Privacy Policy

MORNING CONSULT®
PRIVACY POLICY


Table of Contents

 

INTRODUCTION

The Morning Consult LLC (“Morning Consult” (or “we” or “us” or “our”)) cares about your privacy and the security of your information, and we want you to understand how we collect, use, store, process, and disclose your information. 

This Privacy Policy discloses our privacy practices with respect to your access to and use of the morningconsult.com website, our email newsletters, social media pages, mobile and other applications owned and operated by us, and any other services associated therewith (“MC Media”). This Privacy Policy also discloses our privacy practices with respect to your access to and use of our products, such as the products available at the intel.morningconsult.com website, which includes our proprietary Morning Consult Intelligence software-as-a-service (“SaaS”) platform, and any and all underlying software, including for the avoidance of doubt the portion of our products that you may access when we provide professional services (“MC Products”). This Privacy Policy governs Morning Consult’s collection of information from you through your use of MC Media and MC Products (together, the “MC Assets”). It does not apply to any information you may provide to Morning Consult through other means, e.g., via mail or via telephone. Please read this Privacy Policy carefully so that you understand Morning Consult’s online privacy practices. By using MC Media, you acknowledge and agree to the collection, use, storage, processing, and disclosure of your Information (defined below) as set forth in this Privacy Policy, and that your visit to, download or use of MC Media, and any dispute over Morning Consult’s online privacy practices in connection therewith, is governed by this Privacy Policy and Morning Consult’s Terms and Conditions of Use. By using MC Products, you acknowledge and agree to the collection, use, storage, processing, and disclosure of your Information as set forth in this Privacy Policy, and that your use of MC Products, and any dispute over Morning Consult’s online privacy practices in connection therewith, is governed by this Privacy Policy and the Commercial Terms and Conditions. To the extent that the terms of this Privacy Policy or the Commercial Terms and Conditions conflict with the terms of any written agreement entered into between you (or your employer, or an affiliate of your employer, as the case may be) and Morning Consult governing the use of MC Products, the terms of such written agreement shall prevail to the extent such terms do not violate applicable law. 

This Privacy Policy also discloses our privacy practices with respect to our job applicants, potential candidates for employment, or prospective employees (MC Job Applicants”) and how we manage and protect the information of MC Job Applicants in connection with Morning Consult’s recruiting processes and programs. This Privacy Policy does not apply to our employees or contractors. Please read this Privacy Policy carefully so that you understand Morning Consult’s online privacy practices. By submitting your application for employment with us, you acknowledge and agree (a) to the collection, use, storage, processing, and disclosure of your Information (defined below) as set forth in this Privacy Policy, (b) that you are not required to provide any requested information to us, but failing to do so may result in not being able to continue your candidacy for the job for which you have applied, (c) that all of your representations are true and correct to the best of your knowledge and belief and you have not knowingly omitted any related information of an adverse nature (providing inaccurate information may make you ineligible for employment), (d) that this Privacy Policy does not form part of any contract of employment offered to candidates hired by Morning Consult, and (e) that your visit to and use of MC Media in connection with your application for employment, and any dispute over Morning Consult’s online privacy practices in connection therewith, is governed by this Privacy Policy and Morning Consult’s Terms and Conditions of Use. 

Questions regarding privacy issues should be directed to privacy@morningconsult.com or to Morning Consult, Attn.: Privacy Counsel, 1025 F Street NW, Suite 800, Washington, DC 20004.

 

INFORMATION WE COLLECT

MC Assets: Morning Consult collects and stores information, personal or otherwise, that you supply either voluntarily or while navigating or using MC Assets. That information includes personal information (e.g., information that identifies you as an individual or relates to an identifiable individual), technical information (e.g., device identifier, Internet protocol (“IP”) address, browser type, or operating system), and usage information (e.g., how you use, navigate, and respond to MC Assets and information about content or advertisements you have been shown or have clicked on while using MC Media). 

MC Job Applicants: In connection with your job application, Morning Consult collects and stores information, personal or otherwise, that you supply either voluntarily, while navigating or using our job applicant portal, or from other sources. That information includes personal information (e.g., information that identifies you as an individual or relates to an identifiable individual) and technical information (e.g., device identifier, IP address, browser type, or operating system).

We may combine these types of information together, and collectively refer to all of this information in this Privacy Policy as “Information.”

