PRIVACY POLICY

Last Updated: November 22nd, 2021

Summary

Personal Information We Collect

How We Use Personal Information

How We Share Personal Information

Cookies and Tracking Technologies

Choices You Have

How You Can Update Your Personal Information

How We Secure Your Personal Information

Your California Privacy Rights

Changes to This Policy

Contacting Us

Other Important Privacy Information

Summary

CSIdentity Corporation (“we,” “us” and “our”) respects individual privacy and values the confidence of our subscribers. We want you to be familiar with what information we collect about you, how the information is being used and what choices you have regarding the collection and use of the information. The privacy principles that we follow with respect to the collection, use, disclosure, and protection of information in the course of providing our products and services are consistent with relevant U.S. federal and state laws.

If you are an international subscriber, please go here to view privacy practices related to products sold outside of the U.S.

This Privacy Policy (the “Policy”) applies to and describes our privacy practices and principles in connection with our subscribers and consumers who access this website or our mobile applications. The Policy covers information that we collect directly from you, or employer automatically when you interact with our websites and mobile applications and from third party sources.

By using our websites, mobile applications and/or our products and services, you consent to the privacy practices described in this Policy. You also agree to obtain annual notices of, and changes to, this Policy electronically by visiting our website.

Personal Information We Collect

Personal information is information about you that identifies you as an individual. The personal information we collect depends on how you interact with us and the products and services that you subscribe to. We collect personal information directly from you or employer through our websites, Application Program Interfaces (“APIs”) and mobile applications and when you contact our customer service (collectively, the “Site”). We also collect personal information from third party sources.

When you subscribe to or add products and services we offer, we collect information from you, including:

·Your contact and identity information such as name, date of birth, postal and e-mail addresses, phone numbers, and Social Security number;

·Information you provide to verify your identity and use features in our products and services. This information may include details about your finances and financial accounts (including login and authentication information), and identifying and biometrical information about you;

·Your credit card or other payment account information when you purchase products and services from us;

·Your children’s identity information when enrolling your children in our child identity protection products such as their name, date of birth, and Social Security number;

·Information provided when you contact our customer service, fraud resolution agents, provide general feedback, submit content, or post to any community forum on the Site.

Depending on the products and services that you subscribe to, we obtain information from others on your behalf, including:

·Information from other Experian companies (“affiliates”) and from our third-party providers, including credit and additional information that enables us to provide you with our products and services;

·If you provide information that enables us to access data from your financial and/or other accounts, we will obtain information from those accounts, including account details, individual payment transactions, deposits, and withdrawals;

·Sensitive health information if you request monitoring of health information

·If you provide information on a third-party website to subscribe to our products and services, that third party may provide that information to us so we can provide you with our products and services. Please see additional details about third-party websites in Other Important Privacy Information;

·Your employment information and benefit plan information.

How We Use Personal Information:

We use personal information:

·To verify your identity and provide you with the products and services you request. Depending on the information you provide and your selected products and services, your personal information is used to access and monitor information you’ve asked for, provide you with identity protection services;

·To send credit, score, identity protection, and transactional alerts to the e-mail, mobile device, and/or phone number you provide;

·To send important information to you related to your account, the Site, our Terms and Conditions, or our policies.

·To inform you of products, services, and promotions that may be of interest to you unless you have requested that we do not send you marketing and promotional communications;

·To process payments for the products and services you purchase;

·If applicable, to verify your children’s identity and provide products and services you request on behalf of your children;

·For our everyday business purposes, including audits, security, detecting and preventing fraud, analysis, product improvements, research, and development;

·For other purposes when you provide your consent and/or we describe the purpose to you at the time it is collected. For example, when you request that we provide your information to monitor your financial accounts or when you request features that we offer from companies we partner with;

·For providing you or your employer with benefit services.

Non-personal information is any information that does not reveal who you are, doesn’t identify you individually, and/or is about a collective group of Site users. This includes information described under "Cookies and Tracking Technologies" and other information that doesn’t identify you, including general demographic, publicly available, derived, inferred, or specifically expressed information from users of the Site. This information may be used by us and shared with third parties for any purpose. However, if we combine any non-personal information with your personal information so that it reveals who you are, it will be treated by us as personal information as long as it is combined.

How We Share Personal Information

Affiliates: As a part of Experian, we share personal information with our Experian affiliates for the purposes noted in this Policy. We do not share personal information with our affiliates for their marketing purposes without your consent.

We also share personal information with non-affiliated third parties as described: Business Partners: We share your information to provide you with products and services that you request.

