Privacy Policy
This Privacy Policy has been designed to set out our consumer information collection and processing practices related to personal information in the course of our business, including on our website, myhelpbenefits.com (the “Website”), or other web properties (referenced collectively herein as the “Website”), and the services provided on the Website (the “Services”). Please review fully as this policy affects your rights and our use of your personal information and advises you how to exercise your rights with respect to your personal information. This Privacy Policy is governed by the Terms of Use.
1. INFORMATION COLLECTION
We have collected personal information about individuals, including individuals who have visited and used our Websites; participated in our surveys or other promotions; and/or provided their personal information to third parties who have shared such with us, in the preceding twelve (12) months, as noted here:
| Categories of (PI) | Categories of Sources from which the Personal Information is collected from? | Business Purpose | Length of Retention |
| Identifiers, or information that identifies, relates to, describes, or is capable of being associated with, a particular individual | ☐ not applicable (not collected) ☒ Consumer directly; ☐ Advertising networks; ☒ ISPs; ☒ Data analytics providers; ☐ Gov’t entities; ☐ Operating systems and platforms; ☐ Social networks; ☒ Data brokers; ☒ Other third parties: credit reporting agencies | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. | Identifiers collected in conjunction with an individual’s TCPA consent are retained for a period of 6 years; All other data is retained indefinitely, unless the consumer requests that their information be deleted |
| Characteristics of protected classifications under California or federal law. | ☐ not applicable (not collected) ☒ Consumer directly; ☐ Advertising networks; ☒ ISPs; ☒ Data analytics providers; ☐ Gov’t entities; ☐ Operating systems and platforms; ☒ Social networks; ☒ Data brokers; ☐ Other third parties | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. | Retained indefinitely, unless the consumer requests that their information be deleted |
| Commercial information | ☐ not applicable (not collected) ☒ Consumer directly; ☒ Advertising networks; ☒ ISPs; ☒ Data analytics providers; ☐ Gov’t entities; ☐ Operating systems and platforms; ☒ Social networks; ☒ Data brokers; ☐ Other third parties | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. | Retained indefinitely, unless the consumer requests that their information be deleted |
| Biometric information | ☒ not applicable (not collected) | Not applicable | Not applicable |
| Internet or other electronic network activity information | ☐ not applicable (not collected) ☒ Consumer directly; ☒ Advertising networks; ☒ ISPs; ☒ Data analytics providers; ☐ Gov’t entities; ☒ Operating systems and platforms; ☒ Social networks; ☒ Data brokers; ☐ Other third parties | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. | Retained indefinitely, unless the consumer requests that their information be deleted |
| Geolocation data | ☐ not applicable (not collected) ☒ Consumer directly; ☒ Advertising networks; ☒ ISPs; ☒ Data analytics providers; ☐ Gov’t entities; ☒ Operating systems and platforms; ☒ Social networks; ☒ Data brokers; ☐ Other third parties | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. | Retained indefinitely, unless the consumer requests that their information be deleted |
| Audio, electronic, visual, thermal, olfactory, or similar information (sensory data) | ☐ not applicable (not collected) ☒ Consumer directly; ☐ Advertising networks; ☐ ISPs; ☒ Data analytics providers; ☐ Gov’t entities; ☒ Operating systems and platforms; ☐ Social networks; ☐ Data brokers; ☒ Other third parties: call centers | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. | Retained indefinitely, unless the consumer requests that their information be deleted |
| Professional or employment-related information | ☐ not applicable (not collected) ☒ Consumer directly; ☐ Advertising networks; ☐ ISPs; ☒ Data analytics providers; ☐ Gov’t entities; ☐ Operating systems and platforms; ☐ Social networks; ☒ Data brokers; ☒ Other third parties: credit reporting agencies | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. | Retained indefinitely, unless the consumer requests that their information be deleted |
| Education information | ☐ not applicable (not collected) ☒ Consumer directly; ☐ Advertising networks; ☐ ISPs; ☒ Data analytics providers; ☐ Gov’t entities; ☐ Operating systems and platforms; ☐ Social networks; ☒ Data brokers; ☐ Other third parties | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. | Retained indefinitely, unless the consumer requests that their information be deleted |
| Inferences drawn from any of the information identified above to create a profile about a consumer reflecting their preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | ☐ not applicable (not collected) ☒ Consumer directly; ☒ Advertising networks; ☐ ISPs; ☒ Data analytics providers; ☐ Gov’t entities; ☒ Operating systems and platforms; ☐ Social networks; ☒ Data brokers; ☐ Other third parties | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. | Retained indefinitely, unless the consumer requests that their information be deleted |
