FullPAC, Inc. Privacy Policy 

Last Modified: June [2], 2026

FullPAC, Inc., a Nevada corporation (together with its subsidiaries and affiliates, “FullPAC”) is serious about protecting your privacy. We appreciate your trust and will strive to protect your privacy carefully and sensibly. This notice (this “Privacy Policy”) describes how we may collect personal information from the visitors to our site (the “User,” “you,” or “your”), how we may use that information, with whom we may share it, what choices you have regarding it, and how we protect it. 

Scope and Application

This Privacy Policy describes how FullPAC processes personal information in its capacity as a controller — that is, where FullPAC determines the purposes and means of processing. It applies to personal information FullPAC collects, uses, and discloses in connection with:

  • the websites and online platforms operated by FullPAC and its affiliates, currently including the marketing websites at gotv.com, robocent.com, advocacylab.com, and govt.com, the customer-facing application platforms used to access our services, and any successor, consolidated, or replacement site or platform (collectively, the “FullPAC Sites”); and
  • FullPAC’s own marketing, sales, customer relationship, and research activities, including any proprietary surveys, polling, or other research conducted on FullPAC’s own account.

This Privacy Policy does not cover personal information of FullPAC employees, contractors, or job applicants, which is addressed in separate notices provided to those individuals.

The FullPAC Sites and our services are directed exclusively to users located in the United States. FullPAC does not target, market to, or knowingly accept personal information from individuals located in the European Economic Area, the United Kingdom, or Switzerland. If you are located outside the United States, please do not provide personal information through the FullPAC Sites.

Services performed for FullPAC clients 

FullPAC’s principal business is providing technology and services to political clients, including campaigns, committees, political action committees, advocacy organizations, and officeholders. In delivering those services, FullPAC frequently processes personal information on behalf of and at the direction of its clients. With respect to such data, FullPAC acts as a service provider, processor, or equivalent role as defined under applicable privacy law, and the processing is governed by written agreements with each client that incorporate the terms required by those laws. This Privacy Policy does not govern the privacy practices applicable to client-controlled data; those practices are determined by the client. Individuals seeking to exercise privacy rights with respect to client-controlled data should contact the relevant client directly.

Requests directed to FullPAC concerning client-controlled data 

Where an individual contacts FullPAC seeking action with respect to personal information processed by FullPAC on behalf of a client, FullPAC will:

  • take any action that is within FullPAC’s independent authority or responsibility, including, where applicable, adding the relevant phone number, email address, or other identifier to FullPAC-maintained suppression or do-not-contact lists;
  • promptly notify the relevant client of the request, where the client is identifiable; and
  • where appropriate, direct the individual to the client for substantive resolution.

Cross-Client Suppression and Do-Not Contact Lists

FullPAC maintains internal suppression and do-not-contact lists that it uses to honor opt-out requests and to support its compliance obligations under the Telephone Consumer Protection Act and related rules, the CAN-SPAM Act, and similar laws. These lists are FullPAC’s own records, maintained in FullPAC’s capacity as a controller of those records.

The lists are applied on a cross-client basis: a phone number, email address, or other identifier added to a suppression list as a result of an opt-out, do-not-contact request, or compliance event in connection with one client’s communications is honored across all communications transmitted through FullPAC’s services, including for other clients.

Categories of personal information on these lists are limited to identifiers (such as phone numbers and email addresses) and metadata about the request (such as the date and channel of the opt-out). FullPAC retains suppression and do-not-contact list entries indefinitely for the purpose of honoring those requests on an ongoing basis.

Acknowledgement

By accessing and using the FullPAC Sites, you acknowledge that you have reviewed the privacy practices described in this Privacy Policy.

Changes to Privacy Policy

FullPAC reserves the right to change the terms of this Privacy Policy at any time. FullPAC may change its privacy practices because of changes in relevant and applicable legal or regulatory requirements, the business or business practices of FullPAC, or in its attempts to better serve your needs. Notice of such changes to FullPAC’s privacy practices will be given in the manner described in FullPAC’s Terms of Service, as posted on the FullPAC Sites, and a revised Privacy Policy will be posted on the FullPAC Sites.The version of this Privacy Policy posted on the FullPAC Sites controls over any other copy, including any printed or PDF version.

What Information Does FullPAC Collect?