Information You Voluntarily Give Us –

MC Media: In connection with your use of MC Media, Morning Consult collects identity and contact Information you voluntarily supply when registering for optional subscriptions and setting/adjusting subscription preferences or otherwise interacting with MC Media. Examples of this type of Information include the personal information you provide when you subscribe for MC Media (e.g., your name, job title, organizational affiliation, and email address). Supplying such Information is entirely voluntary. However, if you choose NOT to supply the requested Information, Morning Consult may be unable to provide you with services made available to other users of MC Media. When you interact with MC Media you may share other Information about yourself by, for example, signing up for a webinar, downloading a report, requesting a demo, participating in surveys, or applying for jobs. This type of Information includes your name, email address, phone number, state, demographic information, and resume.

MC Products: In connection with your use of MC Products, Morning Consult collects identity and contact Information that is voluntarily supplied by you (or your employer, or an affiliate of your employer, as the case may be) as our customer (herein referred to as an “Authorized User”). Examples of this type of Information include the personal information you provide when your employer registers you as an Authorized User to access MC Products (e.g., your name, organizational affiliation, and email address), through a unique username and password, or such other login method we may designate from time to time. Supplying such Information is entirely voluntary. However, if you choose NOT to supply the requested Information, Morning Consult may be unable to provide you with access to our SaaS platform. 

MC Job Applicants: In connection with your application for employment, Morning Consult collects identity, contact, education, and employment Information that is voluntarily supplied by you. Examples of this type of Information include the personal information you provide to us in your resume, curriculum vitae (CV), or cover letter, such as your name, address, contact information, work and educational history, achievements, test results, and personal information you provide to us in the online application, such as your racial, ethnic, or origin identity, gender, whether you identify as part of the LGBTQ+ community, disability status, veterans status, or any other classifications under state or federal Equal Employment Opportunity laws. Additionally, our application process allows you to pull relevant information from social media websites (such as LinkedIn) into your application form. If you choose to feed any Information from such social media tools, it will be used in accordance with this Privacy Policy.

Information Collected Automatically –

We also collect certain usage and technical information regarding your navigation through, interaction with, and use of MC Assets, including when you navigate and use MC Media as an MC Job Applicant.

As is true of most websites, Morning Consult also collects and stores information that is generated automatically as you navigate through and use MC Assets, which may be stored in log files. This Information includes cookies, tracking pixels, web beacons, users’ IP addresses, browser type, device information (e.g., family, ID, type, and platform), operating system, session ID, general location data and other information about your use of MC Assets, including a history of the pages you view. See the “Cookies and Other Technologies” section below for more information on how we use these technologies to collect this Information. 

Information Collected from Other Sources –

MC Assets: We also collect Information about you from other sources, including through interactive applications (such as mobile devices, third-party services, and embedded audio and video players), and in the case of MC Media, from co-branded partners and from commercially available sources (such as data aggregators and public databases).

Morning Consult authorizes the collection of Information by third party advertisers through advertising technologies deployed in ads that may appear on MC Media without separate consent. The collection and use of Information by these third party advertisers is governed by the privacy policies of those third parties and is not covered by Morning Consult’s Privacy Policy. We are not responsible for the privacy practices of those parties. Morning Consult also collects your Information if you choose to provide it via forms in our advertisements that appear on third party websites (e.g., to subscribe to MC Media).

MC Job Applicants: We also collect Information about you from third parties, such as professional recruiting firms, your references, prior employers, Morning Consult employees with whom you have interviewed, and employment background check providers, to the extent this is permitted by applicable law. Additionally, we also collect Information about you from publicly accessible sources, such as online, to the extent that you have made this information publicly available. For example, we may find your profile on professional social media websites (such as LinkedIn) and contact you about suitable roles.

 

SENSITIVE PERSONAL INFORMATION

MC Assets: We ask that you not send us, and that you do not disclose to us, any sensitive personal information (e.g., social security numbers, information related to political opinions, racial or ethnic origin, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, sex life or sexual orientation) on or through MC Assets or otherwise. Any requested information that relates to sensitive personal information can be left unanswered by you.

MC Job Applicants: Morning Consult collects sensitive personal information that you voluntarily provide in your employment application (e.g., racial, ethnic, or origin identity, gender, whether you identify as part of the LGBTQ+ community, and disability status). If you receive an offer of employment with us, as part of our background check process, you will be asked to provide sensitive personal information, such as your social security number. 

 

HOW WE USE THE INFORMATION – MC Assetts

We use Information for the purposes described in this Privacy Policy, or disclosed at the time of collection, or with your consent, or as specified in the Terms and Conditions of Use or the Commercial Terms and Conditions, or the terms of any written agreement entered into between you (or your employer, or an affiliate of your employer, as the case may be) and Morning Consult governing the use of MC Products. 

