TRANSPARENT.LY PRIVACY STATEMENT

INFORMATION WE COLLECT

We collect both personal and other information about you. Personal information (also referred to as personal data in some jurisdictions) is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with you. In contrast, non-personal information does not and cannot reveal an individual’s identity such as information that has been deidentified or aggregated.

The type and amount of personal information we collect varies based on which of our products and services you use and what you choose to share with us.

We collect the following categories of personal information:

CATEGORIES	EXAMPLES
PERSONAL IDENTIFIERS	Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, or other similar personal or device identifiers, phone number, date of birth, partial social security number, and age. We may approximate your location based on your IP address.
PERSONAL CHARACTERISTICS	Age range, marital status or sex (including gender, gender identity, gender expression), or other demographic information.
COMMERCIAL AND SERVICE RELATED INFORMATION	Services purchased, obtained, considered, or other purchasing or consuming histories or tendencies. Accident, driving, or insurance claim history, credit information such as credit score range, dwelling value, dwelling age, dwelling type, dwelling ownership history, dwelling disaster zone, dwelling mortgage amount, and other dwelling characteristics as provided by you on our websites.
INTERNET OR OTHER ELECTRONIC NETWORK ACTIVITY INFORMATION	Browsing history, search history, information regarding your interaction with our website, application or advertisement, links you use or web pages you visit while visiting our site or applications, browser type, internet service provider (ISP), cookies, device identifier or other device information, and location information.
MULTIMEDIA INFORMATION	Audio, electronic, or similar information.
EDUCATION INFORMATION	Highest level of education or degree program of interest.
INFERENCES	Inferences drawn from any personal information collected to create a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

SOURCES OF PERSONAL INFORMATION

We collect personal information and other information about you in several ways and from several sources. Personal information is collected from the following sources:

• Directly from you when you use or interact with one of our websites (“Sites”), emails, or speak with us on the phone; and
• From other parties such as our corporate affiliates, data brokers, service providers, and marketing companies.

USE OF YOUR PERSONAL INFORMATION

We use your personal for business purposes including:

• To fulfill your request or provide our services and products to you. We may use your personal information such as age and address to provide you information about different providers of insurance products, financial products, educational degree information and other services (collectively, “Business Clients”) and to connect you with these providers at your request. We may also use your personal information to complete a transaction or respond to a customer service request or other inquiry.
• Improve, develop, and analyze our Sites, services, and products. We use your personal information and other information to:
  • analyze, improve, develop, or deliver our Sites, products and services and develop new services, products or features using algorithms, analytics software, and other similar methods;
  • conduct research studies to maintain, protect and develop our networks, services, and products and protect our customers; and
  • analyze how visitors use our Sites to improve the Sites and enhance and personalize your experience.
  We collect some information used for these purposes using analytics software, cookies, and other tracking technologies. For more information about the collection and use of this information, see Online Advertising, Tracking and Opt-Outs below.
• Marketing and Targeted Advertising. We may use your personal information to serve you ads or customized content on the internet, send you promotional communications about products, services, features, and options we believe may be of interest to you. We may send communications via e-mail, regular mail or may send text messages via a mobile device. Push notification preferences are controlled in your device.
• Communicate with you. We may communicate with you to provide you transaction confirmations or other service-related messages via mail, email, phone or other available methods such as push notifications.
• Comply with legal requirements and protect the safety and security of our business, services, and Sites. We may use your personal information to comply with laws, regulations or other legal obligations, to assist in an investigation, to protect and defend our rights and property or the rights of third parties or enforce terms and conditions. We may also use your personal information to prevent suspected fraud, threats to our network or other illegal activities, prevent misuse or for any other reason permitted by law. We may use your personal information to protect our company, our affiliates, our customers, our network and our Sites.
• Update, enhance or correct our records. We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine that information with other information we have about you to update, enhance or correct our records.

