information, we do not promise, and you should not expect, that personal information, searches, communications, or systems will always remain secure. In the event of a breach of the confidentiality or security of your personal information, we will notify you if required by law and as reasonably necessary so that you can take appropriate protective steps. We may notify you under such circumstances using the email address or other contact information we have on record for you. You should also take care with how you handle and disclose your personal information. Please refer to the Federal Trade Commission website for information about how to protect against identity theft.

19. Your Rights. Depending on where you live, you may have certain rights with respect to your personal information. These rights may include the right to:

a. Request access to personal information we maintain about you;

b. Request correction of inaccurate personal information;

c. Request deletion of personal information, subject to legal exceptions;

d. Request a copy of personal information in a portable format;

e. Opt out of the sale of personal information;

f. Opt out of the sharing of personal information for cross-context behavioral advertising or targeted advertising;

g. Opt out of certain profiling where applicable;

h. Limit certain uses or disclosures of sensitive personal information where applicable;

i. Appeal a decision regarding a privacy request where required by law; and

j. Not be discriminated against for exercising privacy rights.

These rights are subject to legal limitations and exceptions. If you wish to exercise one of the above rights, please submit your request using the contact information set out below.

20. California Privacy Rights. If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act, grants you certain rights regarding your personal information, including:

a. The right to know the categories of personal information we collect, use, disclose, sell, or share;

b. The right to know the specific pieces of personal information we maintain about you, subject to verification and legal exceptions;

c. The right to request deletion of personal information, subject to legal exceptions;

d. The right to request correction of inaccurate personal information;

e. The right to opt out of the sale or sharing of personal information;

f. The right to limit certain uses and disclosures of sensitive personal information, where applicable; and

g. The right not to be discriminated against for exercising your privacy rights.

California residents may request certain information regarding our disclosure of personal information to third parties for direct marketing purposes. To make such a request, please contact us using the contact information at the bottom of this Policy. We may need to verify your identity before providing information to you.

21. Do Not Track and Opt-Out Preference Signals. Certain web browsers may allow you to enable a “Do Not Track” option that sends signals to the websites you visit indicating that you do not want your online activities tracked. This is different from blocking cookies and is also different from certain legally recognized opt-out preference signals. Our Sites currently do not respond to all browser-based “Do Not Track” signals. However, where required by applicable law, we honor valid opt-out preference signals, including Global Privacy Control signals, when we are able to recognize and process them. If our practices change, we will update this Policy accordingly.

22. California Consumer Privacy Act Notice. California residents should also click here to access our California Consumer Privacy Act (CCPA) Notice.

23. Privacy Rights Requests. If you reside in California or certain other active data privacy states, the law may grant you certain rights regarding your personal information, including the right to know what data we collect, disclose, sell, or share; the right to request deletion of your personal information, subject to certain exceptions; the right to request correction of inaccurate personal information; the right to opt out of the sale or sharing of your personal information; the right to opt out of targeted advertising or profiling where applicable; the right to limit certain uses of sensitive personal information where applicable; and the right to appeal a decision where required by law.

If you wish to exercise any applicable privacy rights, please click here to email us, select “Do Not Sell or Share My Data” at the bottom of this page, or contact us using the contact information listed below.

California residents may also submit deletion requests through the California Delete Request and Opt-Out Platform (“DROP”), where applicable. Giant Partners will process deletion requests received through DROP in accordance with applicable California law.

We will respond within the timeframe required by applicable law. To process your request, we may need to verify your identity, which may require us to match the information you provide with information we maintain. Consumers may use authorized agents to submit requests where permitted by law, and we may verify the consumer’s identity and the agent’s authority to act on the consumer’s behalf.

Due to our internal compliance procedures and cybersecurity policies, we reserve the right to use reasonable procedures to validate, process, and manage bulk requests for opt-out and deletion requests. If you are an authorized agent submitting a large batch of opt-out or deletion requests, please contact us directly at compliancesupport@giantpartners.com. We offer batch processing options to efficiently handle large groups of requests in line with our security controls and applicable law.

Please note that email-based bulk requests from unknown domains may be filtered as spam or blocked by our email provider, which may prevent successful receipt. You also have the right not to face discrimination if you exercise your privacy rights.

a. Statistical Reporting

The California Consumer Privacy Act and the California Delete Act require certain data brokers to compile and disclose information regarding consumer privacy requests received during the previous calendar year. The statistics provided below relate to requests made by or on behalf of California consumers during the reporting period of January 1, 2025 through December 31, 2025.