Service Providers: We share your personal information with third parties who perform services on our behalf. We share information with these service providers to provide you with the products and services you request and for everyday business purposes. For example, we use service providers for billing, communicating with our customers, detecting and preventing fraud, analysis, product improvements and development.

With Your Consent: We share your personal information with third parties who you expressly authorize, consent to, or direct us to share your information with. We also share information when you ask us to access data from your financial and/or other accounts through one or more of our third parties.

Legal: We share personal information with government entities and others for lawful and necessary purposes, including to respond to requests from government entities or our regulators; to comply with subpoenas, law enforcement requests, and other legal processes; to enforce our Terms and Conditions; and as necessary to protect the rights, privacy, safety or property of our customers, ourselves or others.

In the event of a merger, acquisition, sale, bankruptcy, or other disposition of some or all of our assets, we may share and/or transfer your personal information to an affiliate or relevant third party.

Cookies and Tracking Technologies

By using the website, you agree to the use of technology that tracks how users interact with our Site to ensure that the website is operating properly and to optimize website functionality.

When you use our Site, we, our affiliates, our business partners, and third-party service providers collect information about your devices and interactions with our Site. The types of information collected and how that information is used and/or shared depends on how you interact with our Site and, in some cases, the choices you make. A variety of tools and technologies are used to collect this information.

Information collected and the tools and technologies used for collection include:

·Device Information: The Site collects information about your devices and browsers, including types of operating systems, versions, preferences, settings, Internet Protocol (“IP”) addresses, and geolocation. If you access our Site using mobile devices, we collect information about your mobile devices, including device IDs, mobile network information, and geolocation. This information is used for identity verification, track users’ movements on our Site, to analyze trends, and gather demographic information about the Site’s users as a whole.

·Server Logs: Logs are used to automatically record device information as well as your interactions with our Site such as what time of day you visited. In the event of a problem with our Site, information in the logs allow us to diagnose and the resolve problem.

·Cookies: Cookies are small text files sent to your browser by a website you visit. The Site collects and uses session and persistent cookies. Cookies allow companies to recognize your device and store information about your account and preferences. For example, we may use cookies to store information about pages visited on our sites, settings and preferences, or other information associated with visitors to our Site. Cookies also allow us to track internal metrics and enhance the experience of users of our Site.

·Pixel tags: Pixel tags (i.e., web beacons, clear GIFs, pixels, or tags) are images or small strings of code placed on websites, advertisements, or within e-mails. These technologies collect information about your online activities over time and across different websites or online services. For example, the Site gathers user activities on our Site, links that users click on and pages viewed, the URLs user came from, and e-mails opened or forwarded. This information is used for Site tracking and administration (i.e., user movements, usage, performance, and improvements), enabling you to enroll and log-in to the Site, delivering and tailoring custom content, development of new products services, and fraud detection and prevention.

·SDKs: We use Software Development Kits ("SDKs") to collect mobile device information and general location. The SDKs track user movements, mobile application events, and user interactions. This information is used for identity verification and also helps us improve our mobile applications for our customers.

We and/or our service providers also share the information we collect with third parties for these purposes. We and our clients have access to reports produced by service providers that contain aggregated trends and statistics about website usage on our proprietary platforms.

We also use service providers to help us perform analytics such as ensuring services are working correctly and securely and providing aggregate statistics and analytics. To learn about the third-party providers we use on our Site and their privacy practices, please see their privacy notices below:

Choices You Have

You can use a range of tools to control information collection and use as well as make choices about receiving offers of products and services from us. Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is no common understanding of how to interpret the DNT signal, our websites do not operate differently in response to browser DNT signals. If you want to change your subscription options, you can do so through the membership section of your account. If you wish to cancel your subscription, please contacting us.

Opt-outs:

·E-mail: We may send you promotional or marketing e-mail communications containing information about other products and services offered by us or other third parties we partner with. If you no longer wish to receive marketing or promotional e-mails from us, you may opt-out of receiving them by following the instructions included in e-mails that we send you or by contacting us. If you opt-out, we will continue to send you credit, score, identity protection, and transaction alerts via e-mail.

·Push: We may send push notifications or alerts to your mobile device. You can deactivate push notifications and alerts at any time by deleting the app, changing your device settings, or changing the push notification settings within the app.

·Text: If you consent, we may communicate with you via text (“SMS”) messages at the phone number you provide. You may later opt-out of receiving SMS messages by responding to any SMS with one of the following single-word commands: “STOP,” “QUIT,” “CANCEL,” “END,” or “UNSUBSCRIBE.”

