Privacy Policy

Welcome to Better U — a provider of holistic mental health solutions. This Privacy Notice explains how Better U, Inc. (“Better U”) collects, uses, discloses, and otherwise processes personal data in connection with our website https://www.betterucare.com/, the Better U app, as well as any specific product, service, or application that references or links to this Privacy Notice (the “Services”). We may also choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions, or states. Please refer to the Region-Specific Disclosures section below for additional disclosures that may be applicable to you.  

This Privacy Notice does not address our privacy practices relating to Better U job applicants, employees and other employment-related individuals, nor data that is not subject to applicable data protection laws (such as deidentified or publicly available information). This Privacy Notice is also not a contract and does not create any legal rights or obligations not otherwise provided by law. 

Our Role in Processing Personal Data

Data protection laws sometimes differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (the why and how) of processing personal data. A “processor,” which is sometimes referred to as a “service provider,” or a “business associate” under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), processes personal data on behalf of a controller subject to the controller’s instructions. 

This Privacy Notice describes our privacy practices where we are acting as the controller of personal data. However, this Privacy Notice does not cover or address how our customers may process personal data when they use our services, or how we may process personal data on their behalf in accordance with their instructions when we are acting as their processor. 

For example, we provide non-clinical administrative and operational servives to independent medical practices, including Better U Clinical, P.A., Better U Clinical CA, ZF Medical New York, P.C., Better Now Clinical N.J., PC, and affiliated professional corporations (together, the “Medical Groups”). Better U is not itself a medical practice and does not control the clinical judgment or care provided by the Medical Groups or their clinicians. The professional medical services are provided solely by the Medical Groups and their clinicians, and the non-clinical site services are provided by Better U, acting as a business associate under HIPAA. When we act in this capacity, we process your protected health information (“PHI”) in accordance with the terms of a business associate agreement with the Medical Group that is providing you with treatment, and not in accordance with this Privacy Notice.

As a result, we recommend referring to the privacy notice or notice of privacy practices of the customer/Medical Group with which you have a relationship for information on how they engage processors, like us, to process personal data and/or PHI on their behalf. 

Our Collection and Use of Personal Data

The categories of personal data we collect depend on how you interact with us and our services. For example, you may provide us your personal data directly when you contact us to make inquiries about our Services. 

We also collect personal data automatically when you interact with our websites and other services and may also collect personal data from other sources and third parties. 

Personal Data Provided by Individuals

We collect the following categories of personal data individuals provide us: 

• Contact Information, including first and last name, phone number, email address, and communication preferences. We use this information primarily to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.

• Customer Content, including any files, documents, or communications you choose to input, upload, or transmit to us via our Services, such as our online chat feature. We use this content primarily to provide you with our Services, to facilitate your requests, and to improve our products and services.
• Feedback and Support Information, including the contents of custom messages sent through the forms, chat platforms, email addresses, or other contact information we make available to customers, as well as recordings of calls with us, where permitted by law (including through the use of automated tools provided by us or our third-party providers). We use this information primarily to investigate and respond to your inquiries, to communicate with you, and to improve our Services.

If you choose to contact us, we may need additional information to fulfill the request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the request we receive or personal data we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time. 

Personal Data Automatically Collected

We, and our third-party partners, automatically collect information you provide to us and information about how you access and use our Services when you engage with us. We typically collect this information through the use of a variety of our own and our third-party partners’ automatic data collection technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources. 

We, and our third-party partners, use automatic data collection technologies to automatically collect the following data when you use our services or otherwise engage with us: 

• Information About Your Device and Network, including the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). We employ third-party technologies designed to allow us to recognize when two or more devices are likely being used by the same individual and may leverage these technologies (where permitted) to link information collected from different devices.
• Information About the Way Individuals Use Our Services and Interact With Us, including the site from which you came, the site to which you are going when you leave our services, how frequently you access our Services, whether you open emails or click the links contained in emails, whether you access our Services from multiple devices, and other browsing behavior and actions you take on our services (such as the pages you visit, the content you view, videos you watch, the communications you have through our services, and the content, links and ads you interact with). We employ third-party technologies designed to allow us to collect detailed information about browsing behavior and actions that you take on our Services, which may record your mouse movements, scrolling, clicks, and keystroke activity on our Services and other browsing, search or purchasing behavior. These third-party technologies may also record information you enter when you interact with our Services, or engage in chat features or other communication platforms we provide.
• Information About Your Location, including general geographic location that we or our third-party providers may derive from your IP address.