To Personalize Your Experience –

Morning Consult uses the Information it collects from you in a variety of ways, such as customizing features on MC Assets and advertising that appears on MC Media. The Information you supply will help Morning Consult provide the services requested, offer you enhanced or more personalized features, and tailor MC Media and advertisements to your perceived interests. 

Please note that all of the Information we collect about you may be combined to help us tailor our communications to you and to develop rich online content and services. We rely upon your consent to process the Information you voluntarily supply. 

To Evaluate and Develop New Features, Technologies, and Improvements –

We use your IP address and the information obtained through cookies, web beacons, and similar technologies to deliver MC Assets’ content to you upon request and to measure traffic within MC Assets, as well as to track access and use of MC Assets across devices you use to access MC Assets. Processing this Information is necessary for our legitimate interests to further develop, study and analyze how MC Assets are used, to keep MC Assets updated and relevant by tracking user interests, engagement, trends, and patterns, and to grow our business and inform our marketing strategy.

For Marketing, Promotion, and Advertising Purposes –

Morning Consult uses the Information you provide to send you advertisements on behalf of third parties through MC Media. We also use third party advertising companies to target and serve some of the advertisements that appear on MC Media, and these companies likewise use their own cookies, web beacons, and similar technologies to collect Information from users of MC Assets. The Information collected by these companies includes the IP address of your computer. 

These companies use that Information, sometimes in conjunction with similar Information gathered from other websites, to deliver advertisements on MC Media, and possibly on other websites (e.g., if the third party advertising company operates an advertising network), that are tailored to match the perceived interests of consumers. 

We do not currently serve advertisements on MC Products.

To Communicate with You and Provide Updates –

MC Media: We use your Information (a) to contact you for customer service purposes, (b) to inform you of important changes and additions to MC Media or the services offered over MC Media, (c) to provide you with updates on new data, products, events, invitations to participate in surveys, or messages from partners, and (d) to provide or deliver any other communications that Morning Consult believes may be of interest to you. Our legal basis for processing this Information is based on your consent as well as for our legitimate interests to keep our records updated, to study how MC Media is used, to determine your eligibility to participate in surveys, and to understand your preferences and viewpoints for or on behalf of our partners. If you are eligible to participate in a survey, we use your Information to provide you with gift card offers/payments or charitable donation opportunities. 

MC Products: We use your Information to (a) manage and maintain our business relationship with you, as our customer, (b) contact you for customer service or user feedback purposes, (c) inform you of important changes and additions to MC Products or the services offered over MC Products, and (d) provide or deliver any other communications that Morning Consult believes may be of interest to you as it relates to your use of MC Products. Our legal basis for processing this Information is based on your consent, this Privacy Policy and the Commercial Terms and Conditions or the terms of any written agreement entered into between you (or your employer, or an affiliate of your employer, as the case may be) and Morning Consult governing the use of MC Products.

On occasion, at the request of our customers, Morning Consult may send Authorized Users of MC Products our content, such as newsletters or marketing emails. If, as an Authorized User, you wish to no longer receive these communications, please follow the instructions below on unsubscribing under the “YOUR CONTROLS AND CHOICES” section.

For Administrative, Compliance, and Legal Tasks –

We also use your identity and contact Information for (a) auditing purposes, to verify that our internal processes function as intended and comply with legal, regulatory and contractual requirements, (b) fraud and security monitoring purposes, including, for example, to detect and prevent cyberattacks, and (c) sending you administrative notices, offers, and requests for feedback. 

This Information is also used in order to comply with various legal processes and to protect and enforce the rights and interests of Morning Consult and others. Therefore, we access, preserve and disclose Information if we are required to do so by law or we have a good faith belief that such action is necessary to (a) comply with the law or with legal process, (b) protect and defend our rights, safety and property, including in connection with the Terms and Conditions of Use and Commercial Terms and Conditions, (c) protect against misuse or unauthorized use of MC Assets, (d) protect and defend the rights, safety and property of our users or the public (among other things, this means that if you provide false or misleading information or attempt to pose as someone else, Information about you may be disclosed as part of any investigation into your actions) and (e) cooperate with public and government authorities (which may be outside your country of residence). Processing this Information is necessary for running our business, e.g., complying with legal obligations, provision of administrative and IT services, network security, prevention of fraud, and in the unlikely context of a business reorganization or group restructuring.