FullPAC may collect various types of information from or about you, depending on how you use the FullPAC Sites and their various features. In particular, during the registration process and the process for accessing the services available on the FullPAC Sites, you supply FullPAC various types of information, including personal information that you choose to disclose, and information regarding how you use the FullPAC Sites, which FullPAC collects as you interact with the FullPAC Sites.

With respect to personal information, you may provide FullPAC with various types of information. Such information may include:

  • Identifiers (e.g., your name, address, telephone number, e-mail address, and other similar information)
  • Financial information (e.g., transaction information, billing and payment information that you voluntarily provide through the FullPAC Sites). 
  • Commercial information (e.g., interest in specific products or services, other similar information)
  • Internet or other electronic network activity information (e.g., IP address, browser type, cookies used for identification, and information regarding a user’s interaction with the FullPAC Sites).

Should you purchase or use any FullPAC products or services on or through the FullPAC Sites, the information that you supplied during the registration process may be used to track details about those purchases or use. FullPAC may collect email addresses from customers and visitors of the FullPAC Sites for the purpose of communicating with customers. 

FullPAC may also retain the content and metadata regarding any correspondence you may have with FullPAC or its customer service representatives, regardless of the mode of communication by which such correspondence was made. This includes, without limitation, any information contained and consented to, as described in the Terms of Service. This information helps FullPAC to improve the FullPAC Sites and the materials, products, and services that it offers on the FullPAC Sites, and to more effectively and efficiently respond to both current and future inquiries.

As with many other web sites, the Web servers used to operate the FullPAC Sites collect certain data pertaining to you and the equipment and communication methods that you use to access the Internet and the FullPAC Sites. Without combining this data with other sources of information, the Web servers do not readily identify you. The Web servers do reveal such things as the Internet protocol (“IP”) address assigned to your computer, pages you accessed on the FullPAC Sites, or immediately prior to visiting the FullPAC Sites, and the length of time you accessed the FullPAC Sites.

This information is collected to, among other things, facilitate operation and system administration of the FullPAC Sites, to generate aggregate, non-identifiable statistical information, and to improve content and content delivery with regard to the FullPAC Sites and the materials, products, and services that FullPAC makes available on the FullPAC Sites.

Sensitive Personal Information

Certain categories of personal information are designated as “sensitive personal information,” “sensitive data,” or equivalent terms under various state privacy laws and are subject to heightened protections.

In connection with the FullPAC Sites and our activities as controller, we may collect the following categories of information that are designated as sensitive under one or more applicable privacy laws:

  • Account credentials. Where the FullPAC Sites support user accounts, we collect log-in identifiers in combination with passwords or other authentication credentials.
  • Financial account information. In connection with billing for our services, we facilitate the collection of payment information, which is processed by our third-party payment processors. We do not collect or retain payment card numbers or financial account numbers in unmasked form.
  • Information collected through proprietary research. To the extent we conduct proprietary surveys, polling, or other research activities on our own account, the questions asked may elicit information designated as sensitive under applicable state privacy laws. Where this is the case, we will provide notice and seek any required consent at the time of collection.

Other than as described above, we do not knowingly collect categories of sensitive personal information through the FullPAC Sites in connection with our activities as controller.

We use sensitive personal information only for the purposes for which it was collected, including: providing the services or features you have requested; verifying your identity; preventing fraud, unauthorized access, and other security incidents; processing payments; complying with legal obligations; and conducting proprietary research with appropriate notice. As described in the section on Your Privacy Rights, residents of certain states may have the right to direct us to limit our use and disclosure of sensitive personal information.

Cookies and Similar Technologies

We use cookies and similar technologies on the FullPAC Sites. This section describes what those technologies are, how we use them, and how you can manage your preferences. 

What are cookies and similar technologies? Cookies are small data files placed on your device when you visit a website. We also use other technologies that perform similar functions, including pixels, web beacons, and local storage. In this Policy, we use the term “cookies” to refer collectively to these technologies. 

