The following information will help you understand how we collect, use, share and safeguard your Personal Information. It also describes your choices regarding use, access, and correction of your Personal Information.
This Policy applies to information we collect:
Collectively, we refer to the bullets outlined above as the “Services.” By accessing our Services, you agree to this Policy. This Policy may change from time to time. Your continued use of Services after we make changes is deemed to be acceptance of those changes, so please check this Policy regularly for updates.
If you are a resident of those states with specific state privacy laws, please review the Additional Information Regarding Your State Privacy Rights below.
The nature of the Services is not intended for individuals under the age of 16. If we learn we have collected or received Personal Information from someone under age 16 without parental consent, we will delete that information. If you believe we might have any information from or about a child under age 16, please contact us at firstname.lastname@example.org
“Personal Information” is information that relates to an identified or identifiable person, whether alone or in combination with other information.
We collect the following types of Personal Information:
We may collect Personal Information from a variety of sources, including, sometimes automatically:
We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy.
For information on how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking, please see our Cookies Policy.
We collect or disclose Personal information for these legitimate business or commercial purposes:
We may aggregate and/or anonymize Personal Information so it is no longer considered Personal Information. We do this to generate data for our use, which we may use and disclose for any purpose.
We collect the Personal Information and use it for legitimate business purposes as detailed in the following table:
|Purpose of collection|
|Identifiers||Performing Services; Auditing; Short-term Use; Data Security & Fraud Prevention; Research and Development; Quality and Safety; M&A;Commercial Interests; Legal Interests|
|Commercial Data||Performing Services; Short-term Use; Commercial Interests; Legal Interests|
|Financial Data||Performing Services; M&A; Legal Interests|
|Internet Data||Performing Services; Auditing; Short-term Use; Data Security & Fraud Prevention; Research and Development; Quality and Safety; M&A;Commercial Interests; Legal Interests|
|Geolocation Data||Performing Services; M&A; Legal Interests|
|Inference Data||Performing Services; Commercial Interests; Short-term Use; M&A; Legal Interests|
|Protected Data||Performing Services; Commercial Interests; Short-term Use; M&A; Legal Interests|
|Profile Data||Performing Services; Commercial Interests; Short-term Use; M&A; Legal Interests|
|Associated Data||Performing Services; Commercial Interests; Short-term Use; M&A; Legal Interests|
|Performing Services; M&A; Legal Interests|
The table below explains the categories of information that we may share with third parties and the categories of those parties:
|Third Parties with whom we share information and why||Categories of information shared|
|Our Subsidiaries and Affiliated Businesses. We may share information we collect within our family of companies to deliver Services to you, and enhance our products, services, and your customer experience, consistent with this Policy.Those businesses may also use your information for their own purposes, including marketing purposes.||
|Third Parties Aiding in our Provision of Services. We may share information we collect with third party vendors, service providers, and consultants that provide products or services as part of our Services to you. These third parties may only use your information as directed by us.||
|Third Parties for Marketing Purposes. We may share your information with partners whose offerings we think may interest you.||
|Third Parties for Legal Requirements and Proceedings. We may disclose information to law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal process or other law enforcement or government measures, and to comply with other legal obligations. We may disclose information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraudulent or illegal activity.||
|Third Parties for the Protection of our Websites, Services and Users. We may disclose information to protect and defend the rights, interests, and safety of the Websites and, our subsidiaries and affiliates, and their employees, contractors, and agents; to protect the security and safety of our users of the Websites or any product or service, including when we believe disclosure is necessary to prevent physical harm or financial loss.||
|Third Parties in Business Transfers. We may disclose information in connection with a proposed or completed corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets.||
|Third-Party Online Advertisers and Ad Networks. We may use or rely on third-party advertising technologies that allow for the delivery of relevant content and advertising on the Websites, as well as on other websites you visit and other applications you use, and these technologies will collect certain information from your use of the Websites to assist in delivering such ads.||
|Internet Services Providers. In connection with the provision of the Websites, we may share information with companies that provide internet services.||
|Data Analytics Providers. We may share information with companies that provide data analytics services in order to operate, evaluate and improve our business.||
|Operating Systems and Platforms. We may share information with software companies that power your devices and companies that provide common tools or information for software or apps about software or app consumers.||
|List Rental or Data Broker Services. Where permitted by law, we may share or sell information with list rental or data broker services for such list rental or data broker services’ marketing or commercial purposes.||
We have implemented reasonable measures to secure Personal Information from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. Unfortunately, no transmission or storage system can be guaranteed 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us at email@example.com
You have choices regarding marketing-related communications. If you no longer want to receive marketing-related emails, you may opt out by following the unsubscribe instructions in any of our marketing emails or by contacting us at firstname.lastname@example.org. Note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative and account messages, from which you cannot opt out.
If you would like to request to review, correct, update, suppress/delete, or object to or restrict processing of your Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company, please email email@example.com or call 877-861-8985 to leave a voicemail. We will respond to your request consistent with applicable law. If you are a California resident, please refer to the Additional Information Regarding Your State Privacy Rights below for more information about the requests you may make under the CCPA.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note, however, that certain Personal Information may be exempt from requests pursuant to applicable data protection laws or other laws and regulations, such as for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
We retain personal information as long as necessary according to our enterprise records retention schedule. Retention period calculations are based upon the time the Personal Information is needed to satisfy the purposes described in this Policy, to comply with applicable laws, legal holds, and other legal obligations (including contractual obligations), operational requirements, and to fulfill your requests.