| Sensitive personal information | ☐ not applicable (not collected) ☒ Consumer directly; ☐ Advertising networks; ☒ ISPs; ☒ Data analytics providers; ☐ Gov’t entities; ☐ Operating systems and platforms; ☐ Social networks; ☒ Data brokers; ☒ Other third parties: credit reporting agencies | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. | Retained indefinitely, unless the consumer requests that their information be deleted |
As noted in the above chart, we may collect personal information that personally identifies, relates to, describes, or is capable of being associated with you, including:
- Identifiers, or other Information that identifies, relates, to, describes, or is capable of being associated with an individual, which may include your first name, last name, postal address, address, phone number, mobile number, IP address, age range/age, or other similar identifiers;
- Characteristics of protected classifications under applicable state or federal law, which may include your gender, marital status, and disability;
- Your commercial information, which may include your visiting one of our client’s websites, purchase of products or services from us or third parties, profile information relating to your interests, internet usage, search history, feedback information, communication preferences, customer service and communication history;
- Your internet or other electronic network activity information, which includes your IP address, log data, analytics data, device ID, and other data collected through pixels, cookies, web beacons, JavaScript, and similar technologies on our and third party websites. This may also include your browsing history, search history and your interaction with a website, app, email or advertisement;
- Your geographical location, when we collect your IP address, we collect your general geographic location when viewing our Website. If you provide your address in response to a prompt, then we collect your precise geographic location;
- Recording your calls to us and movement through our Website, where permitted by law, we may recording phone calls between us or our customer service providers, including call centers. We may also implement technology on our Website which tracks and captures your browsing and use of Services while on our Website;
- Professional or employment-related information, which may include your employment history or other employment information which you provide to us on our Website or by visiting one of our client’s websites;
- Education information, which may include your education level, or other education information which you provide to us on our Website or by visiting one of our client’s websites;
- Inferences drawn from other personal information or data, means we use all of the information we and third parties collect from you to draw an inference about interests and preferences you would like us to use based on our and third party’s analysis of your trends and this may include making a profile of you which includes all information we or they have collected and this may result in a profile of your likes and dislikes;
- Sensitive personal information, which may include your disability status, you provide to us on our Website or by visiting one of our client’s websites; and
No Information Collected from Children. We will never knowingly collect any Personal Information from anyone under the age of 16. If we accidentally collect such information, we delete the same upon notice.
2. HOW INFORMATION IS COLLECTED THROUGH TECHNOLOGY ON OUR WEBSITE AND EMAILS
In addition to information which you provide directly on our Website, we also collect information through various types of technology on our Website and through emails.
(a) Generally. We, our service provides and third party vendors, networks, ISP(s) and supporting advertisers use technologies such as cookies, web beacons, web tags, and java scripts to collect information about you. Using these technologies, we collect the personal information described above, including but not limited to your IP addresses, browser type, ISP, referring/exit pages, operating system, date/time stamp, and/or clickstream data. We use this to analyze trends, monitor and update our Website, ease of movements through our Website and gather demographic information about our user base, as a whole, to attract advertising on our Website. We may create reports or logs based on these technologies on an individual or aggregated basis. California residents should be advised we do not respond to do not track signals or cookies.
(b) Cookies. If enabled, cookies store small amounts of information on your computer about actions you take on our Website. This helps us track which of our features you visit most often, and what content you view and keep track of the number of return visits. We accumulate and aggregate statistical information generally pertaining to our Website, to market our Website and deliver specific content to you based on your past viewing history. You can modify or disable cookies, but our Website may not function properly for you. You may read more about cookies at http://cookiecentral.com/faq/.