Categories of cookie use. We use the following categories of cookies on the FullPAC Sites: 

  • Strictly necessary cookies are required for the FullPAC Sites to function and cannot be disabled. They support core functionality such as security, network management, and accessibility. 
  • Performance and analytics cookies help us understand how visitors interact with the FullPAC Sites by collecting information about the pages visited, time spent, and similar metrics. We use this information to improve the FullPAC Sites and measure the effectiveness of our communications. 
  • Functional cookies allow the FullPAC Sites to remember choices you make and provide enhanced features. 
  • Advertising and targeting cookies are used to deliver advertising relevant to your interests, including on third-party sites and platforms, and to measure the effectiveness of our advertising. As described in the section on Disclosure of Personal Information, these activities may constitute a “sale” or “share” under California law and “targeted advertising” or equivalent activity under the laws of other states. 

A current list of the specific cookies and similar technologies in use on the FullPAC Sites, including the providers, purposes, and durations, is available through the cookie management tool on the FullPAC Sites.

Third-party cookies. Some of the cookies on the FullPAC Sites are placed by third parties, including providers of analytics, advertising, and embedded content. These third parties may collect information about your interactions with the FullPAC Sites and may combine that information with information they collect from other sources. The third parties’ use of personal information collected through their cookies is governed by their own privacy policies.

Managing your preferences. You can manage your cookie preferences in the following ways: 

  • Cookie management tool. The cookie management tool on the FullPAC Sites allows you to accept or reject categories of non-essential cookies. You can change your preferences at any time by accessing the tool, which is available on each page of the FullPAC Sites.
  • Browser settings. Most browsers allow you to block or delete cookies through browser settings. Note that browser settings control cookies set by all sites you visit and may not affect non-cookie technologies. Blocking strictly necessary cookies may impair the functioning of the FullPAC Sites.
  • Global Privacy Control. As described in the section on Your Privacy Rights, we honor the Global Privacy Control browser signal as a valid opt-out request for the browser and device on which it is enabled.

Do Not Track. Some web browsers offer a “Do Not Track” feature that signals to websites you visit that you do not wish to have your activity tracked. Because no common standard for responding to Do Not Track signals has been adopted, we do not currently respond to such signals. We do honor Global Privacy Control signals as described above.

Children’s Privacy

The FullPAC Sites are intended for use by adult professional users. The FullPAC Sites are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. 

If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information promptly. Parents or guardians who believe their child has provided personal information to us may contact us at legal@fullpac.com to request review and deletion.

As described in the section on Disclosure of Personal Information, we do not knowingly sell or share the personal information of consumers under the age of 16.

How Does FullPAC Use the Information That We Collect?

In addition to the uses mentioned or described above, FullPAC uses the information that it collects from or about you to improve the materials, products, and services that FullPAC makes available on the FullPAC Sites, to notify you of changes made to the FullPAC Sites or new products or services made available on or through the FullPAC Sites, to evaluate your needs and customize content delivered to you on the FullPAC Sites according to those needs, to facilitate the processing of any purchases or uses you make through the FullPAC Sites, to send you promotional material from FullPAC or its affiliates, and for other legitimate and lawful business purposes of FullPAC.

How Does FullPAC Protect Information Collected About You?

We implement and maintain reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, or destruction. These safeguards include encryption of personal information in transit and at rest where appropriate, access controls limiting personal information to authorized personnel, network and infrastructure security measures, vendor due diligence and contractual security obligations, and physical security controls for our facilities and equipment.

We engage third-party service providers to support specific security functions, including payment processing services that use industry-standard encryption to protect payment card and financial account information.

No security system is impenetrable. While we work to protect personal information, we cannot guarantee the security of any information transmitted to or stored on the FullPAC Sites, and you provide information at your own risk.

Disclosure of Personal Information

We disclose personal information in the circumstances described below. We do not disclose personal information to third parties for their own independent marketing purposes without your consent.

Service providers. We disclose personal information to service providers that perform functions on our behalf, under written agreements that restrict their use of the information to the services they provide to us. Categories of service providers include hosting and infrastructure providers, analytics providers, artificial intelligence and large language model providers, payment processors, marketing automation and email service providers, customer relationship management and customer support providers, communications platforms, and security and fraud prevention providers.

Cross-context behavioral advertising; “sale” and “share” under state law. The FullPAC Sites use third-party advertising and analytics technologies that collect information about your interactions with the Sites and may combine that information with information collected from other sites and services. These activities may constitute a "sale" or "share" of personal information under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and may constitute "targeted advertising" or equivalent activity under the privacy laws of other states. A current list of the specific advertising and analytics technologies in use on the FullPAC Sites, and the cookies and similar technologies they deploy, is available through the cookie management tool on the FullPAC Sites.

