Effective Date: August 25, 2026

1.0 Introduction

Conduit Street Services, LLC ("we", "us", "our", or "Conduit Street Services") respects the privacy of the individuals whose information we hold and is committed to protecting it through our compliance with this privacy policy ("Privacy Policy"). This Privacy Policy describes the types of information we collect, how we collect it, and our practices for using, maintaining, protecting, and disclosing that information.

In plain terms: we operate communication and fundraising services for political organizations and non-profits. We send messages from our own systems, using data held in our own systems. We do not sell personal information, and our clients do not receive access to our database.

2.0 What Does This Privacy Policy Cover?

This Privacy Policy applies to information we collect:

This Privacy Policy does not apply to information collected by any third party, including through any website, application, or content that may link to or be accessible from our website. When you provide information directly to one of our clients — for example, by making a donation or signing up on a client's website — that client's privacy policy governs that information.

3.0 Individuals Under the Age of 18

We do not knowingly collect, solicit, or maintain Personal Information from anyone under the age of 18. If you are under 18, please do not send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 18, we will use commercially reasonable efforts to delete that information from our database. Please contact us at privacy@conduitstreetservices.com if you have any concerns.

4.0 Changes to Our Privacy Policy

We may need to change this Privacy Policy from time to time. When we do, we will post the updated policy on this page with a new effective date, and for material changes we may provide additional notice on our website. Your continued use of our services after changes are posted means you accept the updated policy.

5.0 Information We Collect About You and How We Collect It

5.1 Categories of Information

We collect the following types of information about individuals:

We do not collect social security numbers, driver's license numbers, financial account numbers, or precise geolocation data. Please do not send them to us.

5.2 Information You Provide to Us

The information we collect on or through our website may include:

5.3 Message Measurement Technologies

The email messages we send may contain standard measurement technologies, such as tracked links and small image pixels, that tell us whether a message was opened or a link was clicked. We use this engagement data to manage deliverability and improve our services.

5.4 Information We Receive From Third Parties

5.4.1 Clients

Clients may provide us with their own contact lists so that we can perform services for them. Client lists remain the client's property, and we never sell, rent, or provide them to anyone else as a list. When a client provides us a list, we ingest that data into our systems with markers identifying its owner, and, under our agreements with our clients, we may combine information from client-provided records with information we already hold about the same individuals and use the combined information to operate and improve our services — including audience selection and data quality — on an ongoing basis, including after a client engagement ends.

If you respond to a communication sent through our services — for example, by donating or signing up with one of our clients — that client may share the resulting information with us, and we may retain it in our systems under our agreement with that client.

5.4.2 Licensed Data Providers

We license information from commercial data providers, including voter-file vendors whose data is compiled substantially from government and other public records.

5.4.3 Public Records

We collect publicly available information, including federal and state campaign-finance records of political contributions.

6.0 Cookies and Website Tracking

Our website does not use advertising cookies, analytics trackers, social media plugins, or third-party advertising networks. We do not sell or share personal information collected through our website, and we do not serve targeted advertising.

7.0 How We Use Your Information

We use the information that we collect about you or that you provide to us for the following purposes:

8.0 How We Share Your Information

8.1 What We Do Not Do

We do not sell personal information. We do not rent or sell lists, we do not provide anyone's information to third parties as a list or compilation, and we do not append our data to client records. Our clients engage our services; they do not receive access to our database. We do not provide raw identifiers — names, email addresses, or phone numbers — to clients or to vendors acting for them. Personal information stays within our systems and those of the service providers who operate them on our behalf.

When someone opts out of messages we sent for a particular client, we may give that client — or the vendor who submitted the content on that client's behalf — a file containing only a cryptographic hash of the opted-out identifier and the date of the opt-out, so they can match it against records they already hold and honor the request. A hash is not a contact list. If they cannot match it, we do not provide the underlying identifier.

8.2 When You Respond to a Message

If you receive a communication sent through our services and choose to act on it — for example, by making a donation or filling out a form on a client's website — you are providing your information directly to that client (or its payment processor), and that client's privacy policy governs it. We do not control how clients use information you give them directly. As described in Section 5.4.1, the client may share the resulting information with us, and we may retain it in our systems.

8.3 Service Providers

We use third-party vendors to operate our infrastructure, such as cloud hosting providers and message delivery services. These vendors process personal information only to perform services for us and are subject to contractual confidentiality and data-protection obligations.

8.4 Aggregate and De-Identified Information

We may use and share aggregated or de-identified information — such as campaign performance reports, delivery statistics, and engagement summaries — with our clients, in our own marketing materials, and with third parties. This information does not identify individuals.

8.5 Legal Requirements

We may disclose Personal Information if required to do so by law, court order, legal process, or subpoena, including to respond to any government or regulatory request. We may also disclose your Personal Information if we believe that such action is necessary to:

8.6 Business Transfers

If Conduit Street Services is involved in a merger, acquisition, reorganization, or sale of some or all of its assets, Personal Information held by us may be among the assets transferred. Any successor will be required to handle Personal Information consistent with this Privacy Policy or to provide notice of material changes.