(c) Third Party Cookies. We use various ad services provided by Google that connects the activity on our Website with their advertising network and they may use cookies that collect information regarding certain patterns in your browsing history. To opt-out of this tracking, please see https://support.google.com/ads/answer/2662922?hl=en. We also participate in all of Google’s Analytics Advertising. This includes but is not limited to: (i) Remarketing with Google Analytics; (ii) Google Display Network Impression Reporting; (iii) Google controlled Campaign Manager integration; (iv) Google Analytics Demographics and Interest Reporting; (v) Google Search Console; (vi) Google AdSense; and (vii) Google Tag Manager. Google uses cookies to track activity performed by Google Analytics and its AdWords or DoubleClick cookie. To opt-out please see https://tools.google.com/dlpage/gaoptout/. We also use Google Analytics which is an analysis service. Google utilizes the data collected through its cookies to track and examine the use of this Website, to prepare reports on its activities, and to share them with other Google services. You may opt-out of the Google Analytics service using Google’s Browser Add-on here https://tools.google.com/dlpage/gaoptout/. We may also use Taboola and you may view their cookie collection policy at https://www.taboola.com/policies/privacy-policy. Please remember that we do not control the information collection by these third parties and you will need to view their policies to remove your information and limit their cookie use.
(d) Web Beacons. We may use web beacons to collect information about your visit to our Website, measure and improve the effectiveness of advertisements and track delivery of advertising. Web beacons collect only a limited set of information including a cookie number, time, and date of page view, as well as a description of the page on which the web beacon resides. We may also use web beacons in email messages sent to you. This allows us to determine if you opened or acted upon the email message. Because web beacons are the same as any other content request, you cannot opt-out or refuse them. However, they can be rendered ineffective by either opting-out of cookies or changing the cookie setup in your browser. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.
(e) Pixels and Third Party Tracking. We may automatically collect information when an individual opens one of our emails, through the use of cookies and tracking pixels. We also automatically collect information on whether the individual clicked on any links within such emails. Third party publishers may also automatically collect information when an individual opens an email promoting the Website or clicks on a link included in such email, through the use of cookies and tracking pixels. To the extent that you click on a third party advertisement, or a particular product or service featured on the Website or in any email communication or newsletter, we and the applicable third party collect information on which link you clicked. We may receive compensation from third party lead aggregators, lead purchasers, and/or advertisers based on based on clicks, leads, and/or purchases generated through the Website and through any related emails. If you request to unsubscribe from receiving emails, we and our third party publishers may add your email address to Our suppression file, to comply with CAN-SPAM.
In addition to the above, we also may collect information through third party lead aggregators, lead purchasers, and advertisers, concerning whether you acquired information on the featured products and/or services.
Other. We use Google Tag Manager to manage and deploy marketing tags, or snippets of code, on the Website. We also use Google Search Console to understand how the Website is performing on Google Search; and Google AdSense to advertise.
3. DISCLOSURE OF PERSONAL INFORMATION.
We have disclosed personal information about consumers for a business purpose to third parties within the preceding twelve (12) months as noted here:
| Categories of Personal Information (PI) | Categories of Third Parties to Whom Such PI is Disclosed | Specific Business or Commercial Purpose for Disclosure |
| Identifiers, or information that identifies, relates to, describes, or is capable of being associated with, a particular individual | ☐ not applicable (not disclosed) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Characteristics of protected classifications under California or federal law. | ☐ not applicable (not disclosed) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Commercial information | ☐ not applicable (not disclosed) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Biometric information | ☒ not applicable (not disclosed) | Not applicable |
| Internet or other electronic network activity information | ☐ not applicable (not disclosed) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Geolocation data | ☐ not applicable (not disclosed) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Audio, electronic, visual, thermal, olfactory, or similar information | ☐ not applicable (not disclosed) ☒ direct lead buyers; ☐ email marketers/email marketing partners; ☐ email service providers; ☐ offline marketing partners; ☐ advertising networks; ☐ payment processors; ☐ data hygiene companies; ☐ ISPs; ☐ data analytics providers; ☒ gov’t entities; ☒ operating systems and platforms; ☐ social networks; ☐ data brokers; ☐ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Professional or employment-related information | ☐ not applicable (not disclosed) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Education information | ☐ not applicable (not disclosed) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Inferences drawn from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, behavior, etc. | ☐ not applicable (not disclosed) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Sensitive personal information | ☐ not applicable (not disclosed) ☒ direct lead buyers; ☐ email marketers/email marketing partners; ☐ email service providers; ☐ offline marketing partners; ☐ advertising networks; ☐ payment processors; ☐ data hygiene companies; ☐ ISPs; ☐ data analytics providers; ☒ gov’t entities; ☐ operating systems and platforms; ☐ social networks; ☐ data brokers; ☐ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
