Identity & Data Resolution Notice

Identity & Data Resolution Notice

Click Makers, LLC D.B.A. Growth Ring Media

Purpose

How we connect records about the same person or business across systems, what data we use, how long we keep it, and your choices.

Identity Data

• Contact: name, email, phone, company, role, address
• Identifiers: cookies, IP address, mobile ad IDs
• Internal IDs: form, call tracking, chat, scheduling, CRM, billing
• Campaign context: pages viewed, ads clicked, UTM, creative IDs, call metadata

We do not knowingly collect data from children under 16.

Sources

• You and your systems
• Our sites and tooling (consent banner, pixels, call tracking, analytics)
• Approved service providers and partners named in your SOW

How Matching Works

• Deterministic: exact keys like email, phone, CRM ID, or hashed versions
• Probabilistic: signals such as IP, device traits, referrer, time window, geography
• Location joins: address may link records to the same premises

We prefer deterministic matches. Each match has a confidence score. We do not merge below threshold.

How We Use It

• Deduplicate leads and prevent double counting
• Measure performance and revenue lift
• Personalize sequences you approve
• Suppress targeting after conversion
• Improve data quality and detect fraud

What We Do Not Do

• No selling of personal information as defined by CPRA
• No combining client data across clients except in de-identified or aggregated form
• No use of sensitive personal data for ad targeting

Roles

• Most client work: we act as Service Provider or Processor under your instructions
• Our own sites: we act as Business or Controller for limited first-party data

Consent and Choices

We honor your consent banner choices and Global Privacy Control. To access, correct, delete, or opt out of targeted ads or profiling, email branchout@growthringmedia.com .

Regional

California (CPRA)

• We act as Service Provider or Contractor
• If a use could be "sharing" for cross-context behavioral advertising, we honor opt-out choices and GPC
• We do not sell personal information

Colorado (CPA)

• We honor universal opt-out mechanisms
• We provide a way to opt out of targeted advertising and profiling in furtherance of decisions with legal or similar significant effects
• To appeal a data rights decision, email branchout@growthringmedia.com with "Appeal" in the subject line

Retention

• Identity-resolution tables: typically 24 months from last activity
• Conversion and attribution logs: typically 24 to 36 months

Security

Encryption in transit and at rest where supported, role-based access with MFA, least privilege, vendor contracts, confidence scoring with periodic review.