SHARING YOUR INFORMATION

We may share personal information about you for business purposes or as required or permitted by law with:

• Business Clients whose services we market on our websites: We share your personal information with insurance companies, educational companies, and financial services companies to connect you with these companies so that they may offer their products or services to you.
• Service providers: Personal information may be shared with service providers who perform services on our behalf for a business purpose including providers that:
  • help complete transactions or provide you with services;
  • provide marketing and advertising, email or other communication services;
  • provide services that support our online activities including providing tracking technologies, web hosting and analytics;
  • provide tax and accounting, legal services, and data enhancement services;
  • provide technology services and enhance security, privacy and fraud protections;
  • provide analytics services or conduct research; and
  • provide support to our operations.
• Online marketing and advertising partners: We share personal information with third-party advertising and marketing partners to serve interest-based targeted advertising. We also permit third-party online and other marketing and advertising partners to collect information from you directly on our websites to facilitate online advertising. See Online Advertising, Tracking and Opt-Outs below for more details about these activities.
• Third parties in connection with a business transaction: Personal information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of any or all of our company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by an affiliate or third party, or in the event of a bankruptcy or related or similar proceedings.
• Law enforcement, regulators and other parties for legal reasons: Personal information may be disclosed to third parties, as required by law or subpoena, or if we reasonably believe such action is necessary to:
  • comply with the law and the reasonable requests of regulators, law enforcement or other public authorities;
  • protect our or others safety, rights or property; and
  • investigate fraud or to protect the security or integrity of our Sites or any product or services.

RETENTION OF PERSONAL INFORMATION

We retain personal information in accordance with applicable laws or regulatory requirements and also for as long as necessary to fulfill the purposes for which it was collected and to fulfill the business or commercial purposes that are explained in this Privacy Statement.

ONLINE ADVERTISING, TRACKING AND OPT-OUTS

Technologies and Information Collected:

• We, and our third party marketing and analytics providers, may collect information about your activity on, use of and access to our Sites using a variety of tracking technologies, including cookies, Flash objects, web beacons (also called pixel tags), embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”). Information we may collect this way may be combined with other personal information we collect directly from you. The information collected in this manner includes: The website from where you accessed our Sites, where you went to when you left our Sites, how frequently you visit our Sites, your location when you access our Sites, when and whether you open emails or click the links contained in emails, pages you visit and ads you view on our Sites, recordings of mouse clicks, mouse movements, keystrokes, and other communications you make on our Sites;
• Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, unique device identifiers or advertiser ID, and other similar information, and
• Analytics information collected by us or via third-party analytics tools, to help us measure traffic and usage trends for the Sites and to understand more about the demographics and behaviors of our users.

Use of the information: We or our service providers may use the data collected through Tracking Technologies to improve, enhance, and personalize your customer experience, to monitor and improve our Sites, and for other purposes such as:

• Remembering information so that you will not have to re-enter it during your visit or the next time you visit the Sites;
• Provide custom, personalized content and information, including targeted content and targeted advertising across multiple devices combining your information with information received from third parties;
• Measure and monitor the effectiveness and other attributes of our Sites;
• Perform analytics and detect usage patterns on our Sites;
• Diagnose or fix technology problems;
• Detect or prevent fraud or other harmful activities, and
• Otherwise to plan for and enhance our Sites.

Our service providers and advertising partners include Google, Meta, and Microsoft. To learn more about our service providers, select the links below:

• Google Privacy Policy
• Google Analytics Opt-out Browser Add-on
• Meta Privacy Policy
• Microsoft Privacy Statement

General choices regarding cookies: If you prefer not to accept cookies, most browsers will allow you to change your browser settings to disable existing cookies, automatically request cookies or to notify you when you receive a cookie. These settings are browser or device specific. Options available may vary by browser. If you disable, modify, or reject cookies, some parts or functionalities of our Site may be inaccessible or not function properly. For example, disabling cookies may require you to repeatedly enter information to take advantage of services. Also, if you clear your cookies on your browser or make selections using a different device or browser, you may need to redo your cookie settings.

Targeted Online Advertising and Opt-outs: We or our online marketing and advertising providers may use information about your activities on our Sites or other websites to help tailor our advertisements or offers to your interests. On some of our websites, we allow third-party advertising companies to collect information about your activity on our Sites through cookies or other tracking technologies and combine that information with information they collect on other unrelated sites, which the advertising companies may use to provide you with relevant, targeted advertising. This sort of online advertising is called cross-context behavioral advertising under the California Consumer Privacy Act (CCPA).

CCPA provides California residents the right to opt-out of the “sharing” of your information for cross-context behavioral advertising. You can opt-out of this sharing via the “Do Not Sell or Share My Personal Information” link in the footer of applicable websites. You may also opt-out by enabling a universal tool that automatically communicates your opt-out preferences through browser settings such as the Global Privacy Control (“GPC”). All website visitors, regardless of residency, can opt-out of this sharing.

Some browsers offer a setting called “Do Not Track.” Although we do our best to honor the privacy preferences of our visitors, we may not be able to respond to all “Do Not Track” signals from your browser.

