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Webster is committed to your privacy

At Webster, your privacy is our top priority. We respect the privacy of your information and our goal is to maintain your trust and confidence.

Our commitment

Any personal information that we collect in the course of daily business, and are required by Federal law to obtain, verify and record, is treated responsibly and kept secure. That is our commitment to you.

Privacy and Opt-Out Notice

Our Privacy and Opt-Out Notice applies to information that we collect about individuals who seek, apply for, or obtain our financial products and services for personal, family, or household purposes. It explains how we collect, use and share information, and provides instructions on how you can limit the sharing of certain information. This notice does not apply to business or commercial customers.

Download PDF

Rev. 7/23

FACTS WHAT DOES WEBSTER BANK DO WITH YOUR PERSONAL INFORMATION?
Why? Financial companies choose how they share your personal information. Federal law gives consumers the right
to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • social security number and transaction history
  • account balances and payment history
  • credit history and credit scores
How? All financial companies need to share customers’ personal information to run their everyday business. In the
section below, we list the reasons financial companies can share their customers’ personal information; the
reasons Webster Bank chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information Does Webster Bank share? Can you limit this sharing?
For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus Yes No
For our marketing purposes – to offer our products and services to you Yes No
For joint marketing with other financial companies Yes No
For our affiliates’ everyday business purposes – information about your transactions and experiences Yes No
For our affiliates’ everyday business purposes – information about your creditworthiness Yes Yes
For our affiliates to market to you Yes Yes
For nonaffiliates to market to you No We don’t share
To limit our sharing Call 800.325.2424
or visit us online at websterbank.com.

Please note:
If you are a new customer, we can begin sharing your information 30 days from the date we provide this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

Questions? Call 800.325.2424
or visit us online at websterbank.com.
Page 2
Who we are
Who is providing this notice? Webster Financial Corporation and its family of companies: Webster Bank, N.A.
What we do
How does Webster Bank protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Webster Bank collect my personal information? We collect your personal information, for example, when you

  • open an account or make deposits or withdrawals from your account
  • pay your bills or apply for a loan
  • use your credit or debit card

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing? Federal law gives you the right to limit only

  • sharing for affiliates’ everyday business purposes – information about your creditworthiness
  • affiliates from using your information to market to you
  • sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for information on your rights under state law.

What happens when I limit sharing for an account I hold jointly with someone else? Your choices will apply to you alone unless you tell us otherwise.
Definitions
Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

  • Our affiliates include financial companies that use the Webster, Sterling and Advantage names, such as Webster Wealth Advisors, Inc., Sterling Business Credit, LLC and Advantage Funding Commercial Capital Corporation. HSA Bank is a division of Webster Bank, N.A.
Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • Webster Bank does not share with nonaffiliates so they can market to you.
Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • Our joint marketing partners include credit and debit card companies, broker-dealer companies, insurance companies and brokers, and financial services companies.
Other Important Information
For Vermont Residents. We will not share information we collect about Vermont residents with companies who are not affiliates, except as permitted by law, such as with your consent or to service your accounts. We will not share information about your creditworthiness with our affiliates without your authorization or consent, but we may share information about our transactions or experiences with you with our affiliates without your consent. You are not required to contact us for these elections to apply.
For California Residents. We will not share information we collect about California residents with companies who are not affiliates, except as permitted by law, such as with your consent or to service your accounts. Among our affiliates, we will limit information sharing to the extent permitted by California law. You are not required to contact us for these elections to apply.
Digital Privacy Statement

The Digital Privacy Statement describes how we collect information when you visit or use Webster’s websites, mobile applications, and digital banking services.

Our Digital Services are not directed to children under 13. We also do not knowingly collect personal information from children under 13 through our Digital Services.

Your privacy is our concern.

Learn how Webster Bank may collect, use and share information from or about you and how information may be collected and used for advertising purposes.

