Privacy Policy Data Services and Website Privacy Policy

SDS Holdings, LLC Series B dba The Followup Agency (“We,” “Our,” “”) provides data marketing services (the “Services”) designed to help for-profit and not-profit organizations, and companies that work with them, to market their goods and services in a relevant and efficient way. Our solutions, many of which are described on this website, are used principally to support email marketing.

We take very seriously the privacy interests of the individuals whose information we handle and maintain in our database. We provide this Privacy Policy (“Privacy Policy”) to explain how we use and manage information, and what rights consumers have to control how their information is used in marketing.  

To review the “Addendum” we have created specifically to address disclosures required under the California Consumer Privacy Act, please see our “ADDENDUM FOR CALIFORNIA RESIDENTS” below.

We also operate corporate websites, designed for our own customers and prospective customers, and others who want to learn about our services. We address the information we collect and use for those business purposes (such as information we use to communicate with our corporate customers, and potential customers) in Section 6 of this Privacy Policy.

  1. Information That We Collect and Use in Our Services

In order to provide our Services, we receive data, including personal information, from a variety of sources, including from websites and apps that collect the information, public sources, and other data compilers. We refer to the information that we collect and process throughout this Privacy Policy as “Information” or “the Information.”

The Information in our database includes various identifying information, such as:

– Personal email

– Professional email

– Information and actions associated with an email, such as whether an email has recently been in use, and amount and type of marketing or “email open” activity associated with an email

– IP address

– A cookie or device identifier, which uniquely identifies your browser or device

– Usage data related to your email interactions, such as whether you receive, open or respond to an email, and related information

– Usage data related to your website interactions, such as whether you visit or log in to a website, page visits and related information

– Demographic information, such as inferenced income or age range, household size, or home ownership

– Information regarding consumer interests, such as what type of products you may be interested in, or what types of hobbies you might have, such as whether you are a likely pet owner or a sports or art enthusiast

 Some of the above information may be inferred – for instance, if a household is in a particularly wealthy area, we might infer a particular income range.

We may combine any of the points of Information we collect or receive with other Information. also receives information through this website (and any other website we operate), and our business operations. We describe this information in Section 6.

  1. How We Use the Information uses the Information for various purposes, including the following.

As Part of Our Services:

Data Marketing Services. Our Services include providing marketing information to our customers, generally regarding which customers or prospective customers are most likely to be interested (or disinterested) in certain offers. We also help our customers identify and understand their customers better, by providing insights about them. Our customers include (but are not limited to) small and medium-sized businesses, ad and media agencies, brands and marketing data platforms that help their customers to market and advertise to their own customers (and prospective customers). Our customers also may include other data compilers, who work with their own customers.

Retargeting Services. We sometimes help our customers to “retarget” marketing content to website visitors. In particular, our Services help customers send emails to people who visited or logged in to their websites by cross-referencing information such as cookie identifiers and emails for those purposes.

Additional Marketing Services. Other Services we may provide to our customers (or help them to provide to their own customers), which may supplement the above Services, may involve (a) assisting customers to target and optimize email campaigns, display, or other marketing; (b) measuring how effective marketing campaigns have been, by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases; (c) analyzing and optimizing our customers’ (or their service providers’) proprietary databases; (d) helping customers to detect and prevent fraud and provide “validation” or data hygiene services, e.g., by verifying or removing or correcting old, incorrect or outdated information or evaluating whether an email address recently has been active.

To Operate Our Services

We also use the Information described above for our own internal purposes – such as to improve, test, update, and verify our own database; develop new products; operate, analyze, improve and secure our Services and our databases and servers.

  1. How We Share Information with Third Parties, including Service Providers may share the Information with customers, marketing services and platforms, as well as service providers that help us to provide the Services we’ve described above (or other services we may add in the future). This includes sharing in the following ways:

With Our Customers: As described above, we license the Information in various ways to our customers (and something to partners and resellers, who license the Information to their customer), when we provide our Services. We may sometimes share the Information with those Customers’ service providers (for instance, a provider that prints or sends mailings for a Customer).

With Our Partners: We also may share the Information, including personally identifiable information and Audience Segments, with business and data partners to help provide more tailored targeted marketing, advertising and communications. Likewise, we may do so for analytical purposes, including to help these other parties measure campaign performance, inform future campaigns, or to handle, analyze, or segregate this Information on our or our customers’ behalf.

