Privacy Notice

Privacy Notice
PLANNED PARENTHOOD DIRECT PRIVACY NOTICE
Last Updated: April 15, 2024

Planned Parenthood Direct (“PPDirect,” “we,” “us,” or “our”) is a contracting partner of certain regional Planned Parenthood Affiliates governed by the Bylaws of Parenthood Federation of America, Inc. (“Planned Parenthood"). PPDirect cares about your privacy. This Privacy Notice explains how we use, disclose, and process your personal information (as such term is defined below) collected through our website https://www.plannedparenthooddirect.org, any other websites we own and operate that link to this Privacy Notice (the “Sites”) as well as our mobile applications we own and operate that link to this Privacy Notice (the “Apps”) including but not limited to the PPDirect App and SpotOn, and the related content, platform, services, products, and other functionality offered on or through our services (collectively, the “Services”). The scope of this Privacy Notice has been expanded to include additional information about how we treat personal information and options for how you can control your personal information.

Please note this Privacy Notice is not a contract and does not create any legal rights or obligations not otherwise provided by law. In addition, we reserve the right to make changes to this Policy at any given time. If you want to make sure you are up to date with the latest changes, we advise you to frequently visit this page. If at any point in time PPDirect decides to make use of any personal information on file, in a manner vastly different from that which was stated when this information was initially collected, you will be promptly notified by email which will include the information intended to be used and the purpose for which we intend to use it, at which time you will have the option to permit or refuse such use of your information.

IMPORTANT NOTE: PPDirect is a 501(c)(3) non-profit organization dedicated to creating and fostering connections between patients and clinicians both virtually and within Planned Parenthood’s network of health centers. PPDirect does not itself provide health care services, but our local Planned Parenthood Affiliates, which are separately incorporated 501(c)(3) organizations, do and we support their work.

PPDirect is not a “covered enFty” as defined by, and in accordance with the Health Insurance Portability and Accountability Act (“HIPAA”) Privacy Regulations. However, PPDirect is a Business Associate of other covered entities and as such must abide by the relevant HIPAA Privacy, Security and Breach NotificaFon regulatory requirements. To that end, the information you provide, including Protected Health Information (PHI), may be stored, used to provide services, and disclosed to third parties to complete the requisite services.

This Privacy Notice does not address privacy practices relating to Planned Parenthood Direct employees and other personnel.

Privacy Notice Highlights:

Our Privacy Notice includes the following sections, summarized here:

Our collection and use of personal information: covers the types of personal information we collect, how we collect this information, and the ways we may use the information.
Our disclosure of personal information: provides details on with whom and why we may share your personal information.
Third party data collection and online advertising: explains how we may use your personal information to provide advertisements that you may be interested in.
Control over your information: details the various ways you may exercise control over the information we collect, how you may change certain collection practices, and how to request that we delete your data.
Data retention: describes some of the considerations that go into our data retention policies, and explains that we generally keep personal information for no longer than necessary to fulfill the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law.
Data de-identification: explains our de-identification practices and our commitment to not re- identify your personal information once it has been de-identified.
How we protect your personal information: lists the measures we take to protect your personal information from unauthorized access and use.
Children’s personal data: explains that our Services are not directed to children under the age of 13 and provides processes for requesting the removal of any children’s personal information from our systems.
Links to third-party websites or services: describes application of our Privacy Notice to third- party websites or services.
California Disclosure: describes rights that California residents may have and how to exercise those rights.
Updates to this Privacy Notice: explains what to expect if and when we make any updates to this Privacy Notice.
Security: explains how we protect your information.
Acceptance of Terms: Specifies acceptance of all terms in this notice.
Contact us: describes how to contact us if you have any questions about this Privacy Notice.

I. OUR COLLECTION AND USE OF PERSONAL INFORMATION

We use the term “personal information” in this Privacy Notice to mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person. It does not include information that is considered de- identified under applicable law.

We collect personal information that (A) you provide to us, (B) we receive from third party sources, or (C) we collect automatically, as described below:

A. Personal Information You Provide to Us
This is information that you explicitly take steps to share with Planned Parenthood Direct, including but not limited to the following categories:

Contact Information. For example, first and last name, email address, postal address, phone number, your country or region, or communication preferences.
Donation Information. For example, first and last name, payment information, billing address, profession, or donation history. Please note we may utilize third-party providers to process donations on our behalf.
Demographic Information. For example, age, ethnicity, race, or sexual orientation.
Inquiry and Communications Information. For example, information provided in custom messages sent through web forms on our Sites, in chat messages, to a Planned Parenthood Direct email address, or via phone.
Marketing Emails and Blog Information. For example, email address and applicable interests and communication preferences. If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
Information Provided to Us Through Your Use of the Service. For example, any files, documents, videos, images, data, or information you choose to upload or transmit through your communications with us or your use of the Sites (collectively, “User Content”). User Content and any information contained in the User Content, including personal information you may have included (including but not limited to information that may be deemed “Protected Health Information” as defined under HIPAA), is stored as part of the Services.
Events, Surveys, and Promotions. For example, if you fill out any forms or participate in our events, surveys, competitions (contests/sweepstakes), or other promotional events, you may be asked to provide your contact information (such as your name, email, and phone number, postal code), your demographic information (as defined above), and any other information requested on the form, at sign up, or as part of your competition entry, including photos/videos (each, as applicable). On occasion, you may also provide your shipping and billing information for purposes of claiming a prize.
Job Application Information. If you apply for available positions through our Sites, we may ask you to provide personal information including, your full name, date of birth, phone number, email address, career and educational history, areas of expertise, resumes or CVs, writing samples, letters of recommendation, social media profiles, demographic information, criminal record history, or other information which may be obtained in a background check.
Other Personal Information that you provide to us online, by phone, or in person.