Last Updated: 02/01/2022

This Digital Privacy Statement (Notice) applies to this Webster Bank online or mobile site and any Webster Bank affiliate or subsidiary online interface that links to this Notice (individually, the “Site,” and collectively, the “Sites”). The term “Webster Bank” or “we” or “us” or “our” in this Notice refers to Webster Bank, and its affiliates and subsidiaries. This Notice describes how these Sites may collect, use and share information from or about you and explains how information may be collected and used for advertising purposes.

Webster Bank provides other online interfaces not covered by this Notice. If you visit or access your accounts or apply for a position with us from one of these sites, please review the online privacy practices of that site to understand how your online information may be collected, used and shared.

For visitors to this Site, we may use and share any information that we collect on this site from or about you in accordance with the Webster Bank Privacy Policy. Please refer to this notice for additional information about our privacy practices and your rights and choices.

By using this website or our Mobile Applications (as defined below), or applying for a position with us you agree to the terms and conditions of this notice.

Collecting and Using Information

Information we collect may be one of two types: Personal Information and Other Information, including Aggregate Data and Anonymous Data (such terms being defined below).

Personal Information We Collect Online

Personal Information means personally identifiable information such as information provided primarily by you through forms, applications or other online fields including name, postal or email addresses, telephone, mobile numbers, account numbers, usernames and passwords. We may also collect social security numbers, driver’s license numbers and other personally identifiable information when you provide such information while using our online services and where we believe it is reasonably required for ordinary business, including in connection with an application for employment or other recruiting purposes.

How We Use Personal Information

We may use Personal Information in a number of ways such as:

  • To inform you about important information regarding the Site, products or services for which you apply or may be interested in applying for, or in which you are already enrolled, changes to terms, conditions, and policies and/or other administrative information;
  • To deliver marketing communications that we believe may be of interest to you, including, ads or offers tailored to you; to personalize your experience on the Site and manage your preferences;
  • To process applications for products or services and to evaluate your eligibility for such products or services;
  • To verify your identity and/or location to allow access to your accounts, conduct online transactions and to maintain measures aimed at preventing fraud and protecting the security of account and Personal Information;
  • To allow you to participate in surveys, contests, and similar promotions and to administer such promotions;
  • To administer and manage your relationship with us and to provide products and services to you;
  • To contact you through various channels, including but not limited to mail, telephone, text messaging, Site messaging and email in connection with products and services;
  • To review and process your application for employment with us and for other recruiting purposes;
  • To respond to your requests;
  • To consolidate data collected through aggregation services in order to consolidate your financial account information at one online location;
  • To perform analytics concerning your use of online services; For risk control, for fraud detection and prevention, to comply with laws and regulations, to comply with other legal process and law enforcement requirements, to allow you to utilize features within our Sites by granting us access information from your device such as contact lists or geo-location when you request certain services; and
  • Other purposes permitted by applicable law.

How Personal Information is Shared

Webster Bank shares data with third party service providers to facilitate the processing of your transactions, maintain your account(s), provide support services for your products and services that you apply for or receive from us, respond to court orders and legal investigations, or report to credit bureaus. Data is also shared with third party service providers, acting as our agents, for marketing products and services to you.

Although you may not choose to opt out of having your data shared with our vendors for joint marketing you may choose to opt out of receiving marketing information by calling 1-800-261-5482 or 1-203-272-7711.

Other Information We Collect Online

Other Information is any information other than Personal Information that does not reveal your specific identity or does not directly relate to an individual, such as browser information, information collected through cookies, pixel tags and other technologies, demographic information, other information provided by you such as your date of birth or household income, as well as Aggregated Data and Anonymous Data. Aggregated Data and Anonymous Data is data that we may create or compile from various sources, including but not limited to accounts and transactions. This information, which does not identify individuals or individual account holders, may be used for our business purposes, which may include offering products or services, research, marketing or analyzing market trends, and other purposes consistent with applicable laws.

