Uniters Group LLC

Privacy Notice

Updated: August 6, 2024

 

Uniters Group LLC (“we”, “us”, “our”, or “Uniters”) recognizes the importance of consumer privacy and we take this issue seriously. This Privacy Notice (“Policy”) describes our privacy practices with respect to the Personal Information collected by websites, mobile applications, and any other online interfaces that are owned or operated by Uniters, and contain a link to this Policy (collectively the “Services”). We are committed to treating your Personal Information with care and respect.

 

This Policy describes how we collect, use, and disclose Personal Information on or through the Services. This Policy does not describe our practices on sites or apps that are either not operated by Uniters, or on Uniters-opsensierated sites or apps where this policy or a link to the Policy does not appear.

 

This Policy with regard to Uniter’s mobile app, shall be subject to the Terms and Conditions contained in Apple Inc.’s App Store or Google’s Android Market.

 

If you are a United States (“U.S.”) consumer, you may have certain rights under the California Consumer Privacy Act (“CCPA”), California Privacy Rights Act (“CPRA”), Colorado Privacy Act ("CPA"), Oregon Consumer Privacy Act ("OCPA"), Virginia Consumer Data Protection Act ("VCDPA") and other privacy regulations in the U.S.

 

CONSENT

 

Pursuant to the Terms and Conditions, by using the Services, you are consenting to our collection, use, and disclosure of your information as set forth in this Privacy Notice.

 

TYPES OF INFORMATION WE COLLECT

 

Uniters and its service providers may collect certain Personal Information from you and about you, which may depend upon your interaction with us. For purposes of this Policy,

 

““Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include anonymized, aggregated, or combined information, which includes data that is related to you but is either deidentified or studied as a group and anonymized so that it does not identify you specifically. Personal information does not include publicly available information.

 

We may collect identifying information. We may collect your name, address, phone number, mobile number, fax number, and email address, among other information. An example of how this information may be collected is when you register on our site.

 

We may collect payment information. If you make a purchase with us, we may collect your payment card information, including your credit or debit card number, expiration date, billing address, and other financial account details.

 

We may collect demographic information. We may collect information like your age or gender. We may also collect your ethnicity relationship status. We may collect protected classifications under California or federal law, such as employment eligibility verification.

 

We may collect registration information. We may collect information you use to register for our Services. For example, we may collect your User ID, login name, screen name. nickname, and password. We may collect your social media account IDs.

 

We may collect audio/video data.

 

We may also collect details regarding your preferences, such as interests and nicknames.

 

We may collect professional or employment-related information about your education and prior employment, such as business name and job title.

 

We may collect browser or device information. If you use our Services, we may collect information about your browser or device, including browser/device type, UDID, and geographic location. We may also collect your Internet Protocol (“IP”) address.

 

We may collect other information. We may also collect records relating to your criminal history, court cases, and civil lawsuits.

 

We may also collect Personal Information sent in email(s) or letter(s) as provided by you or third parties.

 

HOW WE COLLECT YOUR INFORMATION

 

We and our service providers may collect your information in a variety of ways, including:

 

Voluntary Submissions - We collect Personal Information from you when you elect to voluntarily provide it to us. For example, we collect Personal Information when you register or create an account with us. The information you provide during the registration process allows us to create a unique profile for you on the Services. We also collect Personal Information when you contact us through our sites or apps. We collect Personal Information if you directly request information or assistance, inquire about the Services, or send us an e-mail. We also collect Personal Information if you connect via a Social Network API, submit a payment, or complete other online forms. For example, if you add or update information in your profile.

 

We may also provide you with the opportunity to share your reviews, thoughts, or comments regarding your relationship with us. Such testimonial information may include your personal experiences with our products or services and related Personal Information that you choose to submit through the Services, in the event you elect to do so, we will request your permission before publicly posting any Personal Information contained therein on the Services. You can also request that we remove your testimonial any time by contacting us at 1-877-336-3041, Monday - Friday, 8:30 a.m. to 5:00 p.m.

 

Please note that if you choose to provide us with Personal Information relating to other people, you represent that you have the authority from such people to do so and to permit us to use the information in accordance with this Policy. You should also be aware that any Personal Information you submit through public areas of the Services can be viewed, collected, and possibly used by others. We encourage you to 2refrain from disclosing Personal Information within such public areas of the Services that you do not wish to share.

