Rollup values the protection of your privacy and maintaining your trust in our services. This Privacy Notice is intended to address the global privacy regulations applicable to the activities and services we perform.
Please be aware that data privacy laws can vary in the different jurisdictions where Rollup operates. In some jurisdictions other federal, state, and/or local laws (collectively “Local Laws”) may also apply.
You may always contact us as described in the How to Contact Us section below if you have questions about this Privacy Notice, the processing of your Personal Data, or to exercise your rights as outlined below.
1. Scope
A reference to “Rollup,” “we,” “us” or “Company” is a reference to Rollup Systems, Inc. and its relevant subsidiaries and affiliates involved in the collection, use, sharing, or other processing of Personal Data.
This Privacy Notice describes how Rollup uses and protects Personal Data collected for the following activities(“Activities”):
- visits to our websites and online apps including rollup.ai, and app.rollup.ai, and any other website on which this Privacy Notice appears (“Sites”);
- communications such as phone calls, text messages, emails, faxes, or video calls (“Communications”);
- participation in surveys or research initiatives (“Research”);
- visits to our branded social media pages (“Social Media”);
- and use of our products and services where we act as a controller of your Personal Data, including trial access to our Services and the Rollup Platform (“Direct Sales”).
This Privacy Notice also explains our marketing practices generally. Please note, depending on how you interact or engage with us we may provide you with other privacy notices that include additional details about our information practices. For example, this Privacy Notice does not apply to job applicants and candidates who apply for employment with us, or to employees in the context of the employment relationship, which are subject to separately provided notices.
If you are a California resident, for more information about your privacy rights, please see the section of this Privacy Notice called “California Privacy Rights.”
1.1. Rollup Platform
This Privacy Notice applies to Rollup’s software-as-a-service products where you engage with Rollup via our Sites, Services, or Direct Sales, including licensed software available through our platform via https://app.Rollup.ai, and any software, mobile applications, products, devices, or other services (collectively "Rollup Platform").
This Privacy Notice does not apply to the extent we process Personal Data while acting as a Processor or Service Provider on behalf of a customer; under such circumstances we only process Personal Data on behalf of and in accordance with the instructions from our customer and any related data processing agreements, subscription service agreements, purchase orders, statements of work, or other applicable agreements.
This Privacy Notice will apply to sections of the Rollup Platform not specifically identified within an applicable agreement including trial subscriptions.
2. Personal Data
2.1. What Is Personal Data
“Personal Data“ means any data or information, in any form or medium, that on its own or when combined with other data could identify a particular individual, or any other data or information that constitutes personal data or personal information under applicable law. Personal Data does not include publicly available information, as defined by applicable law, de-identified information, or aggregated data.
2.2. What Personal Data We Collect
The following describes the categories of Personal Data we may collect from you.
Personal Identifiers: such as name, alias, signature, postal address, phone numbers, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, and account name.
Commercial information: such as records of personal property, products or services purchased, obtained, or considered; and other purchasing or consuming histories. We may also collect customer record information, such as billing or service address, contracting contact information, and similar account details or any combination of the previously mentioned.
Protected Classifications: such as race, color, sex, sexual orientation, gender identity (including preferred pronouns), or other similar information.
Sensitive Personal Data: such as Protected Classification data as described above.
Financial Information: such as payment history, bank account information, bank statements, tax information, credit or debit card number, other financial information for purposes of contracting, or payments.
Internet and Network Activity Data (“Usage Data”): (“Usage Data”): such as information required to provide access to Rollup’s IT systems and networks, including IP addresses, log files, and login information, the type of Web browser you use; device type; your operating system; your web request; your Internet Service Provider and cookies; referring/exit pages and URLs; payload errors, the pages you view and how you interact with links; the time and duration of your visits to the Sites or use of the Rollup Platform.
Geolocation Data: such as region, country, state, postal code, or location information we may derive from your IP address, event or visitor badging.
Audio, Visual, and Similar Information: such as CCTV footage, photographs, and audio/video recordings (e.g., recorded meetings and webinars, whether in person or virtual).
Professional Information: such as professional or employment-related information such as current and former employer(s) and position(s), office location, business contact information, professional memberships.
Educational Information: such as information about Rollup certifications or training, licensing, or education history.
Inferences: such as inferences drawn from any of the information identified above, such as a summary of financial performance for financing and insurance as necessary as well as usage history of Rollup Sites and predictions about consumer preferences.