 

HOW WE USE THE INFORMATION – MC JOB APPLICANTS

We use Information for the purposes described in this Privacy Policy, or disclosed at the time of collection, or with your consent. We collect and use your Information for:

  • Identifying and evaluating your skills, qualifications, and suitability for the role, as well as for future roles that may become available;
  • Recordkeeping in relation to recruiting and hiring;
  • Ensuring compliance with legal requirements, including diversity and inclusion requirements and practices;
  • Conducting criminal history checks, credit checks, and reference checks, as permitted by applicable law;
  • Protecting our legal rights to the extent authorized or permitted by law;
  • Emergency situations where the health or safety of one or more individuals may be endangered; or
  • Communicating with you about the recruitment process.

We also analyze your Information or aggregated/pseudonymized Information to improve our recruitment and hiring process and augment our ability to attract successful candidates.

Our processing of your Information for the purposes mentioned above is based:

      • In part, on our legitimate interest in evaluating your application to manage our relationship with you and to ensure that we recruit the appropriate employees, and to evaluate and maintain the efficacy of our recruiting process more generally;
      • In part, on our need to perform contractual and precontractual measures in respect to our relationship with you, should you be offered employment with us; and
      • In part, to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations.

     

 

SHARING YOUR INFORMATION

MC Assets: Morning Consult shares your Information with third parties, such as service providers, contractors, advertisers, and analytics partners. For example, we provide our advertisers with Information about you and other visitors collected from MC Media that will enable our advertisers to better target advertisements that are more relevant to you.

MC Job Applicants: Your Information will be accessed by recruiters and interviewers. Individuals performing administrative functions and IT personnel within Morning Consult may also have limited access to your Information to perform their jobs. We use software applications provided by third party service providers to support our recruiting management activities. We also share your Information with other third party service providers that assist us in recruiting talent, administering and evaluating pre-employment screening and testing, and improving our recruiting practices. We maintain processes designed to ensure that any processing of Information by third party service providers is consistent with this Privacy Policy and protects the confidentiality, availability, and integrity of your Information. We do not allow our third party service providers to use your Information for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Please also note that as Morning Consult’s business grows, Morning Consult may buy or sell various assets. We have a legitimate interest in disclosing or transferring your Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business (including in connection with any bankruptcy or similar proceedings). In the event that Morning Consult is involved in any of the foregoing transactions, including the transfer of MC Assets and Information pertaining to MC Job Applicants to another company, your Information may be among the transferred assets.



YOUR CONTROLS AND CHOICES

We provide you with the ability to exercise certain controls and choices in relation to our collection, use, and sharing of your personal information. In accordance with applicable law, you may have the following rights:

  • Right of access – the right to be informed of, and request access to, the personal information we process about you;
  • Right to rectification – the right to request that we amend or update your personal information where it is inaccurate or incomplete;
  • Right to erasure – the right to request that we delete your personal information;
  • Right to restrict – the right to request that we temporarily or permanently stop processing all or some of your personal information;
  • Right to object – the right to object to us processing your personal information;
  • Right to data portability – the right to request a copy of your personal information in electronic format and the right to transmit that personal information for use in another party’s service; and 
  • Right not to be subject to automated decision-making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect. 

You can exercise these controls and choices in various ways, such as by submitting a Morning Consult Data Request or by contacting us at privacy@morningconsult.com. 

If you reside in the State of California in the United States, you have certain rights under the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020. For more information, please review our California Privacy Notice below. 

Unsubscribing. You may also manage and modify your subscriptions, and otherwise limit our communications with you, by visiting our Email Preference Center, or by using one or more subscription management links at the bottom of each newsletter/marketing email sent by Morning Consult, at any time. If you have been invited to participate in a survey and do not wish to receive such communications from Morning Consult in the future, you may unsubscribe by following the instructions in the email on how to do so. 

Ad Choices. For more information about interest-based advertising on your desktop or mobile browser, and to opt out of this type of advertising by third parties that participate in self-regulatory programs, please visit the Network Advertising Initiative website and/or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising Website.

If you experience any issues with unsubscribing or managing and/or modifying your preferences as described above, please contact us at privacy@morningconsult.com. Be sure to (a) provide your email address along with the name of the newsletter or subscription from which you would like to unsubscribe and (b) include “Opt Out” or “Change Preferences” in the subject line. By contacting us, you grant Morning Consult permission to use your email address for purposes of responding to your request. Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting the change or deletion. 

You may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. We would, however, appreciate the chance to address your concerns before you lodge a formal complaint so please contact us at privacy@morningconsult.com in the first instance.