The Websites, Apps, and Services may contain links to unaffiliated third parties. This Policy does not apply to such third party sites. When you click a link to visit a third party website, you will be subject to that website’s privacy practices. We encourage you to review the privacy and security practices of any linked third party website before providing any Personal Information on that website.
The inclusion of a link on this site or Services does not imply endorsement of the linked site by us or by our affiliates or subsidiaries.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with Apps or our social media.
Webinars offered as a service to users of the Services (“Webinars”) are hosted by unaffiliated third party vendors, and not by us.
Our third party vendors require users to provide Personal Information to register for or attend Webinars. This Personal Information includes name and email address. Users seeking continuing education credit also may be asked to provide the appropriate identification number(s). Please note that this Personal Information is collected by our vendors and not by us. We encourage you to read the privacy statements of our vendors, which control how such vendors handle Personal Information provided by you to register for the Webinars.
Additionally, our third party vendors provide us with Personal Information about users of our Webinars. We use this Personal Information to track attendance, to facilitate future communication with such users, and for other purposes set forth in this Policy.
Your Personal Information may be stored and processed in any country where we conduct business or in which we engage service providers to support our operations. We may transfer Personal Information to jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of protection as your country of residence. By using our Services, you understand that your information will be transferred to the United States or to other countries in which we or our affiliates or subsidiaries may exist.
If you do not want us to sell or share your Personal Information with affiliated, unaffiliated, or non-agent third parties for promotional or targeted advertising purposes, you can opt-out by emailing firstname.lastname@example.org. Please include your name, email address and/or mailing address, as well as a daytime telephone number.
To ask questions about this Policy and our privacy practices, contact us at:
Privacy Program Office
801 South Marquette Ave.
Minneapolis, MN 55402
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
Certain states, including California, Colorado, Connecticut, Utah, and Virginia, require that we provide additional information regarding our privacy practices and your privacy rights. If you are a resident of those states, we provide you additional notices about our privacy practices and consumer rights relating to your information. This Policy does not apply to our employees, contractors, owners, directors, or officers where the Personal Information relates to their current, former, or potential role. Job applicants can review our Privacy Notice for Job Applicants for more information about the Personal Information we collect when you apply for a position with us.
In addition to the above-listed Personal Information categories, we have collected the following in the last 12 months:
|Personal Information Category||Business Purpose||
Categories of Recipients with
Whom We Shared/Sold/Disclosed
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (Real name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver' license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information)||Performing Services; Auditing; Short-term Use; Data Security & Fraud Prevention; Research and Development; Quality and Safety; M&A;Commercial Interests; Legal Interests||Our Subsidiaries and Affiliated Businesses; Third Parties Aiding in our Provision of Services;Third Parties for Marketing Purposes; Third Parties for Legal Requirements and Proceedings; Third Parties for the Protection of our Services; Third Parties in Business Transfers; Third Party Online Advertisers and Ad Networks; Internet Services Providers;Data Analytics Providers;Operating Systems and Platforms;List Rental or Data Broker Services|
|Protected classification characteristics under state or federal law , such as age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, physical or mental disability, military and veteran status||Performing Services; Auditing; Legal Interests||Our Subsidiaries and Affiliated Businesses; Third Parties Aiding in our Provision of Services; Third Parties for Legal Requirements and Proceedings|
|Sensory information, such as audio,electronic, visual, thermal, olfactory, or similar information||Performing Services; Data Security & Fraud Prevention; Research and Development; Quality and Safety; Legal Interests||Our Subsidiaries and Affiliated Businesses; Third Parties Aiding in our Provision of Services; Third Parties for Legal Requirements and Proceedings|
You may, subject to applicable law, make the following requests:
To exercise your rights to know, delete, or correct described above, please submit a request by either:
Calling: 877-861-8985 or
Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct information related to your Personal Information. You may only submit a request to know twice within a 12-month period. Your request to know, delete, or correct must:
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
You do not need to create an account with us to submit a request to know or delete. We will only use Personal Information provided in the request to verify the requestor's identity or authority to make it.
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at the methods described above.
We endeavor to respond to your request (upon verification) within forty-five (45) calendar days of its receipt. If we require more time (up to ninety (90) calendar days total), we will inform you of the reason and extension period in writing. We will deliver our written response electronically, or by mail if you so choose.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request and your appeal options, if applicable.
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.
In some cases, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Subject to applicable law, we may not discriminate against you because you exercise of any of the above rights, or any other rights under the state privacy laws, including by:
Residents of the State of California may ask us to provide them with a list of the types of Personal Information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. If you are a California resident and would like such a list, please contact us by either:
Calling: 877-861-8985 or
For all such requests, please indicate "CA Shine the Light" in the subject field of your request and include the name of the specific product or service with respect to which you are requesting the information. You must also include your full name, email address, street address, city, state, zip code, and phone number.