4. SHARING AND SALE OF PERSONAL INFORMATION
We have sold and shared personal information about consumers for a business purpose to third parties within the preceding twelve (12) months as noted here:
| Categories of Personal Information (PI) | Categories of Third Parties to Whom Such PI is Sold or Shared | Specific Business or Commercial Purpose for Sale or Sharing |
| Identifiers, or information that identifies, relates to, describes, or is capable of being associated with, a particular individual | ☐ not applicable (not sold or shared) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Characteristics of protected classifications under California or federal law. | ☐ not applicable (not sold or shared) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) | ☐ not applicable (not sold or shared) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Biometric information | ☒ not applicable (not sold or shared) | Not applicable |
| Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement) | ☐ not applicable (not sold or shared) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Geolocation data | ☐ not applicable (not sold or shared) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Audio, electronic, visual, thermal, olfactory, or similar information | ☐ not applicable (not sold or shared) ☒ direct lead buyers; ☐ email marketers/email marketing partners; ☐ email service providers; ☐ offline marketing partners; ☐ advertising networks; ☐ payment processors; ☐ data hygiene companies; ☐ ISPs; ☐ data analytics providers; ☒ gov’t entities; ☒ operating systems and platforms; ☐ social networks; ☐ data brokers; ☐ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Professional or employment-related information | ☐ not applicable (not sold or shared) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Education information | ☐ not applicable (not sold or shared) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Inferences drawn from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, behavior, etc. | ☐ not applicable (not sold or shared) ☒ direct lead buyers; ☒ email marketers/email marketing partners; ☒ email service providers; ☒ offline marketing partners; ☒ advertising networks; ☐ payment processors; ☒ data hygiene companies; ☐ ISPs; ☒ data analytics providers; ☐ gov’t entities; ☒ operating systems and platforms; ☒ social networks; ☒ data brokers; ☒ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
| Sensitive personal information | ☐ not applicable (not sold or shared) ☒ direct lead buyers; ☐ email marketers/email marketing partners; ☐ email service providers; ☐ offline marketing partners; ☐ advertising networks; ☐ payment processors; ☐ data hygiene companies; ☐ ISPs; ☐ data analytics providers; ☒ gov’t entities; ☐ operating systems and platforms; ☐ social networks; ☐ data brokers; ☐ acquirer of assets; ☐ others | ☒ 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 ☒ Helping to ensure security and integrity; ☒ Debugging to identify and repair errors that impair existing intended functionality. ☒ Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. ☒ Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. ☒ Undertaking internal research for technological development and demonstration. ☒ Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
5. THIRD PARTY COLLECTION AND USE OF INFORMATION
(a) Advertisers. Advertising agencies, advertising networks, and other companies who place ads on our Website, may use their own technology, to collect information about you. We do not control the use of such technology and have no responsibility for the use of such technology to gather information about you. We also do not control how such information is used or shared. Please be sure to read their privacy policy and practices.
(b) Links. For your convenience, our Website and email messages sometimes contain hypertext links to websites owned by third parties. We are not responsible for the privacy practices or the content of such other websites. We do not operate or control any information, software, products, or services, available on these third party websites. The inclusion of a link on our Website does not imply any endorsement of the services, products or website, or its sponsoring organization.
(c) Analytics. As described above, we use Service Providers to monitor, analyze and report on the traffic to, from and within our Website and email messages.
6. STORAGE AND SECURITY OF INFORMATION
We use reasonable industry-accepted technology and controls to protect your information and data from disclosure to unauthorized third parties. This includes firewalls, secured facilities, and logged and limited access. Although mostly effective to prevent disclosure, no guarantee can be given that all information you provide to us will not be accessed by unauthorized persons. Thus, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. Any transmission of data to use or through our Website is at your own risk.
7. CHANGE TO THIS PRIVACY POLICY
We have the right to make material changes to this Privacy Policy. We will post those changes through a prominent notice on the Website with no further notice to you. Please review this policy often so that you will always know what information we gather, how we might use that information, and with whom we disclose, share, and sell it.
8. STATE PRIVACY SUPPLEMENTAL NOTICE
The information for residents of each of the featured states below is intended to supplement the information contained in our primary Privacy Policy.