You can also limit receiving certain targeted online advertising referred to as Interest-Based Advertising by visiting NAI Consumer Opt Out.

Opt-out choices apply only to the specific browser from which you opted out. Also, clearing cookies or browsing history will erase your opt-out selection. You may continue to see generic or non-targeted ads about our products and services if you opt-out of sharing for cross-context behavioral advertising or interest-based advertising.

Email Marketing Opt-out: If you opt out from receiving marketing emails, we may still send you transactional, non-marketing emails such as emails about your products or services, responses to your requests and inquiries, or notices of updates to terms and conditions or our privacy practices. To opt-out from receiving marketing and promotional emails, visit Contact Us.

PRIVACY RIGHTS AND CHOICES

You have specific rights under certain state privacy laws. These rights differ by state and the ways you engage with Transparent.ly.

California, Connecticut, New Hampshire, Oregon, Texas, and Virginia Residents: California residents have rights to access, correct, and delete their personal information as well as other rights described below. Similar rights exist for Connecticut, New Hampshire, Oregon, Texas, and Virginia residents.

Right to Know and Access Your Personal Information: You have the right to request the specific pieces of personal information we have collected about you and the right to know:

• the categories of personal information collected;
• the categories of sources from which personal information was collected,
• the business purpose for collecting the personal information; and
• the categories of third parties with whom we disclose or share personal information.

Right to Deletion of Personal Information: You have the right to request we delete the personal information collected about you, subject to certain exceptions including that we need the personal information to:

• Complete a transaction or provide a good or service you requested, or take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify or repair errors that impair functionality;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation; or
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right to Correct Personal Information: You have the right to request we correct any inaccurate information we have about you. We may request that you provide documentation to support your request and we will correct your information unless we determine that the personal information is more than likely accurate.

Non-Discrimination Rights: We will not discriminate against you for exercising any of the privacy rights described in this Privacy Statement.

Verified Requests: To protect you and your personal information, we will only respond to requests to know, access, delete or correct that we have been able to properly verify through our authentication processes. To verify your identity, you will be asked to provide several pieces of personal information, such as name and demographic information, which we will only use to verify your identity or authority to make the request.

Submitting a Request: To submit an access deletion, or correction request, visit online webform to submit an online request or call us at 1-866-266-9877. Responses to a verified request may take up to 45 calendar days, or longer depending on the nature of the request. If additional time is needed, we will notify you of the additional time. We may only respond to two access requests within a 12-month period. Requests from authorized agents must be submitted via the same online portal or toll-free number but to protect your privacy, consumers will be required to verify their identity directly with us via our online portal or toll-free number.

Connecticut, New Hampshire, Oregon, Texas and Virginia residents: If we are unable to fulfill your request to access, review, delete or correct your personal information, we will respond to you explaining why. If you would like to appeal for additional review of our inability to fulfill your request, visit our appeals webpage.

CHILDREN’S PRIVACY

Our Sites are not intended for children. We do not knowingly collect any personal information from children under the age of sixteen. If we become aware that we have collected personal information from a child without the required parental consent, we will make reasonable efforts to delete such data from our records.

SOCIAL MEDIA, LINKS AND EXTERNAL SITES

Links to other company’s websites may be provided on the Transparent.ly Sites as a convenience to you. If you choose to go to these external websites, you will be subject to the privacy practices of those external websites. Transparent.ly is not responsible for the privacy practices of those websites. We encourage you to be aware when you leave our Site to read the privacy policies or statements of every Website you visit, as those privacy policies or statements may differ from ours. Our Privacy Policy applies solely to the Sites where this Privacy Policy appears.

Our website includes Social Media Features such as the Facebook “Like” button, Tweet, “Share this” button, and Widgets, or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

SECURITY

The security of your personal information is important to us. We use a combination of reasonable technical, administrative, and physical safeguards to protect your personal information. However, no website, mobile application, database or system is completely secure or “hacker proof.” So, we cannot guarantee its absolute security. You are also responsible for taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.

We limit access to your personal information to those who need it to do their jobs. We comply with all applicable federal and state data security laws.

CONTACT US

If you should have questions or concerns about our privacy practices, please visit our Contact Us webpage.

CHANGES TO OUR PRIVACY POLICY

We may periodically update or revise this Privacy Statement. The date at the top of this page shows when this Privacy Statement was last revised. We will let you know when we update the Privacy Statement by changing the date or other appropriate means.