PRIVACY POLICY

Last Updated: November 8, 2024

This Privacy Policy explains how personal data about you is collected, used and disclosed by Bully Pulpit Interactive, LLC ("BPI") to provide this Website and products and services offered by BPI. This Privacy Policy describes the personal data we collect and how we use it. By using this website (https://www.bpigroup.com/) (“Website”), you consent to our Privacy Policy. This Privacy Policy does not apply to any other websites developed or hosted by BPI or other products and services not mentioned in this Privacy Policy.

Website Privacy Policy

Information You Provide to Us

  • Information from your inquiries into our services, or how you otherwise indicate you may be interested in our services, which may include providing us with your name, work email, phone number, company name, position title, website, social media links, and time zone.

  • Information when you complete an application for employment. Please see our Candidate Privacy Policy for more details about data that we collect during your application process.

  • Information associated with your interaction with BPI through our corporate social media accounts.

Information We Collect Automatically When You Use Our Website

  • Visitor Device and Log Information: We log information about your use of the Website, including the type of browser you use, access times, pages viewed, your IP address pages visited and device-specific information including the hardware model, operating system and version, unique device identifiers and mobile network information.

  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect and analyze information, and this may include associating cookies with your browser. Cookies help us to improve your experience with our Website by tracking and analyzing your activity. We may also collect information using pixel tags (also known as “web beacons”). Pixel tags are electronic images that may be used in our Websites or emails and help deliver cookies, count visits, track your activity, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon. For more information about cookies, and how to disable them, please see ‘Your Privacy Choices’ below.

Please see an overview of Cookies on our Website HERE.

Information from Third Parties

  • Our Website includes social media icons, which link to platforms like Facebook, Twitter, Instagram, YouTube, LinkedIn, and Medium. These icons allow you to connect with us via social media and make sharing content easier. If you click on a social media icon, you will be redirected to the platform’s website, where your personal information is subject to that platform’s privacy policy. We recommend reviewing each platform’s privacy policy to understand their data practices.

  • When you interact with our accounts on a social media platform, we may collect certain information that you or the platform make available to us such as your social media account ID, your social media ‘likes’, click-throughs to our Website, or custom interactions.

  • We may also engage third parties to provide additional information about business professionals who are interested in our services, engage with our Website, or interact with our ads on social media.

Use of Information

We use the personal information we collect for the following purposes:

  • To provide our services and Website.

  • To solicit new clients with advertising and marketing.

  • To provide client support or to respond to your inquiries.

  • To improve the Website, products, and other services.

  • To monitor and analyze trends, usage and activities in connection with our Website and services.

  • To comply with our agreements or policies.

  • To ensure the security of our Website and services.

  • For other business and legal purposes, such as to detect and prevent fraud, to collect amounts owing to us, and to maintain business records.

  • With your consent for any specified purpose.

How we disclose your personal information:

We may disclose your personal information with your consent. We may also share your personal information with our corporate affiliates, as well as vendors or service providers who:

  • Help us communicate with you.

  • Manage and optimize our Website and services.

  • Provide marketing and advertising services (see ‘Use Of Cookies And Tracking Technologies’ for more information on your choices with these services).

In addition:

  • We may share your personal information in order to:

    • Protect the legal rights of our company, our employees, our agents, and our affiliates.

    • Protect the safety and security of our clients or Website visitors.

    • Detect and protect against fraud.

    • Comply with law or legal process.

  • We may share your personal information as part of a business or asset transaction.

    • We may share your personal information with prospective purchasers exclusively to evaluate the proposed transaction.

    • We may also share your personal information with another company that buys the assets or stock of BPI. That company may use and disclose personal information for purposes similar to those described in this Privacy Policy.

  • Our Website may contain links to other websites or services. We do not exercise control over the information you automatically provide by clicking an external links from our Website, or is collected by these third-party websites. We encourage you to read the privacy policies or statements of the other websites you visit.

  • We may share de-identified, aggregate, or anonymous information for any purpose. This means that the information we share does not identify specific individuals or is combined with other data to protect your privacy in compliance with relevant privacy laws.