How We Collect and Use Other Information

We and our third-party service providers may collect and use Other Information in a variety of ways, including:

  • Through your browser or device: Certain information is collected by most browsers and/or through your device, such as your IP address, device type, operating system version and internet browser type and version. We use this information to ensure Sites function properly, for fraud detection and prevention, and security purposes.
  • Using cookies: Cookies are pieces of information that we store directly on the device you are using. Cookies we use do not contain or capture unencrypted Personal Information. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, language preferences, and your relationship with us. This site uses Google Analytics and other aggregated analytics tools to track performance and to track visitor sessions, visitors across multiple sessions, and referral sources to our sites. At no time is personally identifiable information passed to Google Analytics. (To understand how Google collects and processes information gathered from this site visit www.google.com/policies/privacy/partners/). Note that Google Analytics stores its data within the United States of America and is subject to United States laws. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize/tailor your experience while engaging with us, and to recognize your device to allow your use of our online products and services. We collect statistical information about the usage of the Site in order to continually improve the design and functionality, to monitor responses to our advertisements and content, to understand how account holders and visitors use the Site and to assist us with resolving questions regarding the Site. We also utilize cookies for advertising purposes. Please see the Advertising section below for more information. You can refuse to accept these cookies and most devices and browsers offer their own privacy settings for cookies. You will need to manage your cookie settings for each device and browser you use.

We use the following types of cookies:

Functional Cookies: These cookies are used for operations of our website, including some of our new account opening applications, and are required to log-in to your digital banking account.

Performance Cookies: These cookies allow us to track how visitors are interacting with our digital experiences so that we can improve and personalize your journey.

Targeting/Marketing: These cookies are used to track the performance of marketing campaigns and to identify relevant audiences for campaigns or promotions.

How to control cookies:

You have the ability to control how cookies are placed on your computer or mobile device by changing your internet software browser settings. Disabling or deleting browser cookies may impact your experience on our website or digital banking platform. For example, disabling cookies will disable the ability to log-in to your digital banking account.

The following are a few examples of how to manage cookies on your browser:

Chrome: https://support.google.com/chrome/answer/95647

Mozilla Firefox: https://support.mozilla.org/en-US/kb/block-websites-storing-cookies-site-data-firefox

Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

However, if you do not accept these cookies, you may experience some inconvenience in your use of the Site and some online products and services. For example, we will not be able to recognize your device and you will need to answer a challenge question each time you log on. You also may not receive tailored advertising or other offers from us that may be relevant to your interests and needs.

Other technologies including pixel tags, web beacons, and clear GIFs: These may be used in connection with some Site pages, downloadable mobile applications and HTML-formatted email messages to measure the effectiveness of our communications, the success of our marketing campaigns, to compile statistics about usage and response rates, to personalize/tailor your experience while engaging with us online and offline, for fraud detection and prevention, for security purposes, for advertising, and to assist us in resolving account holders’ questions regarding use of our Site. Please see our Advertising section below for more information regarding our use of other technologies.

IP Address: Your IP Address is a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, to personalize/tailor your experience while engaging with us online and offline, for compliance and security purposes, for advertising, and administering the Site. Please see the Advertising section below for more information.

Mobile Applications: Webster Bank’s Mobile Applications for client accounts (“Mobile Applications”) allows you to access your account balances and perform certain functional transactions. This Notice applies to any Personal Information or Other Information that we may collect through the Mobile Applications. Some mobile devices come with a non-permanent advertising identifier or ID which gives companies the ability to serve targeted ads to a specific mobile device. In many cases you can turn off mobile device ad tracking or you can reset the advertising identifiers at any time within your mobile device privacy settings. In addition, if you have enabled location services on your mobile device, we may collect geolocation data from your device or contact information. You may also choose to turn off location tracking on your mobile device. By turning off ad tracking or location tracking on your mobile device, you may still see the same number of ads as before, but they may be less relevant because they may not be based on your interest.

