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Notice at Collection and U.S. State Supplemental Privacy Notice

This Notice at Collection and U.S. State Supplemental Privacy Notice (“Supplemental Notice”) supplements our main Privacy Policy (together, our “Privacy Statements”). Our Privacy Statements explain how we collect, use, and disclose information that identifies you or could reasonably be linked to you. In this Notice, we refer to that information as “personal information.”

This Supplemental Notice provides additional details about how we handle personal information for people who live in U.S. states with comprehensive privacy laws, such as California (under the California Consumer Privacy Act, or “CCPA”), Oregon (under the Oregon Consumer Privacy Act), and other U.S. state privacy laws, as applicable (together, “State Privacy Laws”).

For California residents, this Supplemental Notice also applies to current and former job applicants, employees, and contractors of Cotality that visit the website. Our Global Applicant Privacy Policy also applies to individuals during the recruitment process.

1. Information about our data practices

1.1. How we collect and retain personal information

In the last 12 months, we may have collected and retained personal information as follows:

Category of Personal Information Examples
1. Identifiers Real name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol address, email address, and account name.
2. Personal Records Name, signature, description, address, telephone number, and financial information (e.g., payment card information).
3. Personal Characteristics or Traits In some circumstances, information considered protected under U.S. law, such as age, gender, nationality, race or information related to medical conditions. Typically associated with HR purposes.
4. Customer Account Details / Commercial Information Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
5. Internet Usage Information Browsing history, search history, and other information regarding your interaction with Services or other sites, applications, or advertisements.
6. Geolocation Data Approximate location of the device or equipment you are using when interacting with us online.
7. Professional or Employment Information Professional, educational, or employment-related information.
8. Non-public Education Records Education records directly related to a student maintained by an educational institution or party acting on its behalf.
9. Inferences from Personal Information Collected Inferences drawn from other information collected about you.

We generally retain personal information to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

1.2. How we obtain personal information

How we may collect your personal information is outlined in Section 2 of our Privacy Policy.

1.3. How we use personal information

Information regarding how we may use your personal information can be found in Section 3 of our Privacy Policy.

1.4. Personal information that may be disclosed for a business purpose

During the last 12 months, we may have disclosed personal information to third parties as described in Section 4 of our Privacy Policy. The categories of personal information we have disclosed to these parties may include: identifiers; personal records; personal characteristics or traits; customer account details / commercial information; internet usage information; geolocation data; professional or employment information; non-public education records; and inferences from personal information collected.

1.5. Personal information that may be sold or “shared” (including for targeted advertising)

In the past 12 months, we may have sold or “shared” (as defined under the CCPA) the following categories of personal information to the following types of third parties:

Categories of Third Parties Categories of Personal Information
· Advertising Networks
· Marketing Partners
· Social Networks
· Identifiers (alias, unique personal identifier, online identifier)
· Demographics (name, title, phone number, business email, home address, personal email, industry, company)
· Commercial information (purchase/transaction history)
· Internet/electronic network activity (browsing history, search history)
· Inferences (e.g., visitors’ occupation)

We sell or share the Personal Information identified above to third parties to advance our commercial or economic interests. For additional information about these third parties, please visit Section 4 of our Privacy Policy.

2. Privacy rights

Depending on where you live and subject to certain legal limits and exceptions, you may have some or all of the rights listed below.

2.1. Right to know/access

You may have the right to request that we confirm whether we are processing or have processed your personal information related to the Website. Additionally, you may have the right to request that we disclose the personal information we have collected about you, including:

  • The categories of personal information we have collected
  • The categories of sources from which such personal information is collected
  • The business or commercial purposes for collecting, selling, or sharing your personal information
  • The categories of third parties to whom we disclose or have disclosed your personal information
  • The specific pieces of your personal information that we maintain or have processed

2.2. Right to delete

You may have the right to request that we delete personal information we have collected about you, subject to certain exceptions (for example, when we need the information to comply with the law, to complete a transaction you requested, or for security purposes).

2.3. Right to correct

You may have the right to request that we correct personal information we hold about you if you believe it is inaccurate.

2.4. Right to opt-out of sale or sharing

You may have the right to direct us:

  • Not to sell your personal information; and
  • Not to share your personal information for cross-context behaviorial or targeted advertising.

2.5. Right to opt-out of automated decision-making technologies or profiling

In some circumstances, you may have the right to opt out of certain types of automated processing or profiling that are used to evaluate or predict aspects about you, such as your preferences or interests, where that processing produces legal or similarly significant effects for you.

2.6. Right to not receive discriminatory treatment

You may have the right not to receive discriminatory treatment for exercising any of the rights described in this Supplemental Notice.

2.7. Right to appeal

You may have the right to appeal or response to your exercising of the privacy rights identified above, or if we refuse to take action after you make a request to exercise those rights. You may appeal by calling us at 1-800-634-4149 or emailing us at datasubjectrequests@cotality.com.

3. Exercising privacy rights

3.1. How to submit privacy requests

To exercise any of the rights described above (including through an authorized agent), you may:

  • To opt out of the sale or sharing of your personal information(including for targeted advertising):
    • Click on “Do Not Sell or ShareMy Personal Information” link;
    • Contact us toll-free at1-800-634-4149;
    • Send an email with your name to datasubjectrequests@cotality.com; or
    • Visit our “Cookies Preferences” page and manage your preferences.

3.2. How we process privacy requests

We will process privacy requests in accordance with applicable State Privacy Laws and subject to the following:

  • Verification Methods. To protect your privacy, we may need to verify your identity before we act on your request. We may ask you for information such as your name, email, phone number, and/or mailing address, and use this information to match it to the information we maintain. If we are unable to verify your request with the information you provided, we may contact you to request additional information.
  • Agent requests. You may use an authorized agent to exercise your rights on your behalf. We may ask the authorized agent to provide a signed authorization from you, confirming their authority to act on your behalf. Additionally, we might require you to verify your own identity directly with us.