We at State Affairs (“State Affairs,” “we,” “us”) know you care about how your personal data is used and shared, and we take your privacy seriously. By using or accessing stateaffairs.com or our app (together, the “Services”) in any manner, you consent to the practices and policies in this Privacy Policy.

Your use of the Services is at all times subject to our Terms of Service. Any terms we use without defining them have the meanings given in the Terms of Service. For this Privacy Policy, we use the term “processing” as it is defined in applicable law, generally covering actions such as collection, use, storage, and disclosure. We will be the controller of your Personal Data processed in connection with the Services.

Children’s Privacy: Our Services are not intended for children under the age of 13, and we do not knowingly collect or solicit Personal Data from anyone under 13. If we learn that we have collected Personal Data from a child under 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us Personal Data, please contact us at info@stateaffairs.com.

Information You Provide to Us

We receive and store any information you knowingly and directly provide to us. For example, through registration and/or your account settings, we may collect Personal Data including without limitation:

• First and last name
• Username
• Email address
• Mailing address
• User content and other information you upload to the Services (which may include Personal Data if you include it in such content)

Certain information is required to register, subscribe, or take advantage of our features. If you’ve provided your email address, we may send you Service-related or promotional emails. You can opt out of promotional emails by updating your settings or clicking “unsubscribe.”

Information Collected Automatically

Whenever you interact with the Services, we automatically receive and record information from your browser or device, such as:

• IP address and device identifiers
• Cookies and similar technologies (e.g., pixels, SDKs)
• Web browser and operating system information
• Page view statistics, usage and search information
• Location information (including precise location if enabled in your device/browser)

We use third-party analytics services to understand engagement. These providers may collect your IP address, browser type, and approximate location, and may set cookies. If you click on a third-party link, that party may set additional cookies. Third parties’ use of cookies is not covered by this Policy.

Information Collected from Third Parties

• Third-party services account information: If you use a third-party service to log in or share content (e.g., OAuth), the service may send us data about you in accordance with its policies and your settings.
• Referrals: If you invite others to the Services, we store the information for referral functionality and related communications.
• Advertising/analytics partners: We may receive information about how you interact with our websites, applications, products, services, advertisements, or communications.

AI/ML Use

We may use artificial intelligence and machine learning (AI/ML) in connection with the Services (e.g., for functionality, performance, and security). Where these technologies process Personal Data, such processing will not produce legal or similarly significant effects concerning an individual and will preferentially rely on de-identified, aggregated, or pseudonymized data, consistent with the DPA.

Non-Personal or Aggregate Information

We may de-identify Personal Data so that you are not identified as an individual and provide that information to partners. We may also provide aggregate usage information to partners, but not in a manner that would identify you.

Affiliated Businesses

In certain situations, affiliated businesses or third-party websites may provide products or services to you through or in connection with the Services. We share Personal Data with such affiliates only to the extent necessary for the related transaction or service. Please review their privacy policies for more information.

Service Providers (Our Agents)

We employ companies and individuals that provide services on our behalf, including:

• Payment processors
• Fraud prevention providers
• Ad networks
• Analytics providers
• Staff augmentation and contract personnel
• Hosting and co-location providers
• Telecommunications providers

Unless we inform you otherwise, these providers may use Personal Data only as necessary to assist us.

User Profiles and Submissions

Certain profile information and content you upload may be displayed to other users to facilitate interaction within the Services. Content you make public can be collected and used by anyone.

Business Transfers

We may share and/or transfer user information in connection with evaluations of or entry into transactions (e.g., mergers, acquisitions, bankruptcy, or other control changes). Any acquirer may continue to use your Personal Data as set forth in this Policy.

Protection of State Affairs and Others

We may access, read, preserve, and disclose information we believe is necessary to (i) comply with law or legal process; (ii) enforce our Terms of Service, this Policy, and other agreements; (iii) prevent spam or investigate fraud; (iv) maintain product and Services security; or (v) protect the rights, property, or safety of State Affairs, our employees, our users, or others.

Consent and Affiliates

We share information with third parties when you give us consent. We also share Personal Data with our affiliates or other members of our corporate family as appropriate.

General

Through your account settings, you may access and, in some cases, edit or delete information you’ve provided. If you have questions about viewing or updating information we have on file, contact us at info@stateaffairs.com. In some circumstances we may not fully comply with a request (e.g., if extremely impractical, affects others’ rights, or not required by law), but we will notify you of such a decision and may request additional information to verify your identity.

California (CCPA)

Notice of Collection: In the preceding 12 months, we have collected identifiers, commercial information, internet activity, geolocation data, and inferences for the purposes described in this Policy.

Right to Know and Delete: You may request that we disclose or delete Personal Data collected from you. Email privacy@stateaffairs.com. We will confirm receipt within ten (10) days.

Right to Opt-Out: We do not “sell” Personal Data as traditionally understood. If and to the extent certain ad-tech activities are deemed a “sale,” we will comply with applicable law.

Authorized Agent: You may designate an agent to submit requests on your behalf; we may require written proof and direct identity verification.

Right to Non-Discrimination: We will not discriminate against you for exercising your rights.

Shine the Light: California residents may request a notice describing categories of personal information shared with third parties for direct marketing and the names/addresses of those third parties. Submit a written request to the address in “Contact Us.” We may require information to verify your identity. We are required to respond to one such request per calendar year.

Consumer Affairs: If you have a question or complaint regarding the Services, email info@stateaffairs.com. You may also contact the California Department of Consumer Affairs, 400 R Street, Suite 1080, Sacramento, CA 95814; 916-445-1254 or 800-952-5210.

This Data Use Addendum (“Addendum”) supplements and, in the event of a conflict, controls over the State Affairs Privacy Policy with respect to the matters described herein.

1. Definitions

“Personal Data” means information that directly identifies a specific individual, such as name, email address, mailing address, phone number, or government-issued identifier. Personal Data does not include: de-identified information, aggregated information, or pseudonymized information that cannot reasonably be used to identify a specific individual without the use of additional information kept separately.

2. No Individualized Personalization from Personal Data

State Affairs will not use Personal Data to profile or tailor content, offers, recommendations, or other aspects of the user experience to an identified individual. All personalization visible to an identified individual will be based on: general editorial or operational criteria; or data that has been de-identified, aggregated, or pseudonymized in accordance with Section 1.

3. Permitted Uses of De-Identified and Aggregated Data

State Affairs may use de-identified, aggregated, or pseudonymized data (including data derived from Personal Data) to:

• Improve, develop, and enhance the Services;
• Train, fine-tune, or operate artificial intelligence and machine learning systems;
• Analyze trends and usage patterns;
• Develop analytics, benchmarks, and other insights; and
• Provide generalized personalization or customization that does not target an identified individual.

4. Artificial Intelligence and Machine Learning

State Affairs may use artificial intelligence and machine learning technologies in connection with the Services, including for functionality, performance, and security improvements. Where these technologies process Personal Data, such processing will:

• Be conducted in a manner that does not produce legal or similarly significant effects concerning an individual; and
• Preferentially use de-identified, aggregated, or pseudonymized data whenever possible.

5. Data Segregation and Security

State Affairs will maintain appropriate technical and organizational measures to protect Personal Data and will ensure that data collected from one customer will not be used to customize or tailor another customer’s environment except in a de-identified or aggregated form.

6. Relationship to Privacy Policy

This Addendum should be read together with the State Affairs Privacy Policy. In the event of a conflict, this Addendum governs the handling and use of Personal Data with respect to personalization, artificial intelligence usage, and automated decision-making.