California Residents – Your Privacy Rights
A. California “Shine the Light” Disclosure. The California “Shine the Light” law gives California residents the right to request, once a year, information under certain circumstances to request information from us regarding the types of personal information we have shared with third parties for their direct marketing purposes during the immediately preceding calendar year; and the names and addresses of third parties with whom we have shared the personal information. You have agreed to allow us to share information with third parties for their direct marketing purposes until you request to opt-out of such sharing. California residents may request further information about our compliance with this law by contacting us via email at [email protected]. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address.
B. California Consumer Privacy Act of 2018. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA and CPRA have the same meaning when used in this Notice. The CCPA and CPRA are collectively referred to as the “CCPA” for purposes of this Notice. If you are a California resident under the meaning of Sec. 17014 of Title 18 of the Cal. Code of Regulations, your use of the Website is subject to the CCPA, and all final, implementing regulations.
C. California Privacy Choices. If you are a resident of California, and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:
(A) Notice at Collection: at or before the point of collection, the right to receive notice of our practices, including the categories of personal information and any sensitive personal information to be collected; the purposes for which such information is collected or used; whether such information is sold or shared; and the length of time that such information is retained. This information is found within this section.
(B) Right to Know What Personal Information is Collected & Right to Access Personal Information: The right to know what personal information the business has collected about the consumer, including the categories of personal information, categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information the business has collected about the consumer;
(C) Right to Delete: The right to request that a business delete personal information that the business has collected from the consumer, subject to certain exceptions;
(D) Right to Correct: The right to correct inaccurate personal information that a business maintains about a consumer;
(E) Right to Opt-Out of the Sale or Sharing of Personal Information: if the business sells or shares personal information, the right to opt-out of the sale or sharing of personal information by the business;
(F) Right to Limit the Use or Disclosure of Sensitive Personal Information: if the business uses or discloses sensitive personal information for reasons other than those in § 7027(m), the right to limit the use or disclosure of such sensitive personal information; and
(G) Right to No Discrimination: The right not to receive discriminatory treatment by the business for the exercise of CCPA privacy rights.
Information regarding our collection, disclosure, and sale/sharing practices are detailed below, in addition to instructions on how to exercise your CCPA rights.
D. What Personal Information Do We Collect?
We have collected personal information about consumers within the preceding twelve (12) months as detailed above under the “Information Collection” section.
E. What Personal Information Do We Disclose?
We have disclosed personal information about consumers for a business purpose to the third parties identified under the “Disclosure of Personal Information” and “Third Party Collection and Use of Information” sections above in the preceding twelve (12) months. We do not use or disclose sensitive personal information for purposes other than those specific in Section 7027(m) of the California Consumer Privacy Act Regulations.
F. What Personal Information Do We Sell or Share?
In the preceding 12 months, we have disclosed for a business purpose and sold personal information in the above noted categories under the “Sharing and Sale of Personal Information” section. Also, in the event that we, or substantially all of our assets, are acquired, such personal information may be included within the transferred assets. In the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such information in a transaction approved by the court.
We do not have any actual knowledge of the sale of personal information of minors under 16 years of age. There are no financial incentives to disclose.
G. How to Submit a Request Under the CCPA
California residents that wish to exercise any of the above data rights under the CCPA may submit a request that specifies the right(s) they wish to invoke by completing the form at https://optconsumerprivacy.com. To process your request, we may require that you submit the following information in conjunction with your request: your first name, last name, phone number, a California address, and email address. We may at times need to request additional personal information from you, taking into consideration our relationship with you and the sensitivity of your request.
The information which you provide in conjunction with your request will be used to verify your request and to attempt to identify you within our data records. The information which you submit in conjunction with your request will be used for the express purposes of verification and providing you with responsive information to your request, if required. Please note that we utilize a two-step process for requests to delete, whereby you first submit your request to delete, and second, you separately confirm that you want your personal information deleted. The CCPA permits requests to know regarding collection and sale or sharing from the same consumer no more than twice in a twelve (12) month period. In certain circumstances, we may decline a privacy rights request, particularly where you are not a resident of California, or where we are unable to verify your identity.
To opt-out of the sale of your personal information, you may submit a request by completing the form at https://optconsumerprivacy.com.