Website Visitors Privacy Choices

For visitors to our Website and our business clients, we provide you with the right to exercise the following choices with our use of your personal information.

  • Access the personal information we maintain about you.

  • Delete the personal information we maintain about you.

  • Correct inaccurate personal information we maintain about you

  • Opt out of certain uses of your personal information, notably you may unsubscribe from email marketing by clicking through the unsubscribe option in any commercial email we send you. In addition, we may use third party cookies for targeted advertising. Refer to the ‘Use of Cookies and Tracking Technologies’ in the BPI Services Privacy Policy below to learn how to opt out of these types of ads.

You can exercise these rights by contacting us at privacy@bpigroup.com or by visiting our Privacy Choices Site.  

For visitors associated with our services, including websites where we may collect personal information on behalf of our clients, please see our ‘BPI Services Privacy Policy’ below in order to exercise rights.

Retention

We will retain your personal information for as long as is necessary for the purposes set out in this Privacy Policy. The criteria we use to determine retention periods for each category of personal information are based on the type of personal information, contractual requirements, or with regards to product or service maintenance and improvements. We will also retain and use personal information as necessary to comply with our legal obligations, resolve disputes and enforce our legal agreements and policies.

BPI Services Privacy Policy

Overview

BPI is a full-service marketing and communications agency that processes a myriad of data types on behalf of our clients for varying types of services, including advertising, market research, and custom communications plans as directed by our clients. Below is a summary overview of our services and the personal information processes associated with each.

Collection of Information

1. Information Provided to Us by Clients: In order to serve our Clients, we will collect personal information directly from our clients or through our software and client support channels, including:

  • Corporate or end-user phone numbers, postal or email addresses for email marketing or targeted online advertising.

  • Billing and administrative finance information.

  • Consumer data such as demographics, behavioral, transactional, political and financial information.

2. Information Collected from Recipients Who Engage With Our Services: We collect personal information provided directly to us through our services. For example, we may collect personal information when:

  • Individuals engage with an ad or a website where we are advertising on behalf of our clients.

  • Respondents fill out surveys through a market research request.

  • Recipients interact with emails, SMS, or other communications.

The types of information we may collect include:

  • Contact information, including name, email address, postal address, phone number, and other contact or identifying information.

  • Online identifiers such as cookie ID, advertising ID, IP address.

  • Behavioral information such as clicks, website activities, and transactions.

  • Demographic or professional information that may be associated with contact information.

  • Responses to survey questions, such as behaviors, transactions, or opinions.

  • Sensitive data such as race and ethnicity or religion.

When individuals access or use websites where we place ads or solicit an engagement, we automatically collect information including:

  • Log Information: Information about use of the website, including the type of browser used, access times, pages viewed, IP address and the pages visited before navigating to the websites.

  • Device Information: Information about the computer or mobile device used to access the websites, including the hardware model, operating system and version, unique device identifiers and mobile network information.

  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect and analyze information, and this may include associating cookies or other unique identifiers with your browser or device. We may also collect information using pixel tags (also known as “web beacons”). For more information about cookies, and how to disable them, please see “Your Privacy Choices” below.

3. Consumer Personal Information We Collect From Other Sources: We may also obtain personal information from other sources and combine that with personal information we collect through advertising or other services, including:

  • Demographic and other information from third party data providers, including select information that may be deemed ‘sensitive’ under certain state laws such as race or ethnicity.

  • Interaction with ads such as views, clicks or website activities.

  • Historical behaviors and transactions, including voter history, public record transactions such as property records, and inferences modeled from geographic information.

  • Employment and education history.

  • Inferences derived and/or modeled from geographies, behaviors, or third party information.

Use of Information

We may use personal information about you for various purposes, including to:

  • Provide and deliver the products and services requested by our clients, including relevant or targeted advertising, market research, or engagement requests.

  • Respond to comments, questions and requests from recipients of our communications to provide customer service.

  • Monitor and analyze trends, usage and activities in connection with our Website.

  • Personalize and improve the Website and provide advertisements, content or features that match user profiles or interests.