 

STORAGE AND RETENTION OF YOUR INFORMATION

MC Assets: We retain Information for as long as needed or permitted in light of the purpose(s) for which it was obtained, consistent with applicable law. The criteria used to determine our retention periods include (a) the length of time we have an ongoing relationship with you and provide you with access to MC Media (e.g., for as long as you continue to use MC Media), (b) the length of time specified in the terms of any written agreement entered into between you as an Authorized User (or your employer, or an affiliate of your employer, as the case may be) and Morning Consult regarding MC Products, (c) whether there is a legal obligation to which we are subject (e.g., certain laws require us to keep records of your transactions for a certain period of time before we can delete them), or (d) whether retention is advisable in light of our legal position (e.g., applicable statutes of limitations, litigation or regulatory investigations). 

MC Job Applicants: If you accept an offer of employment from us, any relevant Information collected during your pre-employment period may become part of your employee personnel records and will be retained in accordance with applicable legal requirements. If we do not employ you, we may nevertheless continue to retain and use your Information for a period of time so that we can understand whether you have previously applied for a role(s) at Morning Consult. The criteria used to determine our retention periods include (a) compliance with applicable laws and regulations, (b) system administration purposes, (c) consideration of you for potential future roles, (d) performance of research, and (e) whether retention is advisable in light of our legal position (e.g., applicable statutes of limitations, litigation or regulatory investigations). 

 

Information Security –

We have put in place reasonable controls designed to help safeguard the Information we collect via MC Assets and MC Job Applicants. However, no security measures are perfect, and we cannot assure you that Information that we collect will never be accessed or used in an unauthorized way. 

To further protect your data, we recommend that you use complex passwords for any accounts you have with us where password protection is offered as an option. Please do not use the passwords you use for MC Assets for other services or share passwords with unauthorized persons. If you have reason to believe that your interaction with us is no longer secure, please immediately contact us at privacy@morningconsult.com.


THIRD PARTY SITES

MC Assets include links to third party websites whose privacy policies Morning Consult does not control. Once you leave MC Assets, any Information you provide at another site will be governed by the privacy policy of the operator of the site you are visiting. The privacy policies of third party websites will differ from ours. 

Please note that if you make a purchase through a third party site, the privacy policy of the third party site will govern the use and distribution of your credit card number or other financial information.


COOKIES AND OTHER TECHNOLOGIES

To help make MC Assets more responsive to the needs of users, including when you navigate and use MC Media as an MC Job Applicant, Morning Consult employs a standard feature of browser software, called a “cookie,” to assign each user a unique, random number that resides on a user’s computer. The cookie does not personally identify the user; it merely identifies the computer with which the user accesses MC Assets. Unless a user voluntarily identifies himself or herself (through subscription or as an Authorized User, for example), neither MC Media nor MC Products will be able to identify the identity of the user, even if a cookie is assigned to a user’s computer. 

The personal information a cookie can contain is information supplied by a user. Cookies prevent you from having to re-enter your preferences on certain areas of MC Assets where you have previously entered preference information. Most web browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Consult the “Help” section of your browser for more information. Please note that by blocking any or all cookies, you may render your computer unable to take advantage of the personalized features enjoyed by other users of MC Assets.

MC Assets’ servers automatically collect limited information about your computer’s connection to the Internet, including your IP address. The IP address is a number that lets computers attached to the Internet know where to send data – such as the web pages users view.

Morning Consult also uses web beacons (also known as “single-pixel GIFs”) to access cookies and to count users who visit MC Assets or open Morning Consult’s HTML-formatted email messages, as well as to track device identification statistics and other non-identifying information for the purpose of analytics, push notifications, and error reporting. These analytics are provided to third party vendors. 

With respect to your application for employment with us, some of our online recruiting activities are hosted by third parties. When you access sites operated by these third parties, they may place cookies and other tracking technologies on your device.

Do Not Track Notice –

Morning Consult takes privacy and security very seriously, and strives to put our users first in all aspects of our business. With regard to Do Not Track (“DNT”) signals, Morning Consult currently does not respond to DNT signals in browsers because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

 

CHILDREN’S PRIVACY

This children’s privacy statement explains Morning Consult’s practices with respect to the online collection and use of personal information from children under the age of thirteen and provides important information on children’s and parental rights under federal law with respect to such information.

MC Assets: MC Assets are not directed to children under the age of thirteen and Morning Consult does NOT knowingly collect personal information from children under the age of thirteen. In fact, Morning Consult requires subscribers’ occupational information in part to dissuade users under the age of thirteen from subscribing. By subscribing to MC Media and/or registering for MC Products, you represent and warrant that you are thirteen years of age or older. Subscription or registration under false or fraudulent pretenses constitutes unauthorized use and will be terminated. 