Third party widgets – We may allow certain widgets (e.g., social share buttons) on our Sites that enable users to easily share information on another platform, such as a social media platform. The third parties that own these widgets may have access to information about your browsing on pages of our Sites where these widgets are placed. You may wish to review information at the third-party site, such as social media platforms where you have an account, to determine how these third parties collect and treat such information. Also, see Linking to other sites and Social media sites.

Online Advertising

Webster Bank advertises online (e.g., pages within our Sites and Mobile Application through bank managed social media presences, and on other sites and mobile apps not affiliated with Webster Bank) and offline (e.g. in banking centers, through call centers, and direct marketing). In order to understand how advertising performs, we may collect certain information on our Sites and other sites and mobile apps through our advertising service providers. We use cookies from third-party partners such as Google and Facebook for marketing purposes that allow us to display promotional material to you on other sites you visit across the internet. We may also share IP addresses, and other technologies. The collected information may include the number of page visits, pages viewed on our Sites, search engine referrals, browsing activities over time and across other sites following your visit to one of our Sites or apps, and responses to advertisements and promotions on the Sites and on sites and apps where we advertise.

Webster Bank may use information described in this Notice to help advertise our products and services in a variety of ways. We use such information to:

Present tailored ads to you, including to:

  • Develop banner ads and splash ads that appear as you sign on or off of your online accounts on our Sites, within mobile banking and other mobility applications;
  • Develop E-mail, postal mail, and telemarketing;
  • Advertise on other sites and mobile apps not affiliated with Webster Bank;
  • Analyze the effectiveness of our ads; and
  • Determine whether you might be interested in new products or services

How we tailor ads

Relationship based advertising

In order to help make our advertising informative and useful, we may use information about your relationship with us (such as types of accounts, transactional information or the state in which you bank) to help determine which advertisements or offers to present to you.

Online Behavioral Advertising – Interest-based Advertising

We or our advertising service providers may use certain information about your activities on our Sites and other websites, such as pages visited and search key words entered to help determine which of our advertisements or offers may be of interest to you. We limit access and collection of information for specific purposes by advertising service providers. We may use this online information for online and offline advertising.

Advertising on third party sites and mobile apps

Webster Bank contracts with advertising companies to advertise our products and services on sites and mobile apps not affiliated with us. These companies use non-personally-identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, hardware/software information, cookie and session ID) and personally identifiable information (e.g., static IP address) during your visits to this and other websites in order to provide advertisements about goods and services likely to be of greater interest to you or advertising-related services, such as ad delivery, reporting, attribution, analytics, and market research. These parties typically use a cookie, web beacon or other similar tracking technologies to collect this information. Third Party sites and mobile apps are not subject to Webster Bank Privacy Notices. Please visit the individual sites and mobile apps for additional information on their data and privacy practices and opt out policies.

Facebook (Social media)

We may participate in Facebook.com’s Custom Audience or LinkedIn’s Audience programs, which enables us to display personalized ads to persons on our email list when they visit Facebook or LinkedIn, respectively. We provide personal information, such as your email address and phone number, to the social media provider to enable it to determine if you are a registered account holder. You may opt-out of participation in this program by contacting us as noted below. You may also opt-out of receiving these ads from the social media network(s) directly.

Advertising Choices

You may set your choices for advertising in the following ways:

Online Behavioral Advertising: If you prefer that we not use information based on online Site behavior to provide online and offline tailored content and advertising, you may opt out of online behavioral advertising.

Opting out also means that the online content and advertising you receive on our non-servicing sites (i.e. before sign-in) will be untailored and may not be based on your online behavior or your relationship.

Please note that if you opt out of this advertising, you may still receive untailored advertising from Webster Bank. When accessing online account servicing areas (i.e. after sign-in), such as Online Banking, you may receive tailored content and advertising based on your account relationships. See Important Reminder section below.