  • Process and deliver contest entries and rewards.

  • Link or combine with personal information we get from others to help understand your needs and provide you with better service.

  • Carry out any other purpose for which the personal information was collected.

How We Disclose Your Personal Information

Our services provide our clients with the ability to synchronize certain external software or data applications with BPI, which may include the transfer of personal information, including:

  • Advertising and marketing services to facilitate our client campaigns.

  • Third party data services to synchronize our data for targeting, measurement, and market research purposes.

  • Customer Relationship Management software or services to enable personalized communications.

  • Phone, Email, and SMS Service Providers to facilitate messaging delivery.

Subject to client agreements, we may disclose client personal information as necessary in order to:

  • Protect the legal rights of our company, our employees, our agents, and our affiliates.

  • Protect the safety and security of those who access and use our services.

  • Detect and protect against fraud.

  • Comply with law or legal process.

  • Complete a legal transaction related to the sale of our business or any assets.

BPI may share aggregate or anonymous information for any purpose. This means that the information we share does not identify specific individuals or is combined with other data to protect your privacy.

Your Privacy Choices

Use Of Cookies And Tracking Technologies

Like many companies, we use cookies, pixels, web beacons, and other tracking technologies to collect personal information about your browsing activities, your interactions with our Website or emails, and to serve tailored ads. There are a number of ways to opt out of having your online activity and device data collected through these services, which we summarize below:

  • Blocking Cookies In Your Browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

  • Advertising Industry Opt-Out Tools. You can also use these opt-out options to limit use of your personal information for interest-based advertising online or in apps by visiting:

Retention

We will retain personal information associated with client campaigns according to the terms of our written agreements. Our data is regularly refreshed and takes into account deletion requests and accuracy changes incorporated by our data source providers.

U.S. State-Specific Notice

Some U.S. states have enacted comprehensive privacy laws. The California Consumer Privacy Act, as amended by the California Privacy Rights Act or “CPRA” (collectively, the “CCPA”), the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Montana Consumer Data Protection Act (“MCDPA”), the Oregon Consumer Privacy Act (“OCPA”), the Texas Data Privacy and Security Act (“TDPSA”), the Utah Consumer Privacy Act (“UCPA”), the Connecticut Data Privacy Act (“CTDPA”), the Delaware Personal Data Privacy Act (“DPDPA”), the Iowa Consumer Data Protection Act (“ICDPA”), the Nebraska Data Privacy Act (“NDPA”), the New Hampshire Senate Bill 255 (“SB 255”), and the New Jersey Senate Bill 332 (“SB 332”) create additional privacy obligations for businesses and provide residents of those states with additional privacy rights.

Privacy Rights

If you are a resident of California, Virginia, Colorado, Montana, Oregon, Texas, Utah, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, or Connecticut, you have the right to:

  • Opt out of the “sale or share” of your personal information for advertising purposes. Some third party cookies placed by BPI as part of our client campaigns may be considered a ‘sale or share’ when they are used for ‘targeted’ or ‘cross-contextual’ advertising campaigns. You may opt out of such cookies as detailed in the ‘Use Of Cookies And Tracking Technologies’ section (above).

  • Right to limit the use of sensitive personal information. The states listed above define the use of select demographics such as ethnicity or religion to be deemed sensitive. If you are a resident of one of these states you have the right to Opt-Out of our use of these types of data attributes.

  • Right of Access. You have the right to know what data is being collected about you, how it’s being used, and with whom it’s being shared. You can request access to view the personal data that we hold about you at any time.

  • Right to Deletion. You have the right to request that we delete your personal information under certain circumstances, such as it’s no longer necessary for the purposes it was collected or if you withdraw your consent.In some cases, we might be required under applicable laws to refuse to delete your personal information. We may also anonymize your personal information in a way that it cannot be related back to you instead of deleting it. After deletion of your personal data, we will maintain a suppression list which lists you as an opted-out user, so we do not process your personal information in the future.

  • Right to Correction. You have the right to request that we correct personal information that we hold about you.If we do not have the technical ability to correct your personal information, we will delete the incorrect personal information.