 

Third-Party Sources - We may acquire Personal Information about you from other sources, such as, people who provide reviews about you, public databases, marketing and contracting partners, social media platforms, people with whom you have otherwise contacted on social media platforms, and other third parties.

 

Referral Information - If you elect to inform us of a referral, we will ask you to provide the name of the person.

 

Passive Collection - We use tracking tools like browser cookies and web beacons. We do this on our website and in emails that we send you. We collect information about users over time when using the website. This includes usage and browser information. We may have third parties, such as Google Analytics, to collect Personal Information this way. We automatically collect and store certain information in our server log files each time a user accesses our Services. This information may include computer or device IP address, internet browser type or service provider, referring/exit pages, operating system, date/time stamp, and clickstream data.

 

Cookies - Cookies are small pieces of data that are based on your internet activity and stored on the hard drive of your computer by your internet browser when you visit a website. Through the use of cookies, we are able to collect traffic, usage, and other similar information about your interaction with the Services, and information about your computer or device that allows us to facilitate your use of the Services.

 

Web Beacons and Other Tracking Technologies - AA web beacon is a programming code that can be used to display an image on a website, e-mail, or other communication. Web beacons are typically one-pixel, transparent images and are used to transfer an individual’s unique user identification, usually a cookie, to a database in order to associate that individual with any information previously acquired about them. They allow third-parties to obtain information such as an IP address of the computer that accesses the website on which the beacon appears, the URL of the website, the time that the website was viewed, the type of browser used to view such a website, and the information contained in any cookies set by the third-party.

 

THIRD PARTIES TRACKING

 

We have relationships with certain third parties. Uniters may share information with these companies in accordance with the terms and conditions set forth in this Policy. They may automatically collect information about your interaction with the Services through the use of tracking technologies such as cookies and web beacons. Among other things, this information is typically used to better understand how the Services are being used.

 

Please consult our Cookie Notice for more information about our use of cookies and how to accept and reject them.

 

Further, certain web browsers may provide a Do Not Track (“DNT”) option. By turning on this web browser setting, you may be able to request that a web application stop tracking your activities, either from cookies or other persistent identifiers, commonly called ”DNT signals”. However, the Services may not respond to DNT signals.

 

HOW WE USE YOUR INFORMATION

 

Uniters uses the information we collect about you in order to:

 

• Confirm and complete the transactions you request.

• Operate, monitor, manage, improve, and expand the Services and/or our business activities.

• Provide you with customer service support and other requested information or services.

• Respond to your inquiries and resolve any problems or disputes with you.

• Develop, enhance, and market our products and services or those of third parties.

• Analyze trends, administer the Services, track user activities on the Services, and gather demographic information about our user base as a whole.

• Communicate with you about your interactions with the Services, your account, this Policy, or the Terms and Conditions.

• Provide you with promotional offers, administrative materials, and/or other related content.

• Personalize your content and experiences on the Services.

• Allow you to participate in contests or promotions upon your request.

• Facilitate social sharing, messaging, or other similar functionalities on the Services.

• Protect the rights or property of Uniters or third parties.

• Protect our company, customers, and Services from security threats.

• Comply with legal or other regulatory requirements.

 

We may also use your information as otherwise permitted by law, or as we may notify you, with prior consent to use your information in such a manner. For example, we may use Personal Information in accordance with disclosures made available to you when you submit that information through the Services, or as otherwise disclosed in this Policy.

 

Analytics companies may access data (such as IP address or device ID) to help us understand how services are used. They use this data solely on our behalf. They are not permitted to share it except in aggregate form. No data is shared as to any individual user.

 

DISCLOSURE AND SHARING YOUR INFORMATION WITH THIRD PARTIES

 

We may share your personal information with third parties:

 

Authorized Disclosures - We may disclose your information to third parties when you consent. For example, if you choose to co-register with our business partners if we believe they have an offer that would be of interest to you and you have provided us with consent to do so.

 

Legally Compulsory Disclosures - We may share your Personal Information when we reasonably believe that we are compelled to do so by government authorities or otherwise needed to comply with applicable laws and regulations, such as in response to a warrant, subpoena, or court order. This includes any law enforcement agency and/or any regulatory authority.

 

Security and Fraud Investigation - Uniters may also share your Personal Information with third parties if we believe in good faith that disclosure is appropriate to protect our rights, property, or safety of third parties. We may share your information if we are investigating potential fraud.