MC Job Applicants: Applications for employment with Morning Consult are not open to children. We do not knowingly collect or solicit Information from anyone under the age of thirteen. If you are under thirteen, please do not attempt to fill out our forms or send any Information about yourself to us.

If Morning Consult becomes aware that it has inadvertently received personal information from a user under the age of thirteen, Morning Consult will delete such information from Morning Consult’s records. Because Morning Consult does not knowingly collect any personal information from children under the age of thirteen, Morning Consult also does NOT knowingly distribute any such information to third parties. Morning Consult does NOT knowingly allow children under the age of thirteen to distribute personal contact information. If you learn that your child has provided us with personal information without your consent, you may alert us at privacy@morningconsult.com.  

 

INTERNATIONAL TRANSFER

Our computer systems are currently based in the United States. This means Information we collect will be processed by us in the United States where data protection and privacy regulations may be subject to different requirements. If you use or visit our websites from outside the United States, or you apply for a position with Morning Consult from outside the United States, you consent to the collection and/or processing of the Information we collect from you in the United States.

 

CALIFORNIA PRIVACY NOTICE

This section (herein referred to as the “California Privacy Notice”) supplements our Privacy Policy and explains additional information and rights available to California consumers as set forth in the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”) (collectively, “CCPA/CPRA”). These rights apply solely to users that are California consumers and their personal information, which means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households (“California Information”). We have adopted this California Privacy Notice to comply with the CCPA/CPRA, and any terms not defined herein shall have the meaning set forth in the CCPA/CPRA.

Categories of California Information Collected – 

In the preceding twelve (12) months, we have collected the following categories of California Information, as described in the CCPA/CPRA, from consumers:

MC Media:

  • Identifiers – such as name, job title, organizational affiliation, email address, phone number, IP Address, and unique and online identifiers (e.g., browsing type, operating system, and other related information); 
  • Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e)) (“California Consumer Records Categories”) – such as name or telephone number;
  • Internet or other similar network activity – such as browsing history, search history, and information regarding your interactions with MC Media and content such as advertisements; and
  • Geolocation data – such as city and/or state of residence (we do not collect precise geolocation information).

MC Products:

  • Identifiers – such as name, job title, organizational affiliation, email address, phone number, account name, IP Address, and unique and online identifiers (e.g., browsing type, operating system, and other related information); 
  • California Consumer Records Categories – such as name or telephone number;
  • Internet or other similar network activity – such as browsing history, search history, and information regarding your interactions with and use of MC Products; 
  • Sensory data – such as video recordings (only in the event you are a customer or potential customer business contact of ours and consent to your call with us being recorded for our internal training purposes); and
  • Geolocation data – such as city and/or state of residence (we do not collect precise geolocation information).

MC Job Applicants:

  • Identifiers – such as name, job title, organizational affiliation, email address, phone number, IP Address, and unique and online identifiers (e.g., browsing type, operating system, and other related information), and social security number (for background check purposes);
  • California Consumer Records Categories – such as name, signature, social security number (for background check purposes), telephone number, education, employment, and employment history;
  • Protected classification characteristics under California or federal law – such as race, ancestry, national origin, citizenship, physical or mental disability (disability status), sex (including gender, gender identity, and gender expression), sexual orientation, and veteran or military status;
  • Internet or other similar network activity – such as browsing history, search history, and information regarding your interactions with MC Media;
  • Geolocation data – such as city and/or state of residence (we do not collect precise geolocation information); and
  • Professional or employment-related information – such as current or past job history or performance evaluations.

Categories of Sensitive California Information Collected – 

In the preceding twelve (12) months, we have collected the following sensitive California Information, as described in the CPRA, from consumers:

MC Media:

We do not collect any sensitive California Information.

MC Products:

With respect to your registration as an Authorized User to access MC Products, we may collect your unique username and password. This may be considered account log-in information, which is sensitive California Information. As described above, supplying such information is entirely voluntary. However, if you choose NOT to supply the requested information, Morning Consult may be unable to provide you with access to our SaaS platform.

MC Job Applicants:

We collect your social security number for background check purposes. We also collect racial and ethnic origin, health information (disability status), and sexual orientation information if you voluntarily provide such information in your employment application.

With respect to MC Assets and MC Job Applicants, we only collect or process sensitive California Information without the purpose of inferring characteristics about you.

Categories of Sources from Which California Information is Collected – 

We collect your California Information, including sensitive California Information as applicable, from the sources described in the “INFORMATION WE COLLECT” section above in our Privacy Policy.