All of the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Services, to offer communications features such as live and automated chat, and to improve the effectiveness of our products, services, offers, advertising, communications and customer service.  We may also use this information to:  (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our services. Monitoring and recording of interactions. To enhance your experience, support clinical quality, and maintain the security of our services, we may log, monitor, and record your interactions with Better U. This includes activity on our websites and mobile applications, form submissions, chat and messaging tools, and communications with our care team, such as phone and video calls. We may work with carefully selected service providers to support these functions, and they are contractually required to protect your information and use it only as permitted by this Privacy Policy and applicable law. By using our services, you consent to this monitoring and recording as described in this Privacy Policy.

For information about the choices you may have in relation to our use of automatic data collection technologies, please refer to the Your Privacy Choices section below. 

Personal Data from Other Sources and Third Parties

We may receive the same categories of personal data as described above from the following sources and other parties: 

• Our Affiliates: We are able to offer you our Services we make available because of the hard work of our team members across all Better U entities. To provide our Services, Better U entities receive personal data from other Better U entities for purposes and uses that are consistent with this Privacy Notice. 
• Single Sign-On: We may provide you the ability to log in to our Services through certain third-party accounts you maintain. When you use these single sign-on protocols to access our Services, we do not receive your login credentials for the relevant third-party service. Instead, we receive tokens from the single sign-on protocol to help identify you in our system (such as by your username) and confirm you successfully authenticated through the single sign-on protocol. This information allows us to more easily provide you access to our Services.
• Mobile Sign-On: We may provide you the ability to log in to our mobile applications or authenticate yourself using facial, fingerprint, or other biometric recognition technology available through your mobile device. If you choose to utilize these login features, information about your facial geometry, your fingerprint, or other biometric information will be collected by your mobile device for authentication purposes. We do not store or have access to this biometric information. Instead, your mobile device will perform the biometric authentication process and only let us know whether the authentication was successful. If the authentication was successful, you will be able to access the applicable mobile application or feature without separately providing your credentials. For more details, please refer to the biometric authentication guides offered by your device provider.
• Other Customers: We may receive your personal data from our other customers. For example, a customer may provide us with your contact information as a part of a referral.
• Social Media: When you interact with us through social media networks, such as when you follow us or share our content on social networks, we may receive some information that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network, and may include profile information, profile picture, username, and any other information you permit the social network to share with third parties. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information primarily to communicate directly with you, such as to send you messages about features that may be of interest to you.
• Advertisers, Influencers, and Publishers: We engage in advertising both on our services and through third-party services. Advertisers, influencers, and publishers may share personal data with us in connection with our advertising efforts. For example, we may obtain information about whether an advertisement on our services led to a successful engagement between you and a third-party advertiser.
• Service Providers: Our service providers that perform services on our behalf, such as analytics and certain marketing providers, collect personal data and often share some or all of this information with us. For example, we receive personal data you may submit in response to requests for feedback to our survey providers.
• Other Sources: We may also collect personal data about you from other sources, including publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.
• Inferences: We may generate inferences or predictions about you and your interests and preferences based on the other personal data we collect and the interactions we have with you.