Controls for Cookies, Tracking Technologies and Targeted Advertising:

·Cookies: Most web browsers automatically accept cookies by default. You can use your browser settings to block, decline, or reject new cookies or delete existing ones. If you choose to block, decline, reject or delete cookies, it may prevent you from taking full advantage of our Site or prevent us from recognizing your device. These actions may impact settings, preferences and if you are a subscriber, how you log into your account.

·E-mail Tracking: E-mail applications have settings which allow you prevent the automatic downloading of images which will disable web beacons in the e-mail messages you read

·Experian and many other companies participate in the Digital Advertising Alliance (DAA)’s WebChoices Tool, which provides a simple way to opt-out of targeted advertising. You can learn more about targeted advertising and opt-out through the DAA at optout.aboutads.info. These features do not block all advertisements to your device, but they can prevent relevant advertisements from appearing.

·To manage privacy settings for the third-party providers we use on our Site:

The controls listed above rely on information stored in unique browser cookies, applications, or device identifiers, so your choices will apply only to the specific browser, application, or device from which you apply the controls. You will need to apply these controls separately on all of your browsers, applications, and devices.

How You Can Update Your Personal Information

If you are a subscriber and the personal information that you provided to us changes, you can make corrections or updates to your information, including your e-mail address, phone number, mailing address, credit card information, or password reminder phrase, by making changes to your subscriber profile page. You may also make updates by contacting us. For your protection, we may request supporting documents before making any changes or updates to your membership information. We strongly urge you to ensure that your information remains up to date.

How We Secure Your Personal Information

We have appropriate physical, technical, and organizational measures and tools in place to protect your personal information against the loss, misuse and alteration of information that complies with relevant legal requirements and best practices. When you enter sensitive information (such as a credit card, Social Security number or login credentials) into the Site, we encrypt the transmission of that information using Secure Socket Layer (SSL) technology.

When you provide information through the Site, you should be aware that your information may be transmitted across the Internet and no method of transmission over the Internet is 100% secure. Although we take reasonable security measures to protect your information when we receive it, you also need to ensure you take appropriate steps to protect your information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem as soon as possible by contacting us.

Your California Privacy Rights under the California Consumer Privacy Act (CCPA)

CSIdentity Corporation is a part of Experian. If you are a California consumer and would like to learn about Experian’s approach to privacy under the CCPA, please visit Experian’s California Privacy Rights Policy here.

Changes to This Policy

In the future, we may update this Policy to reflect changes to our information practices. You can determine when this Policy was last updated and the effective date of this Policy by referring to the last revised date. We encourage you to periodically review this page for the latest information on our privacy practices and this Policy.

Contacting us

If you have questions about this Policy or our privacy practices, please contact us by:

Phone: 855.890.CSID (2743)

E-mail: privacy@csid.com

Mail: CSIdentity Corporation

Attn: Compliance Department

1501 S. Mopac Exp., Suite 200

Austin, TX 78746

Other Important Privacy Information

For Customers of Our Clients

We also resell our services through third party commercial clients (“Clients”). In those cases, we do not have a direct relationship with the individuals whose information we collect to provide products and services through our Clients. If you are a customer of one of our Clients, we may use and share your information with the Client and third parties as noted in this Policy.

If you would no longer like to be contacted by one of our Clients, please contact the Client directly. Customers of our Clients should also direct requests for updates or corrections to their information to the Client. This Policy does not govern the privacy practices of our Clients. Please refer to the Clients privacy policies for information on their privacy practices.

Third-Party Websites, Links and Social Media:

The Site may contain links to third-party websites. We have no control over, nor are we responsible for the privacy practices of these linked websites or any other third-party websites. Once you leave our Site, we cannot be responsible for the protection and privacy of any information that you provide while visiting a third-party website, and such websites are not governed by this Policy. You should exercise caution and look at the privacy policy applicable to the website in question. If you provide any personal information to a third-party website to subscribe to our products or services, your transaction will occur on the third-party website and will be controlled by the third-party privacy policy unless otherwise noted. Our Site also includes social media features, such as the Facebook and Twitter buttons or interactive mini programs that run on our Site. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. These features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the social media provider’s privacy policy. This Policy does not govern information provided to us on any of our social media-branded pages or accounts. THIS POLICY DOES NOT ADDRESS THE PRIVACY PRACTICES OF ANY THIRD PARTIES.

Children’s Privacy:

The Site is not directed to individuals under the age of eighteen (18), and we request that such individuals not provide personal information through the Site. If you are under 18 years of age, you may browse our Site; however, you may not provide personal information to us such as name, address, or e-mail address, and you may not register for, enroll in, and/or make product purchases.

For Former Customers:

When you cancel your subscription or otherwise cease to be our customer, we may continue to use and share your information as described in this Policy