3. Sources
3.1. Where we Collect Personal Data
The Personal Data we collect about you is collected from you directly. In some cases, we may collect Personal Data automatically when you engage with Sites, Services, networks, and technology resources. Rollup may also collect Personal Data through our services providers, as further described below.
3.2. Categories of Sources:
You: We may collect Personal Data directly from you when you engage with the Sites, set up accounts, sign up for or engage in any of our Services, register for Events, contact customer support via telephone or email, engage with Social Media, engage with our Services, conduct Site Visits, or otherwise contact us.
Other Sources: We may receive information about you from other sources, including your company, third parties, Rollup customers or authorized users, referrals, or visitors. To the extent permitted by applicable law, we may combine this data with information we already have about you. If others give us your Personal Data, we will only use that Personal Data for the purpose of providing, supporting, and improving Rollup services and other purposes that are compatible with the specific reason for which it was provided to us (for example, as part of a referral or marketing campaign). Examples of other sources include:
Affiliates or Subsidiaries: we may collect Personal Data about you from our affiliates or subsidiaries.
Rollup Customers: we may collect Personal Data about you from our customers who you share your data with for purposes of the use of the Rollup Platform.
Service Providers or Other Third Parties: we may collect Personal Data about you from Service Providers who provide services on our behalf, such as vendors that assist us with marketing efforts or that perform web hosting services, or from other third parties that provide data collection services.
Publicly Available Sources: we may collect Personal Data about you from publicly available sources such as social media (e.g., LinkedIn).
Automatically Collected Data: We automatically collect Usage Data regarding the actions you take on the Sites, Services, Direct Sales and the Rollup Platform from your browser, device, or network activity. This type of data helps us understand trends in our users’ needs so we can better consider new features or otherwise tailor the Sites and Rollup Platform.
4. Sharing Data
4.1. Recipients with Whom We Disclose Personal Data
Affiliates and subsidiaries: We disclose your Personal Data with our global affiliates, subsidiaries, and agents of Rollup as may be necessary to manage our working relationship with you and our customers.
Customers with whom you are affiliated: If you are granted access to our Services by a Rollup customer, we may disclose your Personal Data with the customer responsible for your access to our Services to the extent this is necessary for verifying accounts and activity; investigating suspicious activity; or enforcing our contract terms, terms of use, and policies.
Third party networks and websites: With third-party social media networks, advertising networks, and websites, so that Rollup can market and advertise on third party platforms and websites.
Service Providers: We may disclose your Personal Data with service providers that process Personal Data on behalf of Rollup to provide services (“Service Providers”). For example, we contract with Service Providers to provide certain services, such as hosting and maintenance, accounting, data analytics, and data storage and management, most of which are located in the United States. We only provide our Service Providers with the Personal Data necessary for them to perform these services on our behalf. Our Service Providers must generally agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, to protect your Personal Data from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Data other than as specified by Rollup.
Contractors: We may make your Personal Data available to contracted entities and individuals for limited Rollup business purposes. Contractors are contractually subject to data protection terms and requirements.
Regulatory and Government Entities: We may disclose your Personal Data with administrative, law enforcement, and regulatory agencies; tax authorities; corporate registries; and other public agencies or authorities. Rollup will cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Data and any other content and information about you to government or law enforcement officials or private parties, if necessary, in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of Rollup or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.
Acquirer or Successor of Rollup: Potential or actual buyers (and their representatives, agents, and advisers) in connection with any proposed purchase, merger, acquisition, reorganization, or other similar corporate event.
Partners: At your direction, we may disclose your Personal Data with integration partners, referral partners, reseller partners, and marketplace partners, with whom you interact via Rollup.
Forums, Public Profiles, and Chat Rooms: Please be aware that whenever you disclose Personal Data on a publicly available page or any other public forum on the Sites or Rollup Platform, others may access that Personal Data. In addition, please remember that when you disclose Personal Data in any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such Personal Data can potentially use it for any purpose, including sending unsolicited communications.
5. Using Data
5.1. How We Use Your Personal Data
We collect Personal Data from you only where we have your consent to do so, where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.
Our purposes for collection include:
Auditing: Verifying data and auditing compliance with technical and organizational standards.
Security: Helping to ensure network, physical, and information security.
Improvements: Debugging and errors analysis, crash reporting, and analytics to improve existing intended functionality of Sites and Services.
Notifications: Providing non-personalized advertising and notifications as part of interaction with Sites and Services, including the Rollup Platform.