Additional Uses of Personal Data

In addition to the primary purposes for using personal data described above, we may also use personal data we collect to:

• Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations or to deliver our Services;
• Manage our organization and its day-to-day operations; 
• Communicate with you, including via email, text message, chat, social media and/or telephone calls;
• Facilitate the relationship we have with you and, where applicable, the company you represent; 
• Request you provide us feedback about our product and service offerings; 
• Address inquiries or complaints made by or about an individual in connection with our Services; 
• Create and maintain accounts for our users;
• Verify your identity and entitlement to our Services;
• Market our products and services to you, including through email, phone, text message, push notification, and social media;
• Administer, improve, and personalize our Services, including by recognizing you and remembering your information when you return to our Services;
• Develop, operate, improve, maintain, protect, and provide the features and functionality of our Services; 
• Identify and analyze how you use our Services;
• Infer additional information about you from your use of our Services, such as your interests. 
• Create aggregated or de-identified information that cannot reasonably be used to identify you, which information we may use for purposes outside the scope of this Privacy Notice; 
• Conduct research and analytics on our user base and our products and services, including to better understand the demographics of our users;  
• Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
• Test, enhance, update, and monitor the Services, or diagnose or fix technology problems; 
• Help maintain and enhance the safety, security, and integrity of our property, Services, technology, assets, and business;
• Defend, protect, or enforce our rights or applicable contracts and agreements (including our Terms of Use), as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Better U and others; 

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• Facilitate business transactions and reorganizations impacting the structure of our business; 
• Comply with contractual and legal obligations and requirements; and
• Fulfill any other purpose for which you provide your personal data, or for which you have otherwise consented.

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Our Disclosure of Personal Data

We disclose or otherwise make available personal data in the following ways: 

• To Our Affiliates: We are able to offer you the products and services we make available because of the hard work of our team members across Better U entities. To provide our Services, Better U entities disclose personal data to other Better U entities for purposes and uses that are consistent with this Privacy Notice. 
• To Other Customers and the General Public: We may share content designed for sharing, such as content you post on social media, with certain or all other Better U customers, or the general public, based on the applicable privacy settings and intended recipients. Keep in mind that the customers who view customer-generated content can always reshare or redistribute the content both on and off our Services or save or copy the content outside of our Services. In addition, by publicly posting content on our Services or social media pages, you are directing us to disclose that information as broadly as possible and directing those accessing the content to do the same.
• To Marketing Providers: We coordinate and share personal data with our marketing providers in order to advertise and communicate with you about the Services we make available.
• To Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information automatically from your browser or device when you visit our Services through the use of cookies and related technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
• To Service Providers: We engage other third parties to perform certain services on our behalf in connection with the uses of personal data described in the sections above. Depending on the applicable services, these service providers may process personal data on our behalf or have access to personal data while performing services on our behalf.
• To Other Businesses as Needed to Provide Services: We may share personal data with third parties you engage with through our Services or as needed to fulfill a request or transaction. 
• In Connection with a Business Transaction or Reorganization: We may take part in or be involved with a business transaction or reorganization, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose, transfer, or assign personal data to a third party during negotiation of, in connection with, or as an asset in such a business transaction or reorganization. Also, in the unlikely event of our bankruptcy, receivership, or insolvency, your personal data may be disclosed, transferred, or assigned to third parties in connection with the proceedings or disposition of our assets.
• To Facilitate Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement: 
  
  • in connection with the establishment, exercise, or defense of legal claims; 
  • to comply with laws or to respond to lawful requests and legal process; 
  • to protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
  • to detect, suppress, or prevent fraud; 
  • to reduce credit risk and collect debts owed to us; 
  • to protect the health and safety of us, our customers, or any person; or 
  • as otherwise required by applicable law.
• With Your Consent or Direction: We may disclose your personal data to certain other third parties or publicly with your consent or direction. For example, with your permission, we may post your testimonial on our websites. 

Your Privacy Choices

The following privacy choices are made available to all individuals with whom we interact. You may also have additional choices regarding your personal data depending on your location or residency. Please refer to our Region-Specific Disclosures below for information about additional privacy choices that may be available to you. 