Use of California Information – 

We use the California Information collected from you, including sensitive California Information as applicable, for the commercial and business purposes described in the “HOW WE USE THE INFORMATION – MC ASSETS” and “HOW WE USE THE INFORMATION – MC JOB APPLICANTS” sections above in our Privacy Policy. 

Categories of California Information Disclosed for a Business Purpose to Third Parties

In the preceding twelve (12) months, we have disclosed the following categories of California Information for a business purpose:

MC Media:

  • Identifiers
  • California Consumer Record Categories
  • Internet or other similar network activity
  • Geolocation data

MC Products:

  • Identifiers
  • California Consumer Record Categories
  • Internet or other similar network activity
  • Sensory data
  • Geolocation data

MC Job Applicants:

  • Identifiers
  • California Consumer Record Categories
  • Protected classification characteristics under California or federal law
  • Internet or other similar network activity
  • Geolocation data
  • Professional or employment-related information

Categories of Third Parties to Whom California Information was Disclosed for a Business Purpose – 

In the preceding twelve (12) months, we have disclosed your California Information, for a business purpose, to the following categories of third parties:

MC Media:

  • Outside organizations in connection with providing products and services, completing transactions, supporting our daily operations, or business management and development
    • Identifiers
    • California Consumer Record Categories
    • Internet or other similar network activity
    • Geolocation data
  • Software applications, websites, and third-party integrations on or using MC Media
    • Identifiers
    • California Consumer Record Categories
    • Internet or other similar network activity
    • Geolocation data
  • Analytics partners that help us collect data on how MC Media is used, so that we can improve and better understand our consumers
    • Identifiers
    • California Consumer Record Categories
    • Internet or other similar network activity
    • Geolocation data

MC Products:

  • Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, or business management and development
    • Identifiers
    • California Consumer Record Categories
    • Internet or other similar network activity
    • Sensory data
    • Geolocation data
  • Analytics partners that help us collect data on how MC Products are used, so that we can improve and better understand our consumers
    • Identifiers
    • California Consumer Record Categories
    • Internet or other similar network activity
    • Geolocation data

MC Job Applicants:

Outside organizations in connection with facilitating your application for employment, supporting our recruitment management activities, assisting us in recruiting talent, administering and evaluating pre-employment screening and testing, and improving our recruiting practices

  • Identifiers
  • California Consumer Record Categories
  • Protected classification characteristics under California or federal law
  • Internet or other similar network activity
  • Geolocation data
  • Professional or employment-related information

Business or Commercial Purposes for Disclosing California Information to Third Parties – 

In the preceding twelve (12) months, we have disclosed your California Information to the third parties identified above for the following business or commercial purposes:

MC Assets:

  • Helping to ensure the security and integrity of our assets; 
  • Debugging to identify and repair errors that impair existing intended functionality; 
  • Performing services on behalf of us, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying customer information, processing for purposes of providing gift card offers/payments or charitable donation opportunities in the event you participate in a survey, providing analytics services, providing data storage, or providing similar services on behalf of us; 
  • Providing advertising and marketing services;
  • Undertaking internal research for technological development and demonstration; and
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

MC Job Applicants:

  • Helping to ensure the security and integrity of our assets; 
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Performing services on behalf of us, including facilitating your application for employment, supporting our recruitment management activities, assisting us in recruiting talent, administering and evaluating pre-employment screening and testing, improving our recruiting practices, providing analytics services, providing data storage, or providing similar services on behalf of us;
  • Undertaking internal research for technological development and demonstration; and
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Categories of California Information Sold or Shared – 

MC Assets:

While Morning Consult does not sell or share your California Information in exchange for monetary consideration, we do share your California Information for other purposes that could be deemed a “sale” or a “share” under the CCPA/CPRA. 

In the preceding twelve (12) months, we have sold or shared the following categories of California Information, as described in the CCPA/CPRA, from consumers:

  • Identifiers 
  • Internet or other similar network activity 
  • Geolocation data

MC Job Applicants:

With respect to MC Job Applicants, we have not sold or shared your California Information in the preceding twelve (12) months. 

Categories of Third Parties to Whom California Information Was Sold or Shared – 

MC Assets: 

In the preceding twelve (12) months, we have sold or shared your California Information to the following categories of third parties:

  • Advertising partners and networks that help us collect data on how MC Media is used, including for cross-context behavioral advertising, so that we can improve and better understand our consumers
    • Identifiers 
    • Internet or other similar network activity 
    • Geolocation data
  • Analytics partners that help us collect data on how MC Media and MC Products are used, so that we can improve and better understand our consumers
    • Identifiers 
    • Internet or other similar network activity 
    • Geolocation data

Business or Commercial Purposes for Selling or Sharing California Information – 

MC Assets: 

In the preceding twelve (12) months, we have sold or shared your California Information to the third parties identified above for the following business or commercial purposes:

  • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
  • Performing analytics services on behalf of us; and
  • Providing advertising services on behalf of us, including cross-contextual behavioral advertising.