 

Agents and Service Providers - Uniters may disclose Personal Information to our third-party agents and service providers so that they can perform requested services on our behalf. For example, we may engage third parties to assist with web hosting, data analysis, marketing efforts, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, credit card processing, auditing, legal services, and other similar services. These entities are generally prohibited from using such information for purposes unrelated to providing us with the requested services.

 

Change of Control Transactions - We may share information with any successor to all or part of our business or in connection with a similar business deal (such as a merger or acquisition, financing, sale of assets, transition of service to another provider, insolvency, receivership, or a bankruptcy transaction or proceeding). For example, if part of our business is sold, we may include personal information as part of that transaction.

 

Messaging and Social Sharing - If you choose to engage in social sharing activity, we may disclose your information to other website users and your social media account provider. By linking your social media account with our social media account, you authorize us to share information with your social media account provider and acknowledge and agree that the shared information will be governed by the applicable third party’s privacy notice/policy. You should not link your social media account with us or otherwise engage in social sharing on the Services if you would prefer that your information not be disclosed in this manner.

 

Public Submissions - Information and materials you submit to public areas of the Services, such as message boards, profile pages, blogs, and forums, will become public information that may be available to users of the Services and to the general public. We urge you to be careful when deciding to make Personal Information publicly accessible on the internet, including through the public portions of the Services. Your submissions are subject to our Terms and Conditions.

 

Non-Personal Information - We may collect, use, or share other information in any manner not otherwise prohibited by this Policy, without additional notice or compensation to you. You may be presented with additional opportunities to receive information and/or marketing materials from third parties when you interact with the Services. Please note that any information you elect to disclose to such entities will be subject to their established privacy practices, as Uniters is unable to control the privacy practices of third parties. We encourage you to always review the applicable privacy policies and terms of use maintained by third parties prior to disclosing information to them. In the event you do elect to receive promotional materials from third parties and later decide that you no longer wish to receive communications from that entity, you will need to contact the relevant third party directly to change your preferences.

 

YOUR CHOICES AND CONTROL

 

Personal Information - Individuals who are interested in Exercising their Rights such as, to access, correct, or update their Personal Information, can generally do so by submitting a request to Uniters. Upon receipt of any such request, we will take reasonable steps to validate that you are the correct owner of the information that is the subject of your request. This precaution is designed to protect users and their privacy, and may require us to contact you for confirmation purposes.

 

Mobile App - You can stop future collection of information through the mobile application by uninstalling the mobile application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

 

DATA SECURITY, INTEGRITY, AND RETENTION

 

Information collected through the Services is submitted to Uniters and/or service providers, and is hosted or stored by us (or by service providers on our behalf) in databases situated in the U.S. and/or internationally. By providing us with information through the Services, you consent to the processing of such information in any all such locations, including the U.S., which may have different data protection laws than those of your country of residence.

 

Your privacy is very important to us and we are committed to protecting your Personal Information. We use appropriate and reasonable security measures to protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration and destruction. Nonetheless, in the unlikely event that an unauthorized third party compromises our security measures, we will not be responsible for any damages directly or indirectly caused to the unauthorized users ability to view, use or disseminate such information.

 

It is your responsibility to maintain the confidentiality of your username and password on the Services. You are responsible for all uses of your password on the Services. You are responsible for all uses of your password, whether or not such use has been authorized by you. If you become aware of any unauthorized use of your account, contact Uniters at 1-877-336-3041, Monday-Friday, 8:30 a.m. - 5:00 p.m. EST.

 

We retain your information while your account is active or as needed to provide you services. Thereafter, we may retain certain Personal Information as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In the U.S., we may also retain aggregate information for research purposes and to help us develop and improve our website and services.

 

CHILDREN’S PRIVACY

 

Uniters understands the importance of protecting the privacy of children. We do not use the Services to knowingly solicit or collect data from or market to children under the age of 13 without parental consent. If you are a child under 13 years of age, please do not send any information about yourself to us through the Services. The Services are not intended for use by children.

 

In the event that we become aware that we have collected Personal Information directly from any child without parental consent, we will dispose of that information in accordance with the Children’s Online Privacy Protection Act (COPPA) and other applicable laws and regulations. Any parent or guardian who becomes aware that his or her child has provided us with information without their consent should promptly contact us toll-free at 1-877-336-3041, Monday-Friday, 8:30 a.m. - 5:00 p.m. EST and we will take reasonable steps to ensure that such information is deleted from our files.