Communication Preferences

• Email Communication Preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in any of our email communications. Please note you cannot opt-out of service-related email communications (such as, account verification, transaction confirmation, or service update emails). 
• Phone Communication Preferences: You can stop receiving promotional phone communications from us by informing the caller you no longer wish to receive promotional phone calls from us, following the instructions provided on the call for opting out of promotional phone calls (where available), or replying STOP to any one of our promotional text messages. Please note we may need to continue to communicate with you via phone for certain service-related messages (such as, sending a verification code to your phone via call or text for purposes of verifying the authenticity of a log-in attempt). 
• Push Notification Preferences: You can stop receiving push notifications from us by changing your preferences in your device’s notification settings menu or in the applicable service-specific application. Please note we do not have any control over your device’s notifications settings and are not responsible if they do not function as intended. 
• Direct Mailing Preferences: You can stop receiving promotional direct mail communications from us by contacting us at [email protected]. Please note this opt-out does not affect any mailings that are controlled by third parties that may feature or mention our services.

Withdrawing Your Consent

Where we have your consent for the processing of your personal data (e.g., when you opt in to receive certain types of marketing communications from us), you may withdraw your consent by following the instructions provided when your consent was requested or by contacting us as set forth in the Contact Us section below. 

Automatic Data Collection Preferences

Certain of our Services may provide you the ability to adjust your preferences regarding our use of automatic data collection technologies. For example, there is a “Cookie Preferences” manager inside of the cookie consent banner that allows you to adjust your preferences regarding certain automatic data collection technologies on the specific website you are visiting for the specific device and browser you are using at that time (which means you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting).

Where a Better U-specific preference manager or privacy setting is not available, you may be able to utilize third-party tools and features to further restrict our use of automatic data collection technologies. For example, (i) most browsers allow you to change browser settings to limit automatic data collection technologies on websites, (ii) most email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies, and (iii) many devices allow you to change your device settings to limit automatic data collection technologies for device applications. Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using our services, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.  

Targeted Advertising Preferences

We engage third parties to help us facilitate targeted advertising designed to show you personalized ads based on predictions of your preferences and interests developed using personal data we maintain and personal data our third-party partners obtain from your activity over time and across nonaffiliated websites and other services. The data we and our third-party partners use for purposes of facilitating targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research, are primarily collected through the use of a variety of automatic data collection technologies, including cookies, web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help link the personal data we and our third-party partners collect to the same person, or otherwise target advertising to an individual on a third-party website or platform. 

In addition to taking the steps set forth in the Automatic Data Collection Preferences section above, you may be able to further exercise control over the advertisements that you see by leveraging one or more targeted advertising opt-out programs. For example:

• Device-Specific Opt-Out Programs: Certain devices provide individuals the option to turn off targeted advertising for the entire device (such as Apple devices through their App Tracking Transparency framework or Android devices through their opt out of ads personalization feature). Please refer to your device manufacturer’s user guides for additional information about implementing any available device-specific targeted advertising opt-outs. 
• Digital Advertising Alliance: The Digital Advertising Alliance allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://optout.aboutads.info/?c=2&lang=EN for browser-based advertising and https://www.youradchoices.com/appchoices for app-based advertising to opt out of targeted advertising carried out by our third-party partners and other third parties that participate in the Digital Advertising Alliance’s self-regulatory program. 
• Network Advertising Initiative: The Network Advertising Initiative similarly allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://optout.networkadvertising.org/?c=1 to opt out of browser-based targeted advertising carried out by our third-party partners and other third parties that participate in the Network Advertising Initiative’s self-regulatory program. 
• Platform-Specific Opt-Out Programs: Certain third-party platforms provide individuals the option to turn off targeted advertising for the entire platform (such as certain social media platforms). Please refer to your platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs. 

Please note that when you opt out of receiving interest-based advertisements through one of these programs, this does not mean you will no longer see advertisements from us or on our services.  Instead, it means that the online ads you do see from relevant program participants should not be based on your interests.  We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, program participants may still use automatic data collection technologies to collect information about your use of our services, including for analytics and fraud prevention as well as any other purpose permitted under the applicable advertising industry program.

