Privacy Policy

Last updated: March 1, 2026  ·  Effective: March 1, 2026

1. Introduction

Undercurrent Data, LLC ("Undercurrent," "we," "our," or "us") operates a district-level political intelligence platform that converts behavioral content consumption signals from across the open web into actionable intelligence for political professionals. This Privacy Policy explains how we collect, use, disclose, and protect information in connection with our website (undercurrentdata.com), our platform services, and any interactions you have with us.

By using our website or services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described here, please do not use our website or services. This Privacy Policy may be updated periodically; we will notify you of material changes by posting the updated policy on this page with a new effective date.

Undercurrent is an intelligence and analytics product. We do not operate as a consumer-facing data broker. Our services are directed exclusively at business customers — political professionals, campaign organizations, public affairs firms, and related entities — who engage with us under separate contractual terms.

2. Information We Collect

2.1 Information You Provide Directly

When you contact us, request a demo, or engage with our sales or onboarding processes, we may collect:

• Name and professional title
• Business email address and phone number
• Organization or company name
• Information about your intended use of the platform
• Payment and billing information (processed by our payment processor; we do not store full card numbers)
• Communications you send to us, including emails and form submissions

2.2 Information Collected Automatically

When you visit our website, we and our service providers may collect certain information automatically, including:

• IP address and approximate geographic location
• Browser type, device type, and operating system
• Pages viewed, time spent on pages, referring URL
• Session identifiers and interaction logs

We use this information to operate and improve our website, understand how visitors engage with our content, and diagnose technical issues.

2.3 Platform Input Data (Customer Data)

When customers use our audience matching capabilities, they may upload lists (voter files, donor lists, or similar contact information). This data is processed solely for the purpose of generating the match analysis report requested by the customer. We do not use customer-uploaded list data for any purpose beyond the specific analysis session, and we do not share, sell, or retain it beyond the contractual data retention period specified in the applicable service agreement.

2.4 Signal Data and Aggregated Intelligence

The Undercurrent platform is built on aggregated, district-level signal data derived from privacy-compliant behavioral content consumption signals across the open web. This data is processed and analyzed in aggregate form at the congressional district level. The Undercurrent platform does not produce, store, or transmit individual user profiles. All intelligence outputs are aggregated to the district level before delivery to platform users.

3. How We Use Information

We use the information we collect to:

• Operate, maintain, and improve the Undercurrent platform and website
• Process demo requests, onboard new clients, and manage customer relationships
• Respond to inquiries, provide customer support, and communicate about our services
• Send product updates, usage reports, and communications relevant to active service agreements
• Analyze website and platform usage to improve our products
• Comply with applicable legal obligations and enforce our Terms of Service
• Detect, investigate, and prevent fraudulent activity or other security incidents
• Process payments and manage billing

We do not sell, rent, or share your personal information with third parties for their own marketing purposes. We do not use personal information submitted through contact or demo request forms for any purpose other than fulfilling the request and managing the resulting business relationship.

4. Legal Basis for Processing (EEA/UK)

If you are located in the European Economic Area or the United Kingdom, our legal basis for processing your personal information depends on the type of information and the context in which we collect it. We typically process information under the following bases:

• Performance of a contract: Processing necessary to fulfill a service agreement or respond to a service request.
• Legitimate interests: Processing necessary for our legitimate business interests, including improving our services and communicating with prospective customers, where those interests are not overridden by your rights and interests.
• Consent: Where we have obtained your consent to specific processing activities.
• Legal obligation: Processing required to comply with applicable law.

5. Sharing of Information

We may share your information with:

• Service providers: Third-party vendors who assist us in operating our website and platform, including cloud infrastructure providers, payment processors, email delivery services, and CRM providers. These vendors are contractually bound to process information only on our behalf and in accordance with our instructions.
• Professional advisors: Attorneys, accountants, and other professional advisors where necessary to manage our legal and business affairs.
• Legal requirements: We may disclose information where required by law, court order, or regulatory authority, or where disclosure is necessary to protect the rights, property, or safety of Undercurrent, our customers, or the public.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of our assets, information may be transferred to the acquiring entity, subject to the same privacy commitments described in this policy.

We do not sell personal information. We do not share personal information with political campaigns, PACs, or other third-party organizations for targeting or outreach purposes.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this policy, comply with applicable legal obligations, resolve disputes, and enforce our agreements. Specific retention periods vary by data type:

• Contact and demo request information: retained for up to 3 years from last interaction, unless a business relationship is established, in which case records are retained for the duration of the relationship plus a reasonable period thereafter
• Customer-uploaded list data: retained only during the analysis session and for up to 30 days thereafter, unless shorter retention is specified in the applicable service agreement
• Website analytics data: retained in accordance with our analytics provider's standard retention periods, generally not exceeding 26 months
• Billing and payment records: retained as required by applicable financial and tax regulations, generally for a minimum of 7 years

7. Your Rights and Choices

Depending on your location, you may have certain rights with respect to your personal information, including the right to:

• Access the personal information we hold about you
• Correct inaccurate or incomplete personal information
• Request deletion of your personal information, subject to certain exceptions
• Object to or restrict certain processing activities
• Request portability of your personal information in a structured, machine-readable format
• Withdraw consent where processing is based on your consent

To exercise any of these rights, please contact us at privacy@undercurrentdata.com. We will respond to your request within the timeframe required by applicable law. We may need to verify your identity before processing certain requests.

8. Cookies and Tracking Technologies

Our website may use cookies and similar tracking technologies to improve the user experience, analyze traffic, and support our operational needs. These may include:

• Strictly necessary cookies: Required for basic website functionality. Cannot be disabled.
• Analytics cookies: Help us understand how visitors use our website. You may opt out of analytics cookies through your browser settings or by using opt-out tools provided by our analytics vendors.

Most web browsers allow you to control cookies through browser settings. Disabling certain cookies may affect the functionality of our website.

9. Security

We implement reasonable technical and organizational measures to protect your information against unauthorized access, loss, misuse, or alteration. Our security practices include encryption of data in transit and at rest, access controls limiting data access to authorized personnel, regular security reviews of our systems and processes, and contractual data security requirements for our service providers.

No security measures are perfect or impenetrable. We cannot guarantee the absolute security of your information, and we encourage you to take steps to protect the security of your own systems and access credentials.

10. Children's Privacy

Our services are directed exclusively at business and professional users. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected personal information from a minor, we will take steps to delete it promptly. If you believe we may have collected information from a minor, please contact us at privacy@undercurrentdata.com.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. We will indicate the date of the most recent update at the top of this page. For material changes, we will provide additional notice as appropriate, such as by email to active customers or by displaying a notice on our website. Your continued use of our services after the effective date of an updated policy constitutes your acceptance of the changes.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Undercurrent Data, LLC
privacy@undercurrentdata.com
hello@undercurrentdata.com