  • Right to Data Portability. You have the right to obtain a copy of your personal information that we hold about you in a portable format that allows you to transmit your personal information to another entity.

  • Right to Restrict Processing. You have the right to request that we limit how we use your personal information. We will treat such requests as deletion requests.

  • Right to Withdraw Consent. When we rely on your consent for data processing, you are free to withdraw that consent at any time without affecting the lawfulness of prior processing based on consent.

If you want to exercise any of your consumer rights, please visit our Privacy Choices Site or contact us at privacy@bpigroup.com.

International Data Transfers

This Website is based and hosted in the United States. If you access our website from outside the United States, please be aware that your personal information may be transferred to the United States. We ensure these cross-border transfers comply with applicable laws and we take necessary precautions to protect your personal information. This includes implementing standard contractual clauses approved by relevant regulatory authorities or other mechanisms to safeguard the transfer of your personal information across borders. When we transfer personal information out of the European Economic Area (“EEA”) or Switzerland, we transfer personal information subject to the Standard Contractual Clauses (“SCC”). SCC are a set of contractual terms and conditions developed by the European Commission that organizations use to ensure the safe and lawful transfer of personal information from the EEA to non-EEA countries. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. When we transfer personal data outside of the United Kingdom (“UK”), we rely on the UK SCC. For further details please see: International data transfer agreement and guidance | ICO. By using our Website and services, you consent to the transfer, processing, and storage of your personal information in countries other than your own, as outlined in this Privacy Policy.

European Data Protection

This section applies if you are in the EEA, the UK, or Switzerland. BPI uses SCC to transfer personal information from the EEA, Uk, or Switzerland to the United States.

We process your personal data based on one of the following legal bases:

·      Your consent. We process your personal data with your consent.

·      Contractual necessity. We process your personal data to fulfil a contract with you.

·      Legitimate interest. We process your personal data where processing is necessary for the purpose of our legitimate interest except where such interests are overridden by your interests or your fundamental rights and freedoms.

We only process personal data to the extent that it is limited to specific purposes, relevant, accurate and securely stored.

If you are in the EEA, you have the following rights:

·       Right to Access: You have the right to know what personal data we hold about you and how we use it.

·       Right to Rectification: You have the right to request corrections to inaccurate or incomplete data. If we do not have the technical ability to correct your personal data, we will delete the incorrect personal data.

·       Right to Erasure (Right to be Forgotten). You can request deletion of your personal data in certain circumstances, such as when it is no longer needed for its original purpose or if you withdraw your consent.

  • Right to Restrict Processing. You have the right to request that we limit how your data is processed, especially if accuracy or legality is contested. We will treat such requests as deletion requests.

  • Right to Data Portability. You can request your personal data in a machine-readable format to transfer it to another service provider.

  • Right to Object. You have the right to object to processing of your personal data based on legitimate interest or public interest, as well as to data processing for marketing and profiling purposes.

When we transfer personal information out of the European Economic Area (“EEA”) or Switzerland, we transfer personal information subject to the Standard Contractual Clauses (“SCC”). SCC are a set of contractual terms and conditions developed by the European Commission that organizations use to ensure the safe and lawful transfer of personal information from the EEA to non-EEA countries. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. When we transfer personal data outside of the United Kingdom (“UK”), we rely on the UK SCC. For further details please see: International data transfer agreement and guidance | ICO.

If you want to exercise any of your consumer rights, please visit our Privacy Choices Site or contact as at privacy@bpigroup.com.

Research Respondents

Last updated: July 2025

Information We Collect About You

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you.

Our Research Activity

As our services include finding individuals who could be research panellists, we may collate information about you using publicly available sources. These may include online sources such as LinkedIn or the websites of the businesses or institutions with which you are affiliated. We do this when requested by a client to carry out research for a particular project and may also do so proactively. We may also be provided with your information by other people – for example, if it is suggested to us by a third party that you may be interested in being a research panellist. Information collated in this way may include your name, occupation, employer, email address, phone number, location, and area of professional expertise.