You may opt out of these activities at any time by:

  • visiting our “[Your Privacy Choices]” page and submitting an opt-out request;
  • adjusting your cookie preferences using the cookie management tool available on the FullPAC Sites; or
  • enabling the Global Privacy Control (GPC) signal in a supported browser, which we will treat as a valid opt-out request for the browser and device on which it is enabled. 

We do not knowingly sell or share the personal information of consumers under 16 years of age. 

Legal process; protection of rights. We disclose personal information when we believe in good faith that disclosure is required to comply with applicable law, regulation, legal process, or governmental request; to enforce our terms of service or other agreements; to investigate or prevent fraud, security incidents, or other misconduct; or to protect the rights, property, or safety of FullPAC, our users, or others.

Corporate transactions. In connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or other corporate transaction, we may disclose or transfer personal information to the counterparty and its advisors, subject to customary confidentiality protections. If personal information is transferred as part of a completed transaction, we will provide notice of the change in controller as required by applicable law.

With your direction or consent. We disclose personal information for any other purpose disclosed at the time of collection or with your consent.

Aggregated and de-identified information. We may create and disclose aggregated information and de-identified information that cannot reasonably be used to identify, relate to, describe, be associated with, or be linked to any consumer or household. Where we use de-identified information, we maintain it in de-identified form, do not attempt to re-identify it, and contractually obligate any recipient to do the same.

Categories of personal information disclosed in the preceding twelve months. Consistent with the above, in the preceding twelve months we have disclosed the following categories of personal information for the business and commercial purposes described in this Policy:

  • Identifiers (e.g., your name, address, e-mail address, phone number, IP address, and other similar information) – disclosed to service providers, advertising and analytics partners, legal and corporate transaction recipients;
  • Commercial information (e.g., interest in FullPAC products and services, transaction history) – disclosed to service providers and legal and corporate transaction recipients;
  • Internet or other electronic network activity information (e.g., browsing history, interactions with the FullPAC Sites, device and browser data) — disclosed to service providers, advertising and analytics partners;
  • Inferences drawn from the foregoing to create profiles reflecting preferences and characteristics — disclosed to service providers and advertising and analytics partners.

We have not sold personal information for monetary consideration in the preceding twelve months. As described above, certain disclosures of internet or other electronic network activity information and identifiers in connection with cross-context behavioral advertising may constitute a "sale" or "share" under applicable state law.

Linked Sites

For your convenience, third-party content may appear on the FullPAC Sites, including hyperlinks to other websites or the logos of our service providers and clients, that may take you to websites or services not under FullPAC’s control. Please note that this Privacy Policy applies only to the FullPAC Sites and not to other web sites of other organizations to which they link. FullPAC is not responsible for the privacy policies or practices of any other third party sites. You should make your own inquiries regarding them. In addition, when you initiate a transaction on a web site that the FullPAC Sites link to, even if you reached that site through the FullPAC Sites, the information that you submit to complete that transaction becomes subject to the privacy practices of the owner of that linked site. You should read the linked site’s privacy policies to understand how they use and protect the personal information that they collect. FullPAC is not responsible for the privacy or information practices of its suppliers or any third party web sites. 

Your Privacy Rights

Depending on your state of residence, applicable privacy law may grant you the following rights with respect to your personal information, subject to the limitations and exceptions established by state law: 

  • Right to know or access. To confirm whether we process personal information about you and to request access to that information, including the categories of personal information collected, the categories of sources, the purposes of collection, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected.
  • Right to correction. To request that we correct inaccurate personal information that we maintain about you.
  • Right to data portability. To receive a copy of your personal information you have provided to us in a portable and, to the extent technically feasible, readily usable format.
  • Right to deletion. To request that we delete personal information that we have collected from you, subject to exceptions established by applicable law (for example, where retention is necessary to comply with a legal obligation, complete a transaction, or detect security incidents). If we deny your request for deletion, we will let you know the reason why.
  • Right to restrict or opt out of the sale of personal information, the sharing of personal information for cross-context behavioral advertising, and targeted advertising. As described in the section on Disclosure of Personal Information, you may exercise these rights through our [Your Privacy Choices] page, the cookie management tool on the FullPAC Sites, or by enabling the Global Privacy Control browser signal.
  • Right to limit the use and disclosure of sensitive personal information. Where applicable, you may direct us to limit the use and disclosure of sensitive personal information to purposes necessary to provide the services you have requested or as otherwise permitted by law.
  • Right to equal service. If you choose to exercise any of these rights, we will not discriminate against you in any way. 