 

THIRD-PARTY WEBSITES AND SERVICES

 

The Services and certain communications you receive from Uniters may contain links to websites and/or other online content that are owned and operated by third parties. The information practices of any such 6third-party websites or online services and not covered by this Policy. We cannot control the treatment of your information by these third parties, and their privacy practices likely differ from those described in this policy. We strongly encourage you to review the privacy practices of any such third parties prior to disclosing any Personal Information to them. If you have any questions regarding their collection, use, or disclosure of your information, you must contact the relevant third party directly.

 

ARBITRATION

 

Any civil action, claim, dispute or proceeding arising out of, or relating to, this Privacy Notice shall be referred to final and binding arbitration, before a single arbitrator, under the commercial arbitration rules of the American Arbitration Association.

 

If any part of this Privacy Notice is found to be invalid or unenforceable, such provision shall be struck and the other provisions shall remain valid and enforceable provided that doing so does not render the Privacy Notice meaningless or of no value.

 

CONTACT FOR MORE INFORMATION

 

If you have any questions or concerns about our privacy notice and practices, please contact us at:

 

Uniters North America, LLC

Attention: Privacy Team

1700 Palm Beach Lakes Boulevard, Suite 1100

West Palm Beach, FL 33401

 

You can also contact us via email at privacyteam@unitersna.com, or by calling Nancy Graham, Manager of Risk and Compliance, toll-free at 1-877-366-3041. Please note that email communications are not always secure; accordingly, we request that you do not include credit card details or other sensitive information in your emails to us.

 

POLICY UPDATES

 

We will update our Privacy Notice as needed. The date of the revision will be noted in the Privacy Notice when posted. You are advised to consult this Privacy Notice regularly for any changes, as continued use is deemed approval of all changes.

 

 

NOTICE TO CALIFORNIA, COLORADO, OREGON, AND VIRGINIA CONSUMERS - THE CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”), CALIFORNIA PRIVACY RIGHTS ACT (“CPRA”), COLORADO PRIVACY ACT ("CPA"), OREGON CONSUMER PRIVACY ACT ("OCPA"), AND THE VIRGINIA COMMONWEALTH DATA PROTECTION ACT (“VCDPA”):

 

In addition to the above, this Notice to California, Colorado, Oregon, and Virginia Consumers applies to our consumers, users, and website visitors who are California, Colorado, Oregon, or Virginia residents. The purpose of the Uniters Group LLC Privacy Notice is to provide a comprehensive description of how we collect, use, disclose, and sell/share certain Personal Information and of the rights of consumers regarding their Personal Information.

 

This Uniters Group LLC Privacy Notice does apply to our California employees or job applicants, and to information collected in a California business-to-business (“B2B”) context. This Notice does not apply to Colorado, Oregon, or Virginia employee or business-to-business (B2B) data.

 

In addition, this Uniters Group LLC California, Colorado, Oregon, and Virginia Privacy Notice does not cover Personal Information that is lawfully made available from federal, state, or local government records, as such information is excluded from the scope of the above acts.

 

Collection, Use, and Disclosure of Your Personal Information

 

Categories / Sources of Personal Information Collected and Disclosed for a Business Purpose - In the past 12 months, we have collected and disclosed to third parties for our business or commercial purposes, the following categories and sources of Personal Information, which we may continue to collect and disclose in the future:

 

Categories of Personal Information: Identifiers (contact information, cookies, etc.)

Categories of Sources from which Personal Information is Collected:

• Directly from a California, Colorado, Oregon, or Virginia resident or the individual’s representatives;

• Service Providers and other third parties;

• Website/Mobile App Activity/Social Media; and,

• Information from Client Directed Third Parties or Institutions representing a Client/Prospect.

 

Categories of Personal Information: Sensitive Personal Information (credit/debit card, etc.)

Categories of Sources from which Personal Information is Collected:

• Directly from a California, Colorado, Oregon, or Virginia resident or the individual’s representatives; and,

• Website/Mobile App Activity/Social Media.

 

Categories of Personal Information: Protected Classification Information (3rd party system)

Categories of Sources from which Personal Information is Collected:

• Directly from a California, Colorado, Oregon, or Virginia resident or the individual’s representatives;

• Service Providers and other third parties; and,

• Website/Mobile App Activity/Social Media.