The legal basis (according to article 6 of the UK GDPR) for doing so is our Legitimate Interests – we require this information in order to identify potential research panellists.

When You Contact Us

If you contact us via email, phone, post or the contact form on our website, we collect relevant information you provide to us, which may include name, email address, phone number and postal address.

The legal basis (according to article 6 of the UK GDPR) for doing so is our Legitimate Interests – we require this information in order to respond to your enquiry and provide a service.

If You Register for a Research Panel

When you register as a research panellist we require that you submit personally identifiable information, such as name, postal address, email address and phone number. We may also ask you to provide demographically relevant information, which may include special category data as set out in article 9 of the UK GDPR. We use this type of data to ensure that we have an appropriately representative panel. We hold this data in order to maintain a register of potential participants.

The legal basis (according to article 6 of the UK GDPR) for doing so is Consent – when you register as a research panellist you will explicitly give us permission to process your data for this purpose. You may withdraw this consent at any time in which case your data will be removed from the register of potential participants.

If You Participate on a Research Panel

When you are on a research panel, personal data will be collected and processed. The questions put to you during a research panel will be dependent on the client and subject matter and a briefing will be provided to you beforehand. The answers you provide will be recorded or noted down. Audio or video recordings of your participation may also be taken.

Sessions may be monitored, or recordings viewed, by our client. Our client will not be provided with your identity or demographic information from our register.

The legal basis (according to article 6 of the UK GDPR) for doing so is our Legitimate Interests – we require this information in order to carry out an analysis for our client.

Once You Have Participated in a Research Panel

The information that has been collected during a research panel will be processed in accordance with the Market Research Society Code of Practice for the purpose of producing a research report for our client. As part of this process, we seek to remove personally identifiable data before sharing the report with our client. The raw data will be held securely by BPI in accordance with our retention policy.

How Long We Keep Your Data

We only keep your data for as long as necessary.

Records will be regularly reviewed to ensure that data is not held longer than necessary.

In general, and unless we consider it necessary to retain data for longer, our retention periods are:

  • Personal data relating to general enquiries – 24 months after last contact.
  • Personal data on the register of potential participants – until consent is withdrawn where an individual has opted into research.
  • Personal data collected through participation on a research panel – 12 months after the conclusion of the project.

Where we are collating information about you using publicly available sources on the basis that you may be a potential research panellist, we will contact you up to three times to gauge your interest in being a research panellist. If we do not receive a response from you, we will not retain your data.

In the circumstances where you have either withdrawn your consent to being on the register of potential participants or you have indicated, through your lack of response, that you do not wish to be a potential participant after being contacted by us, we will retain some of your personal data (including name, occupation, employer, email address, phone number, location, area of professional expertise) solely for the purpose of ensuring we do not contact you again.

Data that is found to have passed the retention period will be destroyed in a secure manner.

Your Rights

Where you have given us consent to process your data, you have the right to withdraw your consent at any time. You can do this by contacting BPI directly using the contact details below.

You also have the following rights regarding your data:

  • The right to request to access your personal data.
  • The right to rectify any errors if your personal data is inaccurate or incomplete.
  • The right to request the deletion or removal of personal data.
  • The right to request that restrictions are placed on the processing of their personal data.
  • The right to object to the processing of your data.

Requests in regards to these rights should be made using the contact details below and we will respond within a month.

Candidate Privacy Policy

Children's Privacy

Our Website is designed for business professionals. Our Website is not intended for children under the age of 18 years. We do not knowingly and intentionally collect information from children. If we learn that we have collected data from a child without the required legal consent, we will promptly delete it. If you believe we have obtained personal information associated with children or minors, please contact us at privacy@bpigroup.com and we will delete it.

Security

BPI takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. These safeguards include technical, organizational, and administrative measures.

Contact Us

If you have any questions about this Privacy Policy or if you want to exercise your rights, please contact us at privacy@bpigroup.com.

Or by postal at: Bully Pulpit Interactive, LLC | 1445 New York Ave. NW, 5th Floor, Washington, DC 20005 Attn: Legal Department

If you want to exercise any of your consumer rights, please visit our Privacy Choices Site.