H. How an Authorized Agent Can Make a Request Under the CCPA
If you elect to use an authorized agent to exercise your right to submit a request to know, request to delete, and/or request to correct, before processing the request, we require the purported authorized agent to provide proof of your signed permission to submit the request (unless there is a power of attorney in place pursuant to Probate Code §§ 4121-4130). We also require that you directly verify your own identity with us, and directly confirm with us that you provided the authorized agent permission to submit the request on your behalf. The information submitted will not be used for any purposes other than to verify the request, fulfill the request, and fraud prevention.
I. Updates
We may revise this section from time to time as implementing regulations further develop and come into effect and we are able to provide you with better information on your CCPA rights and how to exercise them.
J. Retention of Personal Information
We retain personal information as long as is reasonably necessary to fulfill the purpose for which it was collected, as required by an applicable law, rule, regulation or contractual provision. We will retain your personal information for the purposes of commercial marketing to you until you request we cease further efforts to provide you such offers or in the event you request deletion of your personal information. To determine the appropriate duration of the retention of personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.
As such, we retain personal information for as long as you continue to use our Website and/or Services for the purposes explained in our Privacy Policy. When you discontinue the use of our Websites or Services, we will retain your personal information for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices you have made, such as to receive marketing communications. In particular, we will retain personal information provided, including complaints, claims, and any other personal information provided during the duration of your agreement with us for the services until the statutory limitation periods have expired and the necessary for the establishment, exercise, or defense of legal claims.
Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or de-identify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store the personal information and isolate it from further processing until deletion or de-identification is possible.
K. Out Preference Signal (Global Privacy Control). You may use an Opt-Out Preference Signal, such as the Global Privacy Control (“GPC”), to opt-out of the sale/sharing of your personal information. However, this technology and our use of it is not fully developed by the market. Our database containing your information may not be linked to your browser identification and because your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account or database information as the connection between your browser and our database is not known to us, we may not be able to fulfill this request. If you would like us to make the connection between your browser and your account within our database or wish to opt-out of the sale of your personal information, please email us at [email protected] or submit the requested form at https://optconsumerprivacy.com.
Colorado Residents – Your Privacy Rights
Pursuant to the Colorado Privacy Act (“CPA”), the above identified categories of personal data are collected or processed, for the above identified purposes. The categories of personal data that are shared with third parties are also noted above, as are the categories of such third parties.
We do sell personal data, as noted above, to the above identified categories of third parties, and engage in targeted advertising. To opt out of our sale of or processing of personal data and/or targeted advertising, please submit your request through the form at https://optconsumerprivacy.com. Your authorized agent may opt out on your behalf.
Also, please note that we do process sensitive data. Specifically, if you provide such information to us in connection with a webform on our Website, we collect disability status (“mental or physical health condition or diagnosis” under the CPA). By providing such information to us through our Website, you provide your consent for us to process such information. To the extent that such sensitive data is sold, it would be sold to our third party lead purchasers.
Colorado residents have the following data rights under the CPA:
- Right to opt-out: of the processing of personal data for targeted advertising, sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer;
- Right to access: may request confirmation on whether we process personal data concerning the consumer and to access the consumer’s personal data;
- Right to correction: may correct inaccuracies in the consumer’s personal data, taking into account the nature of the personal data and the purposes of the processing;
- Right to deletion: may delete personal data;
- Right to data portability: in conjunction with the right to access, a consumer may obtain the personal data in a portable and, to the extent technically feasible, readily usable format
Colorado residents that wish to exercise any of the above data rights under the CPA may submit a request that specifies the right(s) they wish to invoke by completing the form at https://optconsumerprivacy.com. We require the following information to authenticate your identity: your first and last name and a Colorado address. Authorized agents of Colorado residents may submit a request in the same manner. Please note that we must be able to authenticate, with commercially reasonable effort, the identity of the consumer and the authorized agent’s authority to act on such consumer’s behalf, by requiring the following information: the Colorado resident’s first and last name and Colorado address, and proof that such Colorado resident has authorized the agent to submit a request on their behalf.
Our contact information is below. To the extent that we decline to act upon your request, you may appeal by emailing us at [email protected]. You may contact the Attorney General if you have concerns about the result of the appeal.
Connecticut Residents – Your Privacy Rights
Pursuant to the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the above identified categories of personal data are processed, for the above identified purposes. The categories of personal data that are shared with third parties are also noted above, as are the categories of such third parties.