Request Type	Received	Complied with in whole or in part	Denied
Requests to Delete	645,241	645,241	0
Requests to Know or Access Personal Information Collected	46,280	46,280	0
Requests to Know What Personal Information Was Sold or Shared and to Whom	30,853	30,853	0
Requests to Opt Out of Sale or Sharing	15,426	15,426	0
Requests to Limit Use or Disclosure of Sensitive Personal Information	3,856	3,856	0
Total	741,656	741,656	0

Median number of days to substantively respond: 20 days
Mean number of days to substantively respond: 25 days

Giant Partners denied 0 deletion requests in whole or in part during the reporting period. Accordingly, there were no requests in which deletion was not required in whole or in part under California Civil Code sections 1798.145 or 1798.146.

24. Users from Outside the United States. The Sites are hosted in the United States and are governed by United States law. If you are using the Sites from outside the United States, please be aware that Giant Partners, Inc. is located in the United States and your personal information may be stored and processed in the United States where we locate and operate our servers and databases. The data protection laws in the United States may not be as strict or comprehensive as those in your country. By voluntarily sharing personal information with us, you understand that your personal information may be stored and processed in the United States.

25. Retention. We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law. Retention periods may depend on the type of information, source of information, legal obligations, contractual obligations, operational needs, fraud prevention, dispute resolution, compliance obligations, and suppression, opt-out, or deletion obligations.

26. Contact Information. Questions concerning the Policy or the Sites, including any request to review, change, delete, or opt out regarding your personal information, may be submitted using the contact information below.

Website: www.giantpartners.com

Email: compliancesupport@giantpartners.com

Physical Address:

Giant Partners, Inc.
Attn: Compliance Officer
112 Lakeview Canyon Road, Suite 140
Thousand Oaks, CA 91362

Phone: (888) 442-6898

27. Data Protection Policy. This section applies to customer data provided to Giant Partners, Inc. by its customers for processing, suppression, matching, enhancement, modeling, data services, marketing services, or related project work. Client data is handled according to the applicable agreement with the customer. Unless otherwise agreed, Giant Partners does not sell client data provided to us solely for processing a customer project.

Giant Partners may use customer-provided data to perform requested services, including suppression, matching, appending, enhancement, address standardization, data hygiene, analytics, modeling, lookalike audience creation, list generation, and related services.

Once a project is complete, and where applicable, Giant Partners may retain, return, or destroy customer-provided data in accordance with the applicable agreement, customer instructions, legal requirements, and business needs. A notarized Certificate of Data Destruction may be available upon request.

How Data is sent to GP:

Some customers may require a Non-Disclosure Agreement, in which case GP may provide a copy of its NDA or review the customer’s NDA for execution by the parties.

Some customers may send data directly to their GP sales representative by email or through another agreed method.

If a customer wishes to send GP a suppression file or other data through a secure upload method, GP may provide a private upload link or other secure file transfer method. Once the customer sends the information, GP’s processing team or applicable internal team may receive notice that the data has been provided.

What happens when Data is downloaded by GP:

Once customer data is received, GP may process the data for the customer’s requested project. This may include appending, enhancement, suppression, matching, address standardization, data hygiene, analytics, modeling, or other requested services.

After processing, the data may be used for one or more of the following purposes, as requested by the customer and permitted by the applicable agreement:

To suppress records from GP’s database or a customer file;
To append, enhance, or standardize customer data;
To model a lookalike audience for the customer;
To generate counts, reports, or deliverables;
To perform other lawful services requested by the customer.

After the results are achieved, and subject to the applicable agreement, customer instructions, legal requirements, and business needs, GP may store the data securely, return the data, or destroy the data and provide a Certificate of Data Destruction upon request.

28. New Jersey and West Virginia Public Servicemembers and Protected Persons. We value the privacy of public service members, protected persons, and other individuals whose information may be subject to special protections under applicable law. If you are a current or former public service member, judge, prosecutor, law enforcement officer, government official, or other protected person under applicable law, including under New Jersey’s or West Virginia’s “Daniel’s Law,” law, you may submit a privacy, non-disclosure, suppression, or removal request using the contact information below:

Giant Partners, Inc.
Attn: Compliance Officer
112 Lakeview Canyon Road, Suite 140
Thousand Oaks, CA 91362

Email: compliancesupport@giantpartners.com

We will review and process protected person requests in accordance with applicable law.  You agree that, to the extent your non-public contact information is protected by New Jersey’s or West Virginia’s “Daniels Law,” you will exercise your right to opt-out (a non-disclosure request) only by emailing your request to compliancesupport@giantpartners.com, and you will allow us a reasonable period of at least 30 days to recognize and honor your request.  You agree not to transmit such demands to us using an email address or other technique prone to result in some or all of your messages being automatically filtered into our email spam folder.  If you transmit your Daniel’s Law demand through any third-party privacy service, organization or platform, you agree to do so only through a pre-agreed upon VPN, download link, or as part of a periodic, consolidated list/spreadsheet from that third-party.

29. Changes to This Policy. We may update this Policy from time to time to reflect changes in our practices, legal requirements, technology, services, or for other reasons. Any changes will be posted on this page, and the date of the latest revision will be indicated at the top of the page.