Provisioning the Activities: Performing or providing the Activities described above including maintaining or servicing accounts, profile management, providing customer service, processing or fulfilling orders and transactions, verifying information, processing payments, providing analytic services, providing storage, trial access, or providing functions.
Marketing and Engagement: Providing advertising and marketing services, event and newsletter subscription services, surveys, contests, other special offers, and Rollup Stories (Customer highlighted stories and imagery).
Internal Research and Development: Providing internal research for technological development and market analysis.
Prevent Fraud: Detecting, investigating, and preventing fraudulent transactions and other illegal activities.
Corporate Governance: Reporting and adherence to corporate governance requirements
Legal Compliance: Providing legal or regulatory compliance, including reporting possible criminal acts or threats to public security to a competent authority, reporting to data protection authority, or applicable court order.
We may also collect and use data for carrying out any other limited purpose described to you at the time the information was collected.
6. How We Use Usage Data
We may store Usage Data itself and such information may be included in databases owned and maintained by Rollup affiliates, agents, service providers, or third-party advertising and analytics providers. We may use such information and pool it with other information, for example, to track the total number of visitors to our Sites or authorized users of the Rollup Platform, or each page of our Sites, and your use of the software, including where and when you click a certain section of our Sites. . We use this information to help us understand how people use the Sites and Rollup Platform, support our advertising and marketing efforts, and to enhance our Services.
7. Tracking Technologies
Cookies and Web Beacons: We may use cookies (a small text file placed on your computer to identify your computer and browser) and web beacons (a file placed on a website that monitors usage) to improve the experience of the Sites and Rollup Platform, such as pre-populating your username for easier login, to allow user-specific messaging, or to permit user-specific advertising.
For more information on cookies, third-party cookies, and cookie management options, please see our Cookie Notice.
You can remove persistent cookies and change your privacy preferences by following directions provided in your Internet browser's “help” directory, or by clicking the Cookie Settings button above. However, certain features of the Sites or Rollup Platform may not work if you delete or disable cookies. Some of our service providers may use their own cookies and web beacons in connection with the services they perform on our behalf, as further explained below.
We and our partners use similar technologies to analyze trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level.
Third-party Technologies: Third parties, such as ad servers, ad networks, and data exchanges (“Advertisers”) may place or recognize a unique cookie on your computer or use other technologies such as web beacons so that they can tailor their advertisements to your apparent interests and deliver those advertisements to you while you are on our Sites. In addition, Advertisers use technologies (such as cookies, pixels, and web beacons) to collect information about your browsing behavior on our Sites which they may match with information they have previously collected. Our Privacy Notice does not cover any use of information that Advertisers may collect from you or that you choose to provide to them. For information about how to opt out of receiving certain behavioral advertisements, please visit this website (or this one if located in the European Union). Please note this does not opt you out of being served ads, you will continue to receive generic ads. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.
Social Media Widgets: Our website includes social media features, such as the Facebook Like button, and widgets, such as the “Share this” button or interactive mini-programs that run on our website. These features may collect your Internet Protocol address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy statement of the company providing the features.
8. Children's Privacy
We do not knowingly collect Personal Data from children under the age of 16. If we become aware that we have inadvertently received Personal Data from a child under the age of 16, we will delete such information from our records.
9. Security
Rollup implements appropriate physical, operational, and technical safeguards designed to help protect your Personal Data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to the Personal Data we collect or use. We also contractually require that our Service Providers protect such information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.
Please be aware that despite our efforts, no data security measures can guarantee security. As a result, while we strive to protect Personal Data transmitted on or through the Sites, we cannot and do not guarantee the security of any information you transmit on or through the Sites. Devise-users are responsible for the protection of personal devices and password credentials.
Rollup also engages in a responsible disclosure program. The program invites you to help bolster existing security measures and adapt to the ever-changing threat environment. If you become aware of a vulnerability, please see our Reporting a Vulnerability page. If you become aware of an error in disclosure of any Personal Data, you may also email privacy@Rollup.ai.
10. Data Retention
We will retain your information for as long as we have an ongoing business relationship with you or the business needs to do so (for example: to comply with applicable law, tax requirements, or enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Data, we shall either delete or de-identify it, or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible. If we collect or use de-identified information, we will not attempt to re-identify it.
10.1. Where We Process and Store Your Personal Data
From time to time, for the purposes described in this Privacy Notice, your Personal Data may be processed by us and our vendors (subprocessors) outside your home jurisdiction, including in the U.S. and other countries. These countries may have data protection laws that are different from the laws of your country. Rollup only transfers Personal Data to another country, including to its subsidiaries and other affiliates, in accordance with applicable data privacy laws, and provided there is adequate protection in place for the data.