How to Submit a Request

To exercise the rights described above, please contact us as follows:

Email: privacy@fullpac.com
Phone: 757-731-6400

Mail: FullPAC, Inc.
ATTN: Privacy Team
1206 Laskin Road, Suite 201-o
Virginia Beach, Virginia 23451
Online: through the [Your Privacy Choices] page on the FullPAC Sites

Authorized agents. You may designate an authorized agent to submit a request on your behalf. We will require (i) written authorization signed by you designating the agent, or a valid power of attorney; and (ii) verification of your identity directly with us, except where the agent has been designated by power of attorney. We may deny a request from an agent that does not provide proof that they have been authorized to act on your behalf.

Verification. We will take reasonable steps to verify your identity before responding to a request, which may include matching information you provide with information we maintain about you or, for sensitive requests, requiring a signed declaration under penalty of perjury. We will use any information collected for verification only for that purpose.

Response time. We will respond to a verifiable request within 45 days of receipt. If we require additional time, we may extend the response period by an additional 45 days, with notice to you of the extension and the reason for it.

Right to appeal. If we decline to take action on your request, you may appeal our decision by replying to our response or by contacting us through any of the channels listed above and indicating that you wish to appeal. We will respond to your appeal within 45 days (or such longer period as applicable law permits) with a written decision and the reasons for it. If your appeal is denied, you may contact your state attorney general or the California Privacy Protection Agency, as applicable, to submit a complaint.

Frequency and fees. You may submit requests free of charge up to twice in any twelve-month period. We may charge a reasonable fee or decline to act on requests that are manifestly unfounded, excessive, or repetitive, in which case we will provide an explanation.

What Choices Do You Have?

You may update at any time the information about you and your personal preferences stored on the FullPAC Sites derived from your registration on the same. You may choose to opt out of receiving future marketing or promotional email messages from us. Each such email (excluding non-promotional communications, such as those responding to your specific inquiries or related to your relationship with us) sent by us contains an “unsubscribe,” “opt- out”, or similar link with instructions on how to remove yourself from the applicable email list. Additionally, we may always email you in response to your correspondence or in connection with any other transactions you have with us.

Retention of Personal Information

We retain personal information for the period reasonably necessary to fulfill the purposes described in this Policy. We may delete or de-identify personal information earlier than any specific retention period where we determine that the information is no longer needed for the purpose for which it was collected, except where retention is required by law, contract, or for the establishment, exercise, or defense of legal claims.

The retention period for a given category of personal information depends on factors including:

  • the duration of our relationship with you and our ongoing need to provide services or respond to your inquiries;
  • legal, accounting, tax, and regulatory requirements that apply to the type of information;
  • contractual obligations that govern retention;
  • the relevant statute of limitations and any actual or anticipated legal dispute or claim;
  • the type and sensitivity of the information; and
  • our operational needs, including security, fraud prevention, and the maintenance of suppression and do-not-contact lists.

Certain categories of information are retained beyond the period of our active relationship with you. These include transaction and billing records (retained for the period required by applicable tax and accounting laws), records of opt-out requests and entries on suppression and do-not-contact lists (retained for the period necessary to honor those requests on an ongoing basis), and information subject to legal hold or required for the defense of legal claims (retained until the relevant matter is resolved).

As described in the section on Your Privacy Rights, residents of certain states may request the deletion of personal information we have collected from them, subject to the limitations and exceptions established by applicable law. Where we cannot fully comply with a deletion request because retention is required by law or for one of the purposes described above, we will explain the basis for any partial denial.

Who Can You Contact For More Information?

Should you feel that your privacy or security is being compromised, or have any other questions regarding FullPAC’s privacy practices or this Privacy Policy, please notify FullPAC using the following contact information:

FullPAC, Inc.
ATTN: Privacy Team
1206 Laskin Road Suite 201-o
Virginia Beach, Virginia 23451

Email: privacy@fullpac.com