 

Categories of Personal Information: Commercial Information

Categories of Sources from which Personal Information is Collected:

• Directly from a California, Colorado, Oregon, or Virginia resident or the individual’s representatives;

• Service Providers and other third parties; and,

• Website/Mobile App Activity/Social Media.

 

Categories of Personal Information: Internet or Other Electronic Network Activity Information (such as, browsing information)

Categories of Sources from which Personal Information is Collected:

• Service Providers and other third parties; and,

• Website/Mobile App Activity/Social Media.

 

Categories of Personal Information: Geolocation

Categories of Sources from which Personal Information is Collected:

• Directly from a California, Colorado, Oregon, or Virginia resident or the individual’s representatives;

• Service Providers and other third parties; and,

• Website/Mobile App Activity/Social Media.

 

Categories of Personal Information: Audio/Electronic/Visual Information

Categories of Sources from which Personal Information is Collected:

• Directly from a California, Colorado, Oregon, or Virginia resident or the individual’s representatives;

• Service Providers and other third parties; and,

• Information from Client Directed Third Parties or Institutions representing a Client/Prospect.

 

Categories of Personal Information: Professional or Employment Related Information (3rd party system)

Categories of Sources from which Personal Information is Collected:

• Directly from a California resident or the individual’s representatives;

• Service Providers and other third parties; and,

• Website/Mobile App Activity/Social Media.

 

Categories of Personal Information: Education Information

Categories of Sources from which Personal Information is Collected:

• Directly from a California resident or the individual’s representatives;

• Service Providers and other third parties; and,

• Website/Mobile App Activity/Social Media.

 

Categories of Personal Information: Biometrics - N/A

Categories of Sources from which Personal Information is Collected: N/A

 

Categories of Personal Information: Inferences for Profiling

Categories of Sources from which Personal Information is Collected: N/A

 

Purpose for Processing Personal Data - In the past 12 months, we have used Personal Information relating to California, Colorado, Oregon, or Virginia residents to operate, manager, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including the following:

 

• Verifying your identity and establishing an account.

• Processing payment for services you purchase.

• Providing services to you and providing customer support to you.

• Sending you notices, messages and alerts.

• Making limited Personal Information available for marketing purposes.

• Undertaking internal research for technological development, market research and demonstration.

• Auditing related to a current interaction and concurrent transactions.

• Complying with legal and law enforcement requirements.

 

Selling or Sharing Your Personal Information to Third Parties - In the past 12 months, we have not bought, received, sold, or shared for commercial purposes, the Personal Information of ten million or more California consumers.

 

Rights Under the CCPA, CPRA, CPA, OCPA, and VCDPA

 

The CCPA, CPRA, CPA, OCPA, and VCDPA provide certain consumers who are California, Colorado, Oregon, or Virginia residents with certain rights with regard to their Personal Information. This Section explains those rights.

 

Right to Know About and Access Your Personal Information - If you are a California, Colorado, Oregon, or Virginia resident, you may have the right to request that we provide you with information regarding what Personal Information we have collected, used, disclosed, or sold about you in the preceding 12 months. For California residents, you may only make a consumer request to know about or access your Personal Information twice within a twelve month period. Once we receive your request and verify your identity, we will disclose to you one or more of the following as requested:

 

1. The right to know, at or before the point of collection, the categories of Personal Information we have collected about you in the preceding twelve months.

2. The categories of sources from which we collected your Personal Information in the preceding twelve months.

3. The business or commercial purposes for which such information is collected or used in the preceding twelve months.

4. The categories of third parties with whom we sold or shared such information in the preceding twelve months.

5. The specific pieces of Personal Information we collected about you in the preceding twelve months.

6. The length of time we intend to retain each category of personal information.

 

Right to Correct or Rectify Inaccurate Personal Information - If you are a California, Colorado, Oregon, or Virginia resident, you may have 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 consumer's personal data.

 

Right to Delete your Personal Information - If you are a Colorado, Oregon, or Virginia resident, you may have the right to delete personal data provided by you or obtained about you, unless retention of the personal data is required by law.