With Our Service Providers: We share the Information with a variety of service providers in order to operate, protect and advertise our Services and maintain our website(s). For instance, we may share the Information with our tech, hosting and customer support providers, marketing and advertising providers, other data providers (such as to enhance or verify our Information), security vendors, payment vendors (as to our business to business information), and other companies help us deliver, secure or develop our Services.

Corporate transfers: If, its stock or its significant assets are acquired by or merged into another entity, our information will be transferred to that entity, and may be shared during due diligence in anticipation of any such transaction.

Affiliates, parent companies and subsidiaries: may share some or all of the Information in our possession with any affiliated or subsidiary companies (if we ever have any).

As required by law or to protect any person or entity: may disclose Information if we believe that such disclosure is necessary to (a) comply in good faith with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or safety of, our customers, or any other person or entity.

  1. Your Marketing and Opt-Out Choices

If you would like to opt-out of email marketing from a particular brand (such as a customer of ours), click on the “opt out” or “unsubscribe” link in the footer (at the bottom) of the marketing email you have received.

While we generally do not engage in “direct mail” marketing, some of our customers and partners may. If you are interested in opting our of this type of marketing — i.e., materials received in your physical mailbox — we recommend that you visit the DMA Choice website, at The DMA Choice service is run by the Direct Marketing Association and allows you to follow few easy steps to ensure that your marketing preferences are honored.

To opt out of our Retargeting Services described in section 2 and email campaigns, you may send us an email at

If we market to you by email in our corporate capacity — such as if you are a customer or prospective customer of ours and we send information about our Services — you may “unsubscribe” from our marketing emails through a link placed in your emails.

  1. Cookies and Similar Technologies

Cookies and How We Use Them and its business partners use certain industry-standard technologies, including cookies and similarly functioning technologies, which we describe below. We and/or our service providers use these technologies on our website, for instance, and our partners may use these technologies in their own marketing services.

We may work with third parties or service providers to provide or enhance our services (e.g. for purposes of tailoring ads, or placing browser cookies), or to offer marketers ways to access or use our Information, often in de-identified form. These partners may set and access their own cookies, pixel tags, and similar technologies on your browser, which may have cookies with varying expiration periods. Those partners may likewise collect various types of information about your browser, device, or browsing activities through use of these cookies.

Cookies, in turn, are small data files that contain a string of characters, such as a unique browser identifier. Cookies are stored on your computer or other device and act as tags that identify your device. Our (or other companies’) servers send your device a cookie when you visit a website. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access web pages (such as the website of a marketer), pixel tags may generate a generic notice of the visit and permit our partners (or sometimes, us) to read the cookies that a respective company or server has deployed. Pixel tags are used in combination with cookies to track the activity on a site by a particular device. When you turn off cookies, pixel tags simply detect a given website visit.

We, or our service providers, and other online marketing platforms that we or they work with, may use cookies to, among other things, “remember” you, determine visitor patterns and trends, collect information about your activities on our clients’ sites, or interact with the advertising you see. Cookies are used in this way to provide relevant content to you and replace non-relevant communications with ads that better match your interests.

Disabling Cookies

Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of our website and other services may be difficult to use or become inoperable.

  1. Data Collected Through Our Corporate Website

Information Collected collects information from users of our website(s) (including any page on which this Privacy Policy is posted), including:

The domain name and IP address of a user’s web browser, as well as a user agent, time stamp and other information about a user’s browser or device.

Information about what content and pages users access, utilize or visit on our website, or how they interact with our content — for instance, if they spent a certain amount of time reviewing a particular blog post or description of particular services.

Information, including personally identifiable and contact information that you provide, which could include (for instance) survey information, sign-up information (e.g., if you sign up for our webinars, events or newsletters), requests for information, mailing addresses, and email addresses.

How Uses the Information We Collect Through Our Website

We use the Information we collect through our website(s) to do the following:

– Create and manage your user account.

– Provide Services you have requested.

– Respond to and communicate with you (including regarding news and updates about our services).

– Send you offers and ads for our products and services, when you browse the website(s) or other companies’ websites on the Internet (such as to “retarget” you with information about our Services).