Retention of California Information – 

The criteria used to determine the period of time that we retain each category of California Information collected from you, including sensitive California Information as applicable, is described in the “STORAGE AND RETENTION OF YOUR INFORMATION” section above in our Privacy Policy. 

Your Rights – 

The CCPA/CPRA provides California consumers with specific rights regarding their California Information. 

Right to Know

You have the right to know what California Information we have collected about you, including the categories of California Information, the categories of sources from which the California Information is collected, the business or commercial purpose for collecting, selling, or sharing California Information, the categories of third parties to whom we disclose California Information, and the specific pieces of California Information the business has collected about you.

Right to Delete

You have the right to delete California Information that we have collected from you. We may deny your deletion request if retaining the California Information is necessary for us or our service provider(s) or contractor(s) to: 

  • Complete the transaction for which we collected the California Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products or identify and repair errors that impair extended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by the law;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • Comply with a legal obligation; and
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Correct

You have the right to correct inaccurate California Information that we maintain about you.

We may deny your request to correct if we determine that the contested California Information is more likely than not accurate based on the totality of circumstances, which includes, but is not limited to:

  • The nature of the contested information (e.g., whether it is objective, subjective, unstructured, sensitive, etc.); 
  • How we obtained the contested information; and
  • Documentation relating to the accuracy of the contested information whether provided by you, us, or another source.

Right to Opt-Out of the Sale or Sharing 

You have the right to opt-out of the sale or sharing of your California Information. We do not sell or share the California Information of consumers we actually know are less than 16 years old.

To exercise the right to opt-out, you may visit the following link:  Do Not Sell or Share My Personal Information 

Right of Non-Discrimination 

We will not discriminate against you for exercising any of your CCPA/CPRA rights. Unless permitted by the CCPA/CPRA, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services;
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services; and
  • Retaliate against you if you are exercising your CCPA/CPRA rights as an MC Job Applicant or independent contractor.

Our denial of your request to know, request to delete, request to correct, or request to opt-out of sale/sharing for reasons permitted by the CCPA/CPRA shall not be considered discriminatory.

How to Exercise Your Rights – 

You can exercise your rights either by submitting a Morning Consult Data Request, or by contacting us at privacy@morningconsult.com.

Please note that to protect your information we may need to verify your identity before processing your request. In some cases, we may need to collect additional information to verify your identity. When submitting a request, please be sure to indicate the right being exercised, and include your first and last name as well as the email address used when interacting with us. A member of our team will review your request.

Under the CCPA/CPRA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity. 

Response Timing and Format – 

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10 business day timeframe, please contact privacy@morningconsult.com.

We endeavor to substantively respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. 

We will deliver our written response electronically. 

Any disclosures we provide will only cover the twelve (12) month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select an electronic format to provide your California Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

 

CHANGES TO THIS POLICY

We evaluate this Privacy Policy periodically in light of changing business practices, technology and legal requirements. As a result, we may update this Privacy Policy from time to time. In the event that Morning Consult does update this Privacy Policy, the modified Privacy Policy will be accessible on MC Assets and will be effective as of the date set forth below. We will notify you about material changes to this Privacy Policy by placing a notice on our website. Your continued use of MC Media, including when you use MC Media as an MC Job Applicant, and/or MC Products after Morning Consult modifies this Privacy Policy shall constitute your agreement to be bound by the terms hereof as modified. For the avoidance of doubt, nothing contained in this Privacy Policy establishes any license or any other right to use or access MC Products, and any such license or right shall be exclusively established by, and governed under the terms of, a separate written agreement between you (or your employer, or an affiliate of your employer, as the case may be) and Morning Consult.

 

Contact Information 

If you have any questions or concerns about this Privacy Policy, the ways in which we collect and use your personal information, your rights regarding such use, or wish to exercise any privacy rights available to you under applicable law, please contact us at:

Email: privacy@morningconsult.com
 

Address: 

Morning Consult
Attn: Privacy Counsel
1025 F Street NW, Suite 800

Washington, DC 20004

Phone: 202.506.1957

Last Updated: December 22, 2022 

 

Morning Consult