If you are a California resident, you may have the right to request we delete certain Personal Information we collected from you, unless the CCPA/CPRA recognizes an exception as listed below. Once we receive your request and verify your identity, we will delete (and direct our service providers to delete) your Personal Information in our records that is not subject to any of the CCPA/CPRA exceptions. Specifically, we may deny your deletion request if your Personal Information is required for any of the following reasons, which we will identify in our response to you if we deny your request.

 

1. Complete the transaction for which we collected the Personal Information, provide the service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

4. Comply with the California Electronic Communications Privacy Act.

5. Engage in public or peer-reviewed, scientific historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

6. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.

7. Comply with a legal obligation.

8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

If you are a Virginia resident, you may have the right to delete personal data provided by you or obtained about you, unless retention of the personal data is required by law.

 

Right to Portability - If you are a California, Colorado, Oregon, or Virginia resident, you may have the right to obtain a copy of the specific pieces of personal data that you previously provided to the Controller in a portable, and, to the extent technically feasible, in a structured, commonly used, machine-readable format that may also be transmitted to another entity at the consumer’s request without hindrance, where the processing is carried out by automated means.

 

Right to Opt-out of the Sale or Sharing of Your Personal Information - If you are a California resident, you may have the right to opt-out of the sale or sharing of your Personal Information, inclusion for cross-context behavioral advertising. If you are a Virginia resident, you may have the right to opt-out of the processing of your personal data for purposes of the sale of your personal data

 

We have no actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

 

Right to Non-Discrimination - If you are a California, Colorado, Oregon, or Virginia consumer, you have a right not to receive discriminatory treatment by us for exercising your privacy rights under the CPRA CPA, OCPA, or VCDPA. Specifically except as permitted by the CPRA, CPA, OCPA, or VCDPA, we will not deny you goods or services; charge you different prices or rates, including through granting discounts or other benefits, or imposing penalties; provide you with a different level of service or quality of goods or services; or, suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

Additional Rights Under the CCPA/CPRA

 

Right to Opt-Out of the Processing of Sensitive Personal Information - If you are a California resident, you may have the right to request we limit the use and disclosure of certain Sensitive Personal Information we collected from you.

 

Right to Appeal - If you are a California resident, you may have the right to appeal. If Uniters does not take action on your Privacy Rights Request within the 45 days response period, or in the event of an extension, within the maximum 90-day response period, we will inform you in writing of the reasons for not taking action, as well as provide an explanation of any rights you have to appeal the decision.

 

Right to Opt-out of Automated Decision Making - If you are a California resident, you may have the right to opt-out of automated decision making for certain categories of Personal Information we collect about you.

 

Right to Private Right of Action - If you are a California resident, you may have the private right of action limited to certain violations only

 

Right to Know the Retention Period for each Category of Personal Information - If you are a California resident, you may have the right to know the retention period for certain categories of Personal Information we collected from you. The following applies to any and all categories of personal information we collect:

 

Division 2, Part 8, Section 12840 of the California Insurance Code, states in part that “all required records pertaining to a service contract shall be maintained by the obligor, its administrator, or the insurer underwriting the contract, for at least 3 years after the expiration of the contract.”

 

Authorized Agent - You may have the option to designate an authorized agent to submit a request on your behalf, so long as the authorized agent has your written and signed permission to do so, you have taken steps to verify your identity directly with us, and you have directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

 

In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity through information that matches our records, or if we cannot verify you have the authority to make a request on behalf of another individual, or if an exception applies. We will advise you in our response if we are not able to honor your request.

 

An authorized agent shall implement and maintain reasonable security procedures and practices to protect your information. An authorized agent shall not use your Personal Information, or any information collected from or about you, for any purposes other than to fulfill your requests, verification, or fraud prevention.

 

The above section does not apply when you have provided the authorized agent with power of attorney pursuant to California Probate Code sections 4121 to 4130.

 

Additional Rights Under the CPA, OCPA, and VCDPA

 

Right to Opt-Out of Processing for Profiling / Targeted Advertising Purposes - If you are a Colorado, Oregon, or Virginia resident, you may have the right to opt-out of processing your personal information for profiling / targeted advertising purposes.

 

Right to Opt-In for the Processing of Sensitive Personal Information -If you are a Colorado, Oregon, or Virginia resident, you may have the right to opt-in for sensitive data processing.

 

Right to Opt-out of Certain Automated Decision Making -If you are a Colorado, Oregon, or Virginia resident, you may have the right to opt-out of certain automated decision making.