You may also opt out of receiving behavioral ads from many sites through the Network Advertising Initiative’s Opt-Out Tool or other tools provided by the publishing platform. Please note that if you opt out, you may still receive untailored online advertising from Webster Bank. Opting out from a specific third-party site means that the ads you receive will not be tailored based on your choices or behavior.

Bank managed Direct Marketing: If you prefer we not deliver you marketing offers in email, postal mail or through telemarketing, you may manage your direct marketing choices by telephone at 1-800-261-5482 or 1-203-272-7711.

Important Reminder:

In order for online behavioral advertising opt outs from our Sites and on other sites to work on your device, your browser must be set to accept cookies. If you delete cookies, buy a new device, access our Site or other sites from a different device, login under a different screen name, or change web browsers, you will need to opt-out again. If your browser has scripting disabled, you do not need to opt out, as online behavioral advertising technology does not work when scripting is disabled. Please check your browser’s security settings to validate whether scripting is active or disabled.

Linking to other sites

We may provide links to third party sites, such as credit bureaus, service providers or merchants. Our Privacy Notice does not apply to third party sites. If you follow links to sites not affiliated or controlled by Webster Bank, you should review their privacy and security policies and other terms and conditions, as they may be different from those of our Sites. Webster Bank does not guarantee and is not responsible for the content, privacy or security of these sites, including the accuracy, completeness, or reliability of their information.

Social media sites

Webster Bank may provide experiences on social media platforms including, but not limited to, Facebook®, Twitter®, YouTube® and LinkedIn® that enable online sharing and collaboration among users who have registered to use them. Any content you post on official Webster Bank managed social media pages, such as pictures, information, opinions, or any Personal Information that you make available to other participants on these social platforms, is subject to the Terms of Use and Privacy Policies of those respective platforms. Please refer to them to better understand your rights and obligations regarding such content. In addition, please note that when visiting any official Webster Bank social media pages, you are also subject to any of Webster Bank’s Privacy Notices and Social Media User Terms. Whenever you visit a third-party website, you should review its privacy notice.

Aggregated Information and Digital Analytics

We collect information about your digital browsing experience through third-party analytics services for threat-monitoring and digital performance measurement. This information is not personally identifiable and is used in-aggregate to provide enhanced digital experiences. This information may include, but is not limited to the type of device being used, type of browser being used and type of operating system. We may use this aggregate and anonymous data for various business purposes, where permissible by law and regulations.

Security

To protect Personal Information from unauthorized access and use, we use security measures that comply with applicable federal and state laws. We will use reasonable organizational, physical, technical and administrative measures to protect personal information within our organization. These measures may include device safeguards and secured files and facilities security to ensure information remains confidential and secure. Webster Bank maintains customer authentication procedures to protect your personal information and accounts from identity theft.

Using other aggregation websites

Other companies offer aggregation websites and services that allow you to consolidate your financial account information from different sources (such as your accounts with us or with other financial institutions) so that you can view all your account information at one online location. To do this, an aggregation provider may request access to Personal Information, such as financial information, usernames and passwords. You should use caution and ensure that the aggregator company has appropriate policies and practices to protect the privacy and security of any information you provide or to which they are gaining access. We are not responsible for the use or disclosure of any Personal Information accessed by any company or person to whom you provide any Webster Bank Site username and password.

If you provide any Site username, password or other information about your accounts with us to an aggregation website, we will consider that you have authorized all transactions or actions initiated by an aggregation website using access information you provide whether or not you were aware of a specific transaction or action. If you decide to revoke the authority you have given to an aggregation website, we strongly recommend that you change your password for the Site to ensure that the aggregation website cannot continue to access your account.

Making sure information is accurate

Keeping your account information accurate and up to date is very important. If your account information is incomplete, inaccurate or not current, please use the Contact Us option on our Site, or call or write to us at the telephone numbers or appropriate address for changes listed on your account statements, records, online or other account materials. You can also speak to a customer representative at a banking center or account representative.