We do sell personal data, as noted above, to the above identified categories of third parties, and engage in targeted advertising. To opt out of our sale of or processing of personal data and/or targeted advertising, please submit your request through the form at https://optconsumerprivacy.com. Your authorized agent may opt out on your behalf.
Connecticut residents have the following rights under the CTDPA:
- Right to confirmation and access: Confirm whether or not a controller is processing the consumer’s personal data and access such data (unless confirmation or access would require the controller to reveal a trade secret);
- Right to correct: may correct inaccuracies in the consumer’s personal data;
- Right to delete: may delete personal data provided by, or obtained about, the consumer;
- Right to data portability: may obtain a copy in a portable and, to the extent technically feasible, readily usable format that allows consumer to transmit data to another controller without hindrance, where processing is carried out by automated means, provided that controller shall not be required to reveal any trade secret; and
- Right to opt-out of certain data processing: may opt-out of the processing of personal data for targeted advertising, sale of personal data, or profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning the consumer.
Connecticut residents that wish to exercise any of the above rights under the CTDPA may submit a request that specifies the right(s) they wish to invoke by completing the form at https://optconsumerprivacy.com. You are permitted to designate an authorized agent. Information provided in response to a consumer request shall be provided free of charge, once per consumer during any twelve-month period. To the extent that we decline to act upon your request, you may appeal by emailing us at [email protected]
Oregon Residents – Your Privacy Rights
The following section is effective on July 1, 2024: Pursuant to the Oregon Consumer Privacy Act (“OCPA”) (ORS 646A.570-646A.589), the above identified categories of personal data (including sensitive data, e.g., disability status) are processed, for the above identified purposes. The categories of personal data (including sensitive data, e.g., disability status) that are shared with third parties are also noted above, as are the categories of such third parties.
We do sell personal data, as noted above, and engage in targeted advertising. To opt out of our sale of personal data and targeted advertising, please submit your request through the form at https://optconsumerprivacy.com. Your authorized agent may opt out on your behalf.
Also, please note that we do process sensitive data. Specifically, if you provide such information to us in connection with a webform on our Website, we collect disability status (“mental or physical condition or diagnosis” under the OCPA). By providing such information to us through our Website, you provide your consent for us to process such sensitive data.
Oregon residents have the following rights under the OCPA:
- Right to access: may request confirmation on whether we are processing or have processed the consumer’s personal data and obtain a copy of such personal data;
- Right to correct: may correct inaccuracies in the consumer’s personal data, taking into account the nature of the personal data and the purposes of the processing;
- Right to delete: may delete personal data, including personal data the consumer provided to the controller, personal data the controller obtained from another source and derived data);
- Right to opt-out of certain data processing: may opt-out of the processing of personal data for targeted advertising, sale of personal data, or profiling the consumer in furtherance of decisions that produce legal effects or effects of similar significance
Oregon residents that wish to exercise any of the above rights under the OCPA may submit a request to myhelpbenefits.com that specifies the right(s) they wish to invoke by completing the form at https://optconsumerprivacy.com. To the extent that we decline to act upon your request, you may appeal by emailing us at [email protected].
Texas Residents – Your Privacy Rights
The following section is effective on July 1, 2024: Pursuant to the Texas Data Privacy and Security Act (Texas Bus. & Com. Code § 541.001 et seq.), the above identified categories of personal data are processed, for the above identified purposes. The categories of personal data that are shared with third parties are also noted above, as are the categories of such third parties.
We do sell personal data, as noted above, and engage in targeted advertising. To opt out of our sale of personal data and targeted advertising, please submit your request through the form at https://optconsumerprivacy.com.
NOTICE: We may sell your sensitive personal data. Specifically, if you provide such information to us in connection with a webform on our Website, we collect disability status (“mental or physical health diagnosis” under the Texas Data Privacy and Security Act). By providing such information to us through our Website, you provide your consent for us to process such information.
Texas residents have the following rights under the Texas Data Privacy and Security Act:
- Right to access: may request confirmation on whether we process the consumer’s personal data and obtain access such personal data;
- Right to correct: may correct inaccuracies in the consumer’s personal data, taking into account the nature of the personal data and the purposes of the processing of the consumer’s personal data;
- Right to delete: may delete personal data;
- Right to data portability: if the data is available in a digital format, may obtain a copy in a portable and, to the extent technically feasible, readily usable format; and
- Right to opt-out of certain data processing: may opt-out of the processing of personal data for targeted advertising, sale of personal data, or profiling.
