Privacy Policy

1. Scope of this policy

This Privacy Policy explains how Azul Performance, LLC (“Azul Performance”, “we”, “us” or “our”) collects, uses, discloses and protects personal information in connection with this website and the marketing services we provide to businesses (together, the “Services”).

Azul Performance is a performance marketing company. We operate a network that connects consumer-facing publishers with advertisers who wish to receive consumer inquiries. We are not a lender, bank, insurance carrier, law firm or licensed broker, and we do not make decisions about any product a consumer may later apply for.

This policy applies to information we handle as a business in our own right. Where we process information on behalf of an advertiser or publisher under a written agreement, that party's own privacy notice governs their use of the information after it reaches them.

By using this website you acknowledge the practices described here. If you do not agree with them, please do not use the Services.

2. Information we collect

The categories of personal information we may collect depend on how you interact with us.

2.1 Information you provide directly

• Business contact details — name, company, role, email address and telephone number supplied when you write to one of our desks.
• Correspondence content — the substance of emails, attachments and any information you choose to include in them.
• Recruitment information — CVs, profile links and application context sent to our careers inbox.

2.2 Consumer inquiry information

Where a consumer submits an inquiry on a publisher property that participates in our network, the information passed to us typically includes contact details, the qualifying information relevant to that category, and the routing metadata described in Section 2.4. We do not operate consumer-facing inquiry forms on this website.

2.3 Information collected automatically

• Device and connection data — IP address, browser type and version, operating system, screen characteristics and language preference.
• Usage data — pages viewed, time on page, referring URL and interaction events.
• Cookie identifiers — as described in our Cookie Policy.

2.4 Routing metadata

For every consumer inquiry that moves through our platform we record the originating page URL, the submission timestamp, the publisher and channel identifier, the disclosure language displayed at the point of submission, and the outcome of each validation and routing check applied. This metadata exists so that both we and the receiving advertiser can evidence the basis on which contact is made.

2.5 Information from third parties

We may receive information from service providers that assist with validation, fraud prevention, analytics and communications, and from publishers and advertisers under our written agreements with them.

2.6 Sensitive information

We do not seek to collect government identification numbers, financial account numbers, precise geolocation, biometric data, or information revealing health, racial or ethnic origin, religious belief, sexual orientation or union membership through this website. Please do not send such information to us by email.

3. How we use information

We use personal information for the following business and commercial purposes:

1. Operating the network — validating, filtering, routing and delivering consumer inquiries to advertisers in accordance with our agreements.
2. Maintaining records — retaining consent context and delivery logs so that a record's history can be reconstructed if questioned.
3. Managing relationships — onboarding advertisers and publishers, reviewing placements, resolving queries and handling settlement.
4. Communicating with you — responding to messages sent to our desks and providing service updates.
5. Quality and fraud controls — detecting duplicate, invalid or fraudulent submissions and investigating suspected misuse.
6. Analytics and improvement — understanding how this website is used so that we can improve it.
7. Security — protecting our systems, our partners and the individuals whose information we hold.
8. Legal compliance — meeting obligations under applicable law, responding to lawful requests and enforcing our terms.
9. Corporate transactions — evaluating or completing a merger, acquisition, financing or sale of assets.

We do not use personal information collected through this website to build consumer advertising profiles, and we do not engage in automated decision-making that produces legal or similarly significant effects on an individual.

4. When we disclose information

We disclose personal information in the following circumstances:

• To advertisers — consumer inquiries are delivered to the advertiser or advertisers a consumer has asked to hear from, together with the routing metadata described in Section 2.4. Those businesses are independent controllers of the information once received and their own privacy notices apply.
• To service providers — hosting, security, validation, analytics, communications and professional advisers, each bound by contract to use the information only for the purpose we specify.
• To publishers — aggregate or record-level performance information relating to traffic they supplied, for reconciliation and quality purposes.
• For legal reasons — where disclosure is required by law, regulation, legal process or governmental request, or where we believe disclosure is necessary to protect rights, safety or property.
• In corporate transactions — to a counterparty, adviser or successor in connection with a merger, acquisition, financing or sale of assets.
• With your direction — where you ask us to share information with a specified third party.
• In de-identified or aggregated form — information that can no longer reasonably be linked to an individual.

We do not disclose personal information to third parties for their own independent marketing purposes except as described in this policy and permitted by the consent obtained at the point of collection.

5. Cookies and similar technologies

This website uses cookies and comparable technologies to operate correctly, remember preferences and measure usage. Details of each category, its purpose and how to control it are set out in our Cookie Policy.

You can manage cookies through your browser settings. Blocking certain categories may affect how parts of this website function.

6. Security

We maintain administrative, technical and physical safeguards designed to protect personal information against unauthorised access, disclosure, alteration and destruction. These include encryption of data in transit and at rest, role-based access controls, credential rotation, logging of access to consumer records, and vendor diligence for service providers who handle personal information on our behalf.