Protecting children’s privacy online

The Site is not intended for use by individuals under the age of thirteen (13). We request that these individuals do not provide Personal Information through the Site. We do not knowingly collect information from children under 13 without parental consent. Visit the Federal Trade Commission website for more information about the Children’s Online Privacy Protection Act (COPPA).

Updates to this Digital Privacy Statement

This Digital Privacy Statement is subject to change. Please review it periodically. If we make changes to this Digital Privacy Statement, we will revise the “Last Updated” date at the top of this Notice. Any changes to this Notice will become effective when we post the revised Notice on the Site. Your use of the Site following these changes means that you accept the revised Notice.

California Consumer Privacy Act Notice

At Webster, we value your privacy and are committed to the protection of personal information. In this California Consumer Privacy Act Privacy Policy, we provide information regarding the collection, use, disclosure, and other processing of information relating to California residents by Webster Financial Corporation, and its affiliates and subsidiaries, including Webster Bank, N.A. (referred to herein as “Webster,” “we,” or “us”).

Under the California Consumer Privacy Act (“CCPA”), “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident and includes certain categories of Personal Information discussed below that constitute “Sensitive Personal Information.” The CCPA, however, does not apply to certain information, such as information subject to the federal Gramm-Leach-Bliley Act.

The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual. For example, this Privacy Policy does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes. For more information about how we collect, disclose, and secure information relating to these customers, please refer to our Privacy and Opt-Out Notice located at websterbank.com/privacy/.

Our Collection, Use, Disclosure, and Sharing of Personal Information

The following chart provides information about the categories of Personal Information that we collect and use, as well as the categories of Personal Information that we disclose to third parties for our operational business purposes, including in the past 12 months preceding the date this Privacy Policy was last updated.

We do not sell Personal Information, and we do not share Personal Information for purposes of cross-context behavioral or targeted advertising, as defined under the CCPA. We have not engaged in such activities in the 12 months preceding the date this Privacy Policy was last updated. Without limiting the foregoing, we do not sell or knowingly share the Personal Information relating to minors under 16 years of age.

Categories of Personal Information Categories of Third Parties to Whom Information is Disclosed for Our Operational Business Purposes Categories of Third Parties to Whom Information is Shared for Cross-Context Behavioral Advertising
Identifiers, such as name, postal address, IP address that can reasonably be linked or associated with a particular California resident or household, email address, account name, online identifiers, and government-issued identifiers (e.g., Social Security number) affiliates; service providers; ad networks; business partners; marketing partners; credit bureaus; legal authorities; other parties in litigation none
Personal information as defined in the California customer records law, such as name, contact information, and financial information affiliates; service providers; ad networks; business partners; marketing partners; credit bureaus; legal authorities; other parties in litigation none
Protected Class Information, such as characteristics of protected classifications under California or federal law, such as sex, age, gender, race, marital status, and veteran or military status affiliates; service providers none
Commercial Information, such as transaction information and purchase history affiliates; service providers; ad networks; business partners; marketing partners; credit bureaus; legal authorities; other parties in litigation none
Internet or network activity information, such as browsing history, search history, and interactions with our online properties, applications, or ads affiliates; service providers none
Geolocation Data, such as device location affiliates; service providers none
Audio, Video, and Similar Data, such as call and video recordings affiliates; service providers none
Education Information subject to the federal Family Educational Rights and Privacy Act, such as student records and directory information affiliates; service providers none
Professional and Employment Information, such as current or past job history or performance evaluations affiliates; service providers none
Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences or characteristics. affiliates; service providers none
Sensitive Personal Information.