 

Right to Appeal -If you are a Colorado resident, you may have the right to appeal a refusal to take action on a Privacy Rights Request within a reasonable period of time after your receipt of our decision. Within 1245 days of receipt of an appeal, Uniters will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you will be provided with a method through which you may contact the Attorney General of Colorado to submit a complaint.If you are an Oregon resident, you may have the right to appeal a refusal to take action on a Privacy Rights Request within a reasonable period of time after your receipt of our decision. Within 45 days of receipt of an appeal, Uniters will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you will be provided with a notice specifying information through which you may contact the Attorney General of Oregon to submit a complaint. If you are a Virginia resident, you may have the right to appeal a refusal to take action on a Privacy Rights Request within a reasonable period of time after your receipt of our decision. Within 60 days of receipt of an appeal, Uniters will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you will be provided with a method through which you may contact the Attorney General of Virginia to submit a complaint.

 

Exercise Your Rights

 

If you are a California, Colorado, Oregon, or Virginia consumer and would like to exercise any of those rights, please see information listed below and under the link:Exercise Your Rights.

 

 

Process Used to Verify Your Request - We cannot fulfill your request or provide you with or delete your Personal Information if we cannot locate records using the information described below, or we are unable to verify that a party making a request on your behalf is authorized to do so. Making a verifiable consumer request does not require you to register with us.

 

To verify your identity in response to a request to delete, we will ask you for identifying information. Whenever feasible, we shall match the identifying information provided by you to the Personal Information we already maintain about you. Depending on the type of request or the information requested by you, we may request additional information from you in order to verify your identity and fulfill your request. We will only use this information to confirm the identity of the consumer seeking to exercise their rights under the CCPA/CPRA, CPA, OCPA, VCDPA, security, or fraud-prevention.

 

For password protected accounts, we may verify your identity through our existing authentication practices for your account. This includes requiring you to re-authenticate yourself before disclosing or deleting your data.

 

We will respond to your request within forty-five days. However, in certain circumstances, we may require additional time to process your request, as permitted by the CCPA/CPRA, CPA, OCPA, VCDPA, or other applicable law. We will advise you within forty-five days after receiving your request if such an extension is necessary and why it is needed. Any disclosures we provide will only cover the 12-month period preceding our receipt of your verifiable consumer request. If we cannot fulfill your request, our response to you will also explain the reason why we cannot fulfill your request.

 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

For non-account holders, in regards to a request to know, we are required to verify the identity of the consumer to a reasonable degree of certainty when disclosing categories of information about the consumer. A reasonable degree of certainty includes matching at least two data points provided by the consumer with data points maintained by us that we have determined to be reliable for the purpose of verifying the consumer. In addition, we are required to verify the identity of the consumer to a reasonably high degree of certainty when disclosing specific pieces of information about the consumer. A reasonably high degree of certainty includes matching at least three pieces of Personal Information provided by the consumer with Personal Information maintained by us that it has determined to be reliable for the purpose of verifying the consumer together with a signed declaration under penalty of perjury that the requestor is the consumer whose Personal Information is the subject of the request. If this method is used for verification, we maintain all signed declarations as part of our record-keeping obligations.

 

Also, in regards to a request to know, we are required to verify the identity of the consumer to a reasonably high degree of certainty depending on the sensitivity of the Personal Information and the risk of harm to the consumer posed by unauthorized deletion.

 

If you have any questions or concerns regarding this Uniters Privacy Notice, or would like to exercise your rights under the CCPA/CPRA, CPA, OCPA, VCDPA, please contact us by using one of the following methods:

1. Making the request by completing the online request form;

2. Calling our toll-free phone number at 1-877-336-3041;

3. User-enabled global privacy controls;

4. Contacting us via email at privacyteam@unitersna.com; or,

5. Writing to us at: Attention: Privacy Team, Uniters North America, LLC, 1700 Palm Beach Lakes Boulevard, Suite 1100, West Palm Beach, FL 33401.

Please note that email communications are not always secure; accordingly, we request that you do not include credit card details or other sensitive information in your emails to us.

 

CALIFORNIA AND DELAWARE “DO NOT TRACK” DISCLOSURE

Privacy regulations in the United States, such as California and Delaware law, require us to indicate if we honor “Do Not Track” settings in our browser concerning targeted advertising. We do not monitor or respond to Do Not Track browser requests.