Texas residents that wish to exercise any of the above rights under the Texas Data Privacy and Security Act may submit a request that specifies the right(s) they wish to invoke by completing the form at https://optconsumerprivacy.com, or by emailing us at [email protected]. Texas residents are permitted to designate another person to serve as their agent and act on their behalf as an authorized agent. Please note that we are not required to act on an opt-out request from an authorized agent unless we are able to verify, with commercially reasonable effort, the identity of the consumer and the authorized agent’s authority to act on the consumer’s behalf. To the extent that we decline to act upon your request, you may appeal by emailing us regarding your appeal at [email protected].
Utah Residents – Your Privacy Rights
Pursuant to the Utah Consumer Privacy Act (“UCPA”) (§ 13-61-101 et seq.), the above identified categories of personal data are processed, for the above identified purposes. The categories of personal data that are shared with third parties are also noted above, as are the categories of such third parties.
We do sell personal data, as noted above, and process personal data for targeted advertising. To opt out of our sale of personal data and/or the processing of your personal data for targeted advertising, please submit your request through the form at https://optconsumerprivacy.com.
We do process sensitive data. Specifically, if you provide such information to us in connection with a webform on our Website, we collect disability status (“information regarding an individual’s medical history, mental or physical health condition, or medical treatment or diagnosis by a health care professional” under the UCPA). By providing such information to us through our Website, you provide your consent for us to process such information. If you wish to opt out of the processing of sensitive data previously provided to us, please submit your request through the form at https://optconsumerprivacy.com.
Consumers have the following rights under the UCPA:
- Right to access: may request confirmation whether a controller is processing the consumer’s personal data; and access the consumer’s personal data;
- Right to delete: may delete the consumer’s personal data;
- Right to obtain a copy/portability: may obtain a copy of the consumer’s personal data, that the consumer previously provided to the controller, in a format that: to the extent technically feasible, is portable; to the extent practicable, is readily usable; and allows the consumer to transmit the data to another controller without impediment, where the processing is carried out by automated means
- Right to opt-out of certain data processing: may opt-out of the processing of personal data for purposes of targeted advertising, or the sale of personal data.
Utah consumers that wish to exercise any of the above rights under the UCPA may submit a request that specifies the right they wish to exercise by completing the form at https://optconsumerprivacy.com. We require the following information to authenticate your identity: your first and last name and a Utah address. Please note that We must be able to authenticate a consumer request to exercise a right under the UCPA, using commercially reasonable efforts.
Virginia Residents – Your Privacy Rights
Pursuant to the Virginia Consumer Data Protection Act (“CDPA”) (Code of Virginia § 59.1-571 et seq.), the above identified categories of personal data are processed, for the above identified purposes. The categories of personal data that are shared with third parties are also noted above, as are the categories of such third parties.
We do sell personal data, as noted above, and engage in targeted advertising. To opt out of our sale of personal data and targeted advertising, please submit your request through the form at https://optconsumerprivacy.com.
Also, please note that we do process sensitive data. Specifically, if you provide such information to us in connection with a webform on our Website, we collect disability status. By providing such information to us through our Website, you provide your consent for us to process such information.
Virginia residents have the following rights under the CDPA:
- Right to access: may request confirmation on whether we process the consumer’s personal data and obtain access such personal data;
- Right to correct: may correct inaccuracies in the consumer’s personal data;
- Right to delete: may delete personal data;
- Right to data portability: may obtain a copy in a portable and, to the extent technically feasible, readily usable format; and
- Right to opt-out of certain data processing: may opt-out of the processing of personal data for targeted advertising, sale of personal data, or profiling.
Virginia residents that wish to exercise any of the above rights under the CDPA may submit a request that specifies the right(s) they wish to invoke through the form at https://optconsumerprivacy.com. To the extent that we decline to act upon your request, you may appeal by emailing us regarding your appeal at [email protected].
Changes to Our Privacy Policy. We reserve the right to amend this Privacy Policy at our discretion and at any time. The only notice to you will be our posting of the updated Privacy Policy on the Website and update the effective date.
Updated July 8, 2024