No method of transmission or storage is completely secure. While we work to protect information, we cannot warrant absolute security, and any transmission of information to us is at your own risk.

7. Retention

We retain personal information for as long as necessary to fulfil the purposes described in this policy, including to maintain the audit and consent records that allow a delivery to be evidenced, to resolve disputes, to enforce agreements and to comply with legal obligations.

Retention periods are set by written policy and vary by category of information. When a period expires, information is deleted or de-identified. Retention is not open-ended and is reviewed on a recurring schedule.

8. Your choices

8.1 Marketing communications

You may opt out of business marketing emails from us at any time by using the unsubscribe mechanism in the message or by writing to privacy@azulperformance.com. We may still send operational messages relating to an existing relationship.

8.2 Consumer suppression

A consumer who no longer wishes to be contacted in connection with an inquiry submitted through our network can ask to be suppressed. Suppression is applied across the network rather than to a single campaign. Requests should be sent to privacy@azulperformance.com.

8.3 Browser controls

Most browsers allow you to refuse or delete cookies and to signal a preference not to be tracked. See our Cookie Policy for detail.

9. United States state privacy rights

Depending on your state of residence, you may have some or all of the following rights in relation to personal information about you:

• Right to know or access the categories and specific pieces of personal information we have collected, the sources, the purposes and the categories of recipients.
• Right to correct inaccurate personal information.
• Right to delete personal information, subject to statutory exceptions.
• Right to portability — to receive a copy in a portable format.
• Right to opt out of the sale or sharing of personal information and of targeted advertising.
• Right to limit the use and disclosure of sensitive personal information.
• Right to appeal a decision we make on a request, where your state provides one.
• Right to non-discrimination for exercising any of these rights.

These rights are recognised, in varying forms, under laws including the California Consumer Privacy Act as amended by the California Privacy Rights Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Virginia Consumer Data Protection Act, the Utah Consumer Privacy Act, the Texas Data Privacy and Security Act, the Oregon Consumer Privacy Act and comparable statutes in other states.

9.1 How to submit a request

Submit a request by email to privacy@azulperformance.com with the subject line “Privacy Request”. Please tell us which right you wish to exercise and the state in which you reside. Full detail of the process is on our privacy choices page.

9.2 Verification

We must verify your identity before acting on a request. Verification is proportionate to the sensitivity of the information involved and we will ask only for what is needed. Information supplied for verification is used solely for that purpose.

9.3 Authorized agents

An authorized agent may submit a request on your behalf with written permission signed by you. We may still contact you directly to confirm the authorisation.

9.4 Timing

We respond within the timeframe required by the applicable statute, generally forty-five days, with an extension where permitted and where we notify you of the reason.

10. Additional California disclosures

10.1 Categories collected

In the preceding twelve months we have collected the following categories of personal information as defined by the CCPA: identifiers; commercial information; internet or other electronic network activity information; professional or employment-related information; and inferences drawn from the foregoing. The sources, purposes and recipients are described in Sections 2 to 4.

10.2 Sale and sharing

Delivering a consumer inquiry to an advertiser in exchange for consideration may be treated as a “sale” under California law, even where the consumer requested the contact. We therefore provide an opt-out route regardless of interpretation. See our privacy choices page.

10.3 Sensitive personal information

We do not use or disclose sensitive personal information for purposes other than those permitted without a right to limit under California regulations.

10.4 Shine the Light

California Civil Code section 1798.83 permits residents to request information about disclosures of personal information to third parties for their direct marketing purposes. Requests may be sent to privacy@azulperformance.com.

10.5 Minors

We do not knowingly sell or share the personal information of consumers under sixteen years of age.

11. Opt-out preference signals and Do Not Track

Where required by applicable law, we honour opt-out preference signals such as Global Privacy Control transmitted by a browser or extension. A recognised signal is treated as a request to opt out of sale and sharing for that browser.

Web browsers may also transmit “Do Not Track” signals. Because no common industry standard for interpreting those signals has been adopted, we do not currently respond to them separately from the mechanisms described above.

12. Children

The Services are directed to businesses and to adults. We do not knowingly collect personal information from individuals under eighteen years of age. If we learn that we have collected such information, we will delete it promptly. A parent or guardian who believes a minor has provided information to us should contact the privacy inbox.

13. Third-party websites and links

This website links to third-party sites, including advertiser and publisher properties and social platforms. We do not control those sites and are not responsible for their content or privacy practices. Review the privacy notice of any site you visit.

13.1 International visitors

The Services are intended for users in the United States and information is processed there. If you access this website from another country, you do so on your own initiative and are responsible for compliance with local law. Data protection law in the United States may differ from that in your jurisdiction.

14. Changes and how to contact us

We may update this policy from time to time. Material changes will be reflected in the effective date at the top of this page and, where appropriate, communicated directly. Continued use of the Services after an update indicates acceptance of the revised policy.

Questions, requests and complaints relating to this policy should be directed to:

If you are dissatisfied with our response you may have a right to contact your state attorney general or another supervisory authority.