Modifying or Deleting Your Personal Data

If you have any questions about reviewing, modifying, or deleting your personal data, you can contact us directly at [email protected]. We may not be able to modify or delete your personal data in all circumstances. 

Partner-Specific Preferences

Certain of our third-party providers and partners offer additional ways that you may exercise control over your personal data, or automatically impose limitations on the way we can use personal data in connection with the services they provide: 

• Device-Specific / Platform-Specific Preferences: The device and/or platform you use to interact with us (such as you mobile device or social media provider), may provide you additional choices with regard to the data you choose to share with us. For example, many mobile devices allow you to change your device permissions to prevent our products and services from accessing certain types of information from your device (such as your contact lists or precise geolocation data), and many social media platforms allow you to change your platform permissions to prevent integrated products and services from accessing certain types of information connected with your profile. Please refer to your device or platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs. 
• Google Analytics: Google Analytics allows us to better understand how our customers interact with our services.  For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website here: www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Add-On here: https://tools.google.com/dlpage/gaoptout/. We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our services.  You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://myadcenter.google.com/?ref=help-center.

Children’s Personal Data

Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 18. If an individual is under the age of 18, they should not use our services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 18 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 18, we will promptly delete that personal data.

Security of Personal Data

We have implemented reasonable physical, technical, and organizational safeguards that are designed to protect your personal data. However, despite these controls, we cannot completely ensure or warrant the security of your personal data. 

Retention of Personal Data

We will usually retain the personal data we collect about you for no longer than reasonably necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal data for longer periods of time as required under applicable law or as needed to resolve disputes or protect our legal rights. 

To determine the appropriate duration of the retention of personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal data is no longer reasonably necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if that is not possible (for example, because personal data has been stored in backup archives), we will securely store the personal data and isolate it from further active processing until deletion or deidentification is possible. 

Third-Party Websites and Services

Our services may include links to third-party websites, plug-ins, applications and other services. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to any personal data practices of third parties. To learn about the personal data practices of third parties, please visit their respective privacy notices. 

Region-Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

• United States: If you are a resident of the United States, please click see below for additional U.S.-specific privacy disclosures, including a description of the personal data rights made available to residents of certain states under applicable law.

Updates to This Privacy Notice

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on this website or our other platforms, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to [email protected].

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ADDITIONAL UNITED STATES PRIVACY DISCLOSURES

These disclosures supplement the information contained in our Privacy Notice by providing additional information about the privacy rights available to individual residents of certain states in the United States and our personal data processing practices relating to those individuals. For a detailed description of how we collect, use, disclose, and otherwise process personal data, please read our Privacy Notice.

Nevada Residents

If you are a resident of the state of Nevada in the United States, you have the right to opt out of the sale of your personal data. Although we do not currently sell personal data of Nevada residents (as defined under Nevada law), you may submit a request to opt-out of the sale of your personal data by emailing us at [email protected].

California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Jersey, New Hampshire, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia Residents

If you are a resident of the state of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Jersey, New Hampshire, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia in the United States the following supplementary disclosures apply to you.

Personal Data Disclosures, Sales and Targeted Advertising

We disclose all of the categories of personal data we collect to the categories of recipients set forth in the Our Disclosure of Personal Data section of our Privacy Notice. Our disclosure of personal data to the following categories of third parties qualifies as the sale of personal data or the sharing or processing of personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”) under certain privacy laws: 

• To Ad Networks and Advertising Partners

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal data or the processing of personal data for purposes of targeted advertising (as described in the Your Additional U.S. Privacy Choices section below).

Please note we do not sell the personal data of individuals we know to be less than 16 years of age or share such information for targeted advertising purposes.

Sensitive Personal Data

We do not request or encourage you to provide any sensitive personal data to us. In circumstances where you choose to disclose such information, for example in a free-text communication to us, we will only use or disclose that sensitive personal data where reasonably necessary and proportionate for the purposes of providing products and performing services you have requested, verifying and improving the products and services we provide, detecting security incidents, fraud, and other illegal actions, ensuring the physical safety of natural persons, performing services on behalf of the business, or short-term transient use. We only collect and process sensitive personal data without the purpose of inferring characteristics about the relevant individual, and we do not sell sensitive personal data or process or otherwise share sensitive personal data for the purpose of targeted advertising.