– Send you offers and ads for products and services of partner brands, or other offers we believe may be of interest to you, such as invitations to events and webinars.

– Perform data analysis (including market research).

– We may combine the Information with other information we obtain from third parties, publicly available sources, and any other product or service we provide to further improve the relevance and effectiveness of products, and advertisements offered, including (but not limited to), those provided on or through our services.

We may use IP addresses to help diagnose problems with our servers and to administer our website(s). We may also use IP addresses to help identify visitors to our website(s) for the duration of a session and to gather demographic information about our visitors.

– We may use clickstream data to determine how much time visitors spend on each web page of our website(s), how visitors navigate through the website(s), and how we may tailor our website(s) to better meet the needs of our visitors. We also use this Information for compliance with our legal obligations, policies and procedures, including the enforcement of our Terms and Conditions.

If we collect Information from “offline” sources — such as if you provide us your business card at a trade show — we will maintain that information and use it for marketing and business purposes as well.

How Shares the Information We Collect Through Our Websites

We may sometimes share or otherwise disclose the Information we collect about you, as described in this Privacy Policy or otherwise disclosed to you when you provide us with the information, including as follows:

We may share the Information with service providers who help us deliver the services you request or we provide. For instance, we share the Information with tech and customer support providers, marketing and advertising providers, other data providers (such as to enhance or verify our Information), security and data hygiene vendors, payment vendors (as to our business to business information), and other companies that may help us deliver or develop Services.

We may share the Information to communicate with you and market to you, including through email, direct mail or display media.

We will disclose your PII (or other Information) if we believe in good faith that we are required to do so by law, regulation or other government authority or to protect the rights, safety or property of ourselves or any person or entity. We may also cooperate with law enforcement agencies in any official investigation and we may disclose any Information to the requesting agency in doing so.

If we or all or substantially all of our assets, are purchased by another company (such as in a merger, consolidation, restructuring, the sale of stock and/or assets, or other corporate change or financing transaction), the Information in our possession will likely be transferred to the successor entity. We also may share the Information during the course of any due diligence process leading up to any such transaction.

Our website(s) use cookies and similar technologies, both for its internal and operational purposes and to market to you (such as to retarget ads to you when you visit other sites across the Internet).

  1. Links

This website may provide links to other websites that thinks users may be interested in. is not responsible for the privacy practices of these other sites or companies.

  1. Security and Data Integrity takes steps to help ensure that the data we possess is housed and transmitted securely. This may include various types of physical and electronic security, including firewall protections, encryption, hashing or truncation of data, and access controls to personal information. However, you should be aware that neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion.

  1. Changes to this Privacy Policy

From time to time, we may update this Privacy Policy. Any changes to it will become effective when it is posted to our website. Please check back to learn of any changes to this Privacy Policy.

  1. Storage of Information in the United States

If you are accessing our website from outside of the United States, your connection likely will be through and to servers located in the United States and all Information you provide will likely be processed and securely maintained in our web servers and internal systems located within the United States (we generally store the Information used in our Services in the United States). Thus, you should be aware that in accessing this website or otherwise communicating with us, the information we collect or receive from you may be subject to laws with lesser or different privacy standards than those in your own country (such as if you are in a country located in the European Union).

  1. Your California Privacy Rights

If you are a resident of California, the California Consumer Protection Act (CCPA) provides certain rights of disclosure, access and deletion of your Information as described below in the “Addendum for California Residents” at the end of this Privacy Policy.

  1. Contact Us has a designated privacy contact. If you have questions related to this Privacy Policy, or regarding our products or services, please contact us:


We appreciate your comments and questions regarding’s privacy practices.

Last updated: Nov 30, 2023


Last Modified: Nov 29, 2023


The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Policy applies if you are a natural person who is a resident of California (“California Consumer”) and uses our Services.

This Addendum supplements the information in the Privacy Policy. However, this Addendum is intended solely for, and is applicable only as to, California Consumers: if you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it.

In the below tables and sections, we describe (as required by the CCPA):

  1. Our Collection of Personal Information— the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from,
  2. Our Disclosure and Sale of Personal Information— the types of recipients to whom we disclose or sell Personal Information.
  3. Our Business Purposes — our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.
  4. Your California Privacy Rights and Choices— what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.

The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information:


Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.