We have taken reasonable measures to require that your Personal Data will remain protected in accordance with this Privacy Notice and applicable regulations. For more information about the subprocessors related to the Rollup Platform, please contact us at legal@rollup.ai.
10.2. Third Parties/Links
Our Sites and Rollup Platform may contain links or integrate with other websites and online services or allow others to send you such links. Rollup is not responsible or liable for any damage or loss related to your use of any third-party website or online service, including through the Rollup Marketplace. You should always read the terms and conditions and Privacy Notice of a third-party website or online service before using it, whether directly or in connection with your use of the Sites or the Rollup Platform.
10.3. Your Rights
You may opt not to disclose Personal Data to us, but keep in mind some Personal Data may be needed to register with us or to use some of our features. If we have collected and processed your Personal Data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
Please note that we may still use any aggregated and de-identified Personal Data that does not identify any individual and we may also retain and use your Personal Data As necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.
11. Your Data Rights
You have several rights with respect to your Personal Data, as further described in this section.
11.1. How to Update and Access Your Personal Data
It is important that the Personal Data contained in our records is both accurate and current. We may offer various self-help functions within our Site, tools, and Services that will allow you to update your Personal Data in our records. If we have Personal Data that you cannot access via these self-service systems, then you may make a request through the Privacy Team by email at privacy@Rollup.com.
Depending on applicable Local Laws, you may have additional rights with regard to your Personal Data. Below is an explanation of your privacy rights. Please note, these rights do not conflict with any rights you may have under the applicable Local Law. Rollup will not discriminate against you for exercising any of your privacy rights.
11.2. Data Subject Rights
Subject to conditions set forth in applicable data protection legislation, you may have the following rights:
- Right to Know/Be Informed - You have the right to know and understand what Personal data we collect and how we process it.
- Right to Access - You have the right to request access to any Personal Data concerning you, subject to limited exceptions that may be prescribed by applicable law.
- Right to Correct (Rectification) - Rollup aims to ensure that all of your Personal Data is correct. You are entitled to have any inadequate, incomplete or incorrect Personal Data corrected (that is, rectified).
- Right to Withdraw Consent - In the event your Personal Data is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
- Right to Data Portability - Where we rely upon your consent as the legal basis for processing, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the Personal Data is processed by automated means, you have the right to receive all such Personal Data which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
- Right to Erasure - You are entitled to have your Personal Data erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds or where Personal Data is unlawfully processed.
- Right to Restriction of Processing (Limit Use and Disclosure) - You have the right to restrict our processing of your Personal Data under the below circumstances. Where your Personal Data is subject to restriction we will only process it with your consent or for the establishment, exercise or defense of legal claims. This may occur:
- If you contest the accuracy of the Personal Data, until we have taken sufficient steps to correct or verify its accuracy;
- where the processing is unlawful but you do not want us to erase the Personal Data;
- where we no longer need your Personal Data for the purposes of the processing, but you require such Personal Data for the establishment, exercise or defense of legal claims; or
- where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.
- Right to object to processing justified on legitimate interest grounds - Where we are relying upon legitimate interest to process Personal Data, you may have the right to object to that processing based on grounds related to your particular situation. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the Personal Data for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
- Right to lodge a complaint - You may lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement. Contact details for data protection authorities in the EEA, Switzerland, and certain other countries are available here.
11.3. Exercise your Rights
To obtain further information regarding your rights, to exercise any of your rights (other than to lodge a complaint), or to ask any questions regarding the processing of your Personal Data, please contact the Privacy Team by email at privacy@Rollup.com.
Only you or someone legally authorized to act on your behalf may make a verifiable consumer request related to your Personal Data. You may also make a verifiable request on behalf of your minor child. You may designate someone as an authorized agent to submit requests and act on your behalf. We will respond to all requests in accordance with applicable laws. We may ask you for information to verify your identity and evaluate your privacy rights request.
Marketing Communications: You can opt out of receiving promotional or marketing communications from us at any time by using the unsubscribe link in the email communications we send or by contacting us using the contact details provided in the How to Contact Us section below. If you set up an account on our Sites, we will still send you non-promotional communications like service-related emails.
If you want your phone number to be added to our internal Do-Not-Call telemarketing register, please contact us by using the information in the How to Contact Us section below. Please include your first name, last name, company and the phone number you wish to add to our Do-Not-Call register. Alternatively, you can always let us know during a telemarketing call that you do not want to be called again for marketing purposes.