Deidentified Information

We may at times receive, or process personal data to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law. 

Automated Decision-Making and Profiling

We do not conduct automated processing of personal data for the purposes of evaluating, analyzing, or predicting an individual’s personal aspects in furtherance of decisions that produce legal or similarly significant effects. As a result, we do not provide a right to exercise control over such forms of automated decision-making and profiling. 

Your Additional U.S. Privacy Choices

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights: 

• Right to Know: The right to confirm whether we are processing personal data about you and, for residents of California, Minnesota and Oregon only, to obtain certain personalized details about the personal data we have collected about you, including: 
  
  • The categories of personal data collected;
  • The categories of sources of the personal data;
  • The purposes for which the personal data were collected;
  • The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom this personal data were disclosed;
  • The categories of personal data shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for these purposes;
  • The categories of personal data sold (if any) and the categories of third parties to whom the personal data were sold; and 
  • For Minnesota and Oregon residents only, a list of specific third parties to whom personal data have been disclosed.
• Right to Access & Portability: The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
• Right to Correction: The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data. 
• Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share personal data for certain targeted advertising purposes.
• Right to Opt-Out of Sales: The right to direct us not to sell personal data to third parties, including the right to opt-out of the disclosure of personal data to third parties for the third parties’ direct marketing purposes under California’s “Shine the Light” Law.
• Right to Deletion: The right to have us delete personal data we maintain about you. 

Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

Submitting Privacy Rights Requests

Please submit a request specifying the right you wish to exercise by: 

• Emailing us at [email protected];

To exercise your right to opt-out as it relates to the use of cookies and related technologies that involve the sale of personal data or the use of personal data for targeted advertising purposes, please click the “Cookie Settings” in the cookies consent banner adjust your preferences accordingly. If you are visiting our site with the Global Privacy Control enabled, any cookies that constitute sales or are used for targeted advertising should already be turned off automatically in our cookie preference manager. Please note this opt-out tool is website, device, and browser specific, so you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting. In addition, you can follow the other steps set forth in the Automatic Data Collection Preferences and Targeted Advertising Preferences sections of the Your Privacy Choices section of our Privacy Statement to further exercise control over automatic data collection technologies.

Before processing your request to exercise certain rights (including the Right to Know, Access & Portability, Correction, and Deletion), we will need to verify your identity and confirm you are a resident of a state that offers the requested right(s). In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests submitted through our online form and toll-free number to include first and last name, email address, phone number, state of residency and/or the date of your last transaction with us.

In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible states. 

Submitting Authorized Agent Requests

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request. 

Appealing Privacy Rights Decisions

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by replying to the communication resolving your original request. 

Additional California-Specific Disclosures

The following disclosures only apply to residents of the State of California. 

California Categories of Personal Data

California law requires we provide disclosures to you about what personal data we collect by reference to the enumerated categories of personal data set forth within California law. To address this obligation, we have identified the relevant enumerated California personal data category for the personal data described in the Our Collection and Use of Personal Data section of our Privacy Notice below:

• Identifiers, such as name, unique personal identifier, online identifier, Internet Protocol address, phone number, email address. 
• Customer records, such as name, telephone number, email address. 
• Commercial information, such as records of services purchased, obtained, or considered. 
• Internet / network information, such as browsing history, search history, and information regarding your interaction with an internet website application, or advertisement. 
• Geolocation data, as derived from your IP address. 
• Inferences, such as information we derive from the personal data we have collected from which we can infer your preferences. 

California’s “Shine the Light” Law

California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. It is company policy that we do not disclose personal information to third parties for their direct marketing purposes if a consumer has exercised their right to opt out.  To opt out of having your personal information disclosed to third parties for their direct marketing purposes, please follow the instructions for opting out of targeted advertising and personal data sales (above).