  • Personal Information that reveals an individual’s: (1) Social Security, driver’s license, state identification card, or passport number; (2) account log-in, financial account, credit or debit card number in combination with any required security or access code,
    password, or credentials allowing access to an account; (4) racial or ethnic origin, religious or philosophical beliefs, citizenship, immigration status, or union membership; (5) the contents of mail, email, and text messages unless we are the intended recipient of the communication;
affiliates; service providers none

We may also disclose Personal Information to a third party in the event of a reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

Purposes for Our Collection, Use, Sharing, or Other Disclosure of Personal Information

We may collect, use, share, or disclose Personal Information in order to:

  • operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives;
  • develop, improve, repair, and maintain our existing and future products and services;.
  • personalize, advertise, and market our products and services;
  • operate, maintain, and improve our website and other online services or applications;
  • conduct research, analytics, and data analysis;
  • plan and manage human resources, including, but not limited to, ensuring appropriate staffing, processing payroll, managing benefits, conducting workforce assessments, reporting and analytics, and succession planning;
  • process and evaluate job applications and recruit employees;
  • undertake quality and safety assurance measures;
  • conduct risk and security control and monitoring;
  • protect the safety of our customers, business contacts, employees and job applicants, and other individuals;
  • detect and prevent fraud and identity verification;
  • facilitate and implement any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings);
  • perform accounting, audit, and other internal functions, such as internal investigations;
  • comply with law, legal process, contracts, and internal policies;
  • maintain records; and
  • exercise and defend legal claims.

Our Use of Sensitive Personal Information

Subject to your consent where required by applicable law, we may use Sensitive Personal Information for purposes of providing goods or services as requested by you; ensuring security and integrity; short term transient use such as displaying first party, non-personalized advertising; performing services for our business, including maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, and providing storage, or providing similar services on behalf of our business.

Our Retention of Personal Information

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria that we consider in determining our retention periods include:

  • The length of time we have an ongoing relationship with you and provide services to you (e.g., for as long as you have an account with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
  • Whether there is a legal obligation to which we are subject (e.g., certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Sources of Personal Information

We collect Personal Information from you and from affiliates, third-party service providers, business partners, consumer reporting agencies, publicly available databases, social media, operating systems and platforms, internet service providers, ad networks, data analytics providers, and joint marketing partners, when they share the information with us.

Individual Requests

If you are a California resident, you may, subject to applicable law, make the following requests:

  1. You may request to know whether we process Personal Information relating to you and to access such Information.
    • You may request that we disclose to you the following information covering the 12 months preceding your request:
      1. The categories of Personal Information that we collected about you and the categories of sources from which we collected such Personal Information;
      2. The business or commercial purpose for collecting or sharing (if applicable) Personal Information relating to you;
      3. The categories of Personal Information that we shared and the categories of third parties with whom we shared such Personal Information (if applicable); and
      4. The categories of Personal Information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed, such Personal Information (if applicable).
  2. You may request to correct inaccuracies in Personal Information that we maintain about you;
  3. You may request to have Personal Information you provided to us deleted; and
  4. You may request to receive a copy of Personal Information that we maintain about you, including, where applicable, to request to obtain a copy of your Personal Information.

We will not unlawfully discriminate against you for exercising your rights under the CCPA. To make a request described above, please contact us by calling 800-966-0256 or by sending an email to [email protected]. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. In some instances, we may decline to honor your request where the law or right you are invoking does not apply or where an exception applies. We may need to request additional Personal Information from you in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.

Authorized Agents

If you would like an agent to make a request on your behalf to the extent permitted under applicable law, the agent may use the request methods listed above. Not all kinds of requests can be made by authorized agents. As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent. In addition, we may require that you verify your identity as described above or confirm that you provided the agent permission to submit the request.

De-Identified Information

Where we maintain or use de-identified data, we will continue to maintain and use the de-identified data only in a de-identified fashion and will not attempt to re-identify the data.

Changes to this Privacy Policy

We may change or update this Privacy Policy from time to time. When we do, we will post the revised Privacy Policy on this page with a new “Last Updated” date.

Contact Us

If you have any questions regarding this Privacy Policy, please contact us at [email protected].

Last Updated on 6/30/23

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