11.4. Your rights where you have been granted access to the Rollup Platform by a customer
As described above, we may also process Personal Data submitted by or for a customer. To this end, unless stated otherwise in this Privacy Notice or in a separate disclosure, we process such Personal Data as a processor/service provider on behalf of our customers. If your data has been submitted to us in our role as a processor/service provider and you wish to exercise any rights you may have under applicable data protection laws, please directly inquire with the customer that granted you access to the Rollup Platform. Because we may only access a customer’s data upon their instructions, if you wish to make your request directly to us, please provide us with the name of the Rollup customer(s) and project name(s) relevant to your request. We will refer your request to that customer, and will support them as needed in responding to your request.
12. Privacy Notice Changes
This Privacy Notice is reviewed and updated periodically to ensure it accurately describes our practices and procedures. We may also make updates or changes to this Privacy Notice because of changes in applicable laws or regulations. Any changes made to this Privacy Notice are effective as of the “Last Updated“ reference above. For material adverse changes, we will take additional measures to inform you of changes, such as by posting a prominent notice on our Site and if possible, contact you at the email you have provided us.
13. How To Contact Us
If you have questions or concerns about our use of your Personal Data, please contact us at:
Rollup Systems, Inc. 1710 Rose St Berkeley, CA, 94703
privacy@Rollup.com
14. California Privacy Rights
This section of the notice provides additional information for California residents and describes our information practices pursuant to the California Consumer Privacy Act 2018, as amended by the California Privacy Rights Act 2020, and its implementing regulations (“CCPA”).
The CCPA provides California residents with certain rights regarding their Personal Data. Please note, these rights only apply to Personal Data we collect and process from website visitors under this Privacy Notice as a Business. For Personal Data we process on behalf of our customers in our capacity as a service provider or processor, please submit your request directly to the customer with whom you have a relationship, and we will provide reasonable assistance to that business client as necessary to enable them to respond to your requests to exercise your privacy rights. In general, California residents, including our customer's employees who reside in California, have the following rights with respect to their Personal Data, subject to certain exceptions:
Right to know/access: you have the right to request (subject to certain exemptions and exceptions):
- The categories or Personal Data we collected about you;
- The categories of sources from which the Personal Data is collected;
- Our business or commercial purposes for collecting, selling, or sharing Personal Data;
- The categories of third parties to whom we have disclosed Personal Data; and
- A copy of the specific pieces of Personal Data we have collected about you.
Right to delete: you have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your Verifiable Consumer Request we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies;
Right to correct: you have the right to correct inaccurate information;
Right to opt-out of sale and sharing: you have the right to opt-out of the “sale” or “sharing” of personal information, as these terms are defined under the CCPA. Rollup does not sell Personal Data in the traditional sense (i.e., for money). However, the CCPA provides a broad understanding of “sale” and “sharing” which can include disclosing Personal Data for other, non-monetary benefits such as third-party data analytics and third-party advertising. To exercise your “opt out of sale” rights please click the Do Not Sell or Share My Personal Information link at the bottom of our Site, fill out the Rollup Privacy Rights Request Web Form, or contact us at privacy@Rollup.com. You also have the right to opt-out of “sales” and “sharing” of your personal information through the use of an opt-out preference signal. If our Site detects that your browser or device is transmitting an opt-out preference signal from a “global privacy control” or “GPC” signal, we will opt that browser or device out of cookies on our Website that result in a “sale” or “sharing” of your personal information. To learn more about GPC signals and implementation, please see https://globalprivacycontrol.org. If you come to our Site from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well. We do not sell or share Sensitive Personal Information, nor do we sell or share any Personal Data about individuals who we know are under sixteen (16) years old.
Right to limit use/disclosure: you may have the right to limit the use and disclosure of Sensitive Personal Information.
Right to non-discrimination: we will not discriminate against you for exercising any of the rights described in this section.
If you are a California resident and would like to exercise your CCPA rights, you may do so via any of the methods described below:
Email us at privacy@Rollup.com
Before responding to your request, we must first verify your identity using the Personal Data you recently provided to us. You must provide us with your name, street address, city, state, zip code and an e-mail address or phone number. We will take steps to verify your request by matching the Personal Data provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.
You may designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
15. California Shine the Light Law
Rollup does not disclose Personal Data to third parties for the third-parties' direct marketing purposes, under Cal. Civ. Code §1798.83(d).