9.0 How Long Do We Keep Your Personal Information?

We keep personal information as long as it is necessary for the purposes for which we obtained it, unless you ask us to delete it or suppress it at an earlier time. Suppression records — the record that you asked not to be contacted — are retained indefinitely so that your request stays honored.

10.0 Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.

11.0 Opting Out of Communications

You can stop receiving communications sent through our services at any time, at no cost, with no documentation required:

By providing us with your email address, you consent to our using the email address to send you service-related notices.

12.0 Additional Information for Users Located in the European Economic Area ("EEA") and United Kingdom

We do not intentionally collect personal data from residents of the European Economic Area or the United Kingdom. Our services are designed for and targeted to residents of the United States. If you are an EEA/UK resident and believe we have inadvertently collected your personal data, please contact us at privacy@conduitstreetservices.com to request deletion. If we do process personal data of EEA/UK residents, such data will be transferred to and processed in the United States, and EEA/UK residents may have rights under the General Data Protection Regulation, including rights of access, rectification, erasure, restriction, portability, and objection.

13.0 U.S. State Consumer Privacy Rights

13.1 Universal Consumer Rights

If you are a resident of any U.S. state, you may have the following rights regarding your personal information, depending on your state of residence:

We honor requests exercising these rights from all U.S. residents, regardless of which state you live in. Submit any request as described in Section 14.

13.2 California Consumer Privacy Rights (CCPA/CPRA)

If you are a California resident, you have rights under the California Consumer Privacy Act and California Privacy Rights Act, including the rights to know, delete, correct, opt out of sale or sharing, and limit the use of sensitive personal information, and the right not to be discriminated against for exercising these rights. You may designate an authorized agent to make privacy requests on your behalf. Details of our collection practices — the categories of personal information we collect, our sources, our business purposes, and the categories of service providers who process it — are described in Sections 5, 7, and 8 of this policy.

13.3 Maryland Consumer Privacy Rights (MODPA)

If you are a Maryland resident, you have rights under Maryland's Online Data Privacy Act, including the rights to know, access, correct, delete, obtain a portable copy, and opt out of targeted advertising, sale of personal data, and profiling that produces legal or similarly significant effects. We do not knowingly sell personal data of consumers under 18 or process personal data of consumers under 18 for targeted advertising.

13.4 Virginia Consumer Privacy Rights (VCDPA)

If you are a Virginia resident, you have rights under the Virginia Consumer Data Protection Act, including the rights to know, access, correct, delete, obtain a portable copy, opt out of targeted advertising, sale, and profiling, and appeal our decision regarding your privacy request.

13.5 Colorado Consumer Privacy Rights (CPA)

If you are a Colorado resident, you have rights under the Colorado Privacy Act, including the rights to know, access, correct, delete, obtain a portable copy, and opt out of sale, targeted advertising, and profiling that produces legal or similarly significant effects.

13.6 Connecticut Consumer Privacy Rights (CTDPA)

If you are a Connecticut resident, you have rights under the Connecticut Data Privacy Act, including the rights to know, access, correct, delete, obtain a portable copy, and opt out of sale, targeted advertising, and profiling that produces legal or similarly significant effects.

13.7 Additional State Privacy Rights

If you are a resident of another state with a comprehensive privacy law — including Utah, Iowa, Tennessee, Montana, Oregon, Texas, Florida, New Jersey, or Delaware — you may have similar rights under your state's law. We honor the rights listed in Section 13.1 for all U.S. residents, so you do not need to determine which statute applies to you before making a request.

13.8 Sensitive Personal Information

We do not knowingly collect or process sensitive personal information, including:

We have implemented processes to identify and remove sensitive data from our databases in compliance with applicable privacy laws.

13.9 Data Minimization

We collect only personal data that is reasonably necessary and proportionate to provide our services. We do not collect data beyond what is necessary for the specific purposes disclosed in this policy.

13.10 Response Times

We will acknowledge receipt of your privacy request within 10 business days and respond to your request within 45 days, as required by applicable law. We may extend this timeframe by an additional 45 days when reasonably necessary, and we will notify you of any extension.

13.11 Identity Verification

Opt-out and suppression requests require no identity verification — we act on the email address or phone number you ask us to suppress. For requests to access, correct, or delete personal information, we verify your request by matching the information you provide against our records. We will only ask for additional information if we cannot verify your identity with what you have provided, and we will never require more information than is reasonably necessary.

13.12 Appeals Process

If we deny your privacy request, you have the right to appeal our decision. We will provide information about our appeals process in our response to your request.

14.0 How to Submit a Privacy Rights Request

To submit a privacy rights request, email us at privacy@conduitstreetservices.com and tell us:

For opt-out and suppression requests, that is all we need. No identification, mailing address, or declaration is required.

For access, correction, and deletion requests, we may follow up if we need additional information to verify your identity or locate your records, as described in Section 13.11.

Response Timeline

We will acknowledge receipt within 10 business days and respond within 45 days as required by law.

Alternative Contact Methods

Mail:

Conduit Street Services, LLC

PO Box 5

Millersville, MD 21108

15.0 Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

Conduit Street Services, LLC

PO Box 5

Millersville, MD 21108

Email: privacy@conduitstreetservices.com