B. Personal Information We Collect from Third Parties
This is information we may receive from third parties, such as community partners, including but not limited to the following categories:

Other Planned Parenthood Organizations. We may receive personal information, such as your contact information, from Planned Parenthood Affiliates and other Planned Parenthood entities.
Other Individuals Who Interact with Us. We may receive your information from other individuals who interact with us. For example, we may receive your contact information from one of our donors who thinks you might also be interested in our Services or supporting our mission.
Social Media.When an individual interacts with our Services through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Google, Facebook, X (formerly known as Twitter), or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network. Individuals should always review and, if necessary, adjust their privacy settings onthird-party websites and social media networks and services before sharing informationand/or linking or connecting them to other services.
Service Providers. Service providers that perform services solely on our behalf, such as survey and marketing providers and payment processors, collect personal information and often share some or all of this information with us. The information may include contact information, demographic information, payment information, information about your communications and related activities, and information about your orders.
Community Partners. We may receive your information from our community partners, such as organizations or entities that align with our mission and vision, that may partner with us to offer products and/or services or run specific campaigns.
Other Sources. We may also collect personal information about individuals from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

C. Personal Information We Automatically Collect
We and our third-party partners may automatically collect information about how you access the Services when you visit our Sites, read our emails, or otherwise engage with us. We typically collect this information through tracking technologies, including cookies and other related technologies, such as web beacons and pixels. This information may include:

Information about the computer, tablet, smartphone, or other device you use. For example, your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that may allow us to uniquely identify your browser, mobile device, or your account, and other such information. We may also work with third-party partners to employ technologies that permit us to recognize and contact you across multiple devices, including through the application of statistical modeling tools.
Information about the way you access and use our Services. For example, the site from which you came and the site to which you are going when you leave our Services, how frequently you access the Services, whether you open emails or click the links contained in emails, whether you access the Services from multiple devices, and other browsing behavior and actions you take on the Sites.
Information about how you use the Services. For example, the pages you visit, the links you click, the ads you view and click on, videos you watch, and other similar actions. We may use third-party tools to collect information you provide to us or information about how you use the Services, and we may record your mouse movements, scrolling, clicks and keystroke activity and other browsing or purchasing behavior on the Services. These tools may also record information you enter when you interact with our Services or engage in chat features through our Services.
Information about your location. For example, general geographic location that we or our third-party providers may derive from your IP address.
Analytics information. For example, analytics data or use third-party analytics tools such as Google Analytics help us measure traffic and usage trends for the Services and to understandmore about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its opt-out options
at https://tools.google.com/dlpage/gaoptout.

We may link or combine your activities and information collected from you with information we receive about you from third parties or with information we collect automatically through tracking technologies. This allows us to provide you with a personalized experience on our Services regardless of how you interact with us.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the Services, as some features and Services may not work properly without cookies enabled. You may also set your email settings to prevent the automatic downloading of images that may contain technologies that would tell us whether you have accessed our email and performed certain functions with it.

D. Why We Use Your Information
We may use personal information we collect for:

Services and Operations: We work to provide our users with a secure and optimized experience when engaging with our online Services. To do this, we may use your personal information to enhance and personalize your user experience, to monitor and improve our Sites and Services, and to improve the effectiveness of our Services, offers, advertising, communications, and customer service. We may also use the information collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Sites; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Sites; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Services.
When Required by Law, to Prevent Fraud, and Protect Our Rights or Others’ Rights: PPDirect, as a nonprofit, must submit donation reports to governmental entities where required by law and fulfill other legal obligations. We may use your personal information to fulfill those obligations. In addition, we may need to use your personal information to prevent fraud or to protect our rights or others’ rights.

If you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information or notices where the scope of the inquiry/request or personal information we require falls outside the scope of this Privacy Notice. In that case, any such additional Privacy Notices will govern how we may process the information provided at that time.

II. OUR DISCLOSURE OF PERSONAL INFORMATION

PPDirect may collect and may make use of personal information to assist in the operation of our website and to ensure delivery of the services you need and request. At times, we may find it necessary to use your personal information as a means to keep you informed of other possible products and/or services that may be available to you from https://plannedparenthooddirect.org.
We may also be in contact with you with regard to completing survey and/or research questionnaires related to your opinion of current or potential future services that may be offered.
We share your personal information to:
1. Provide the primary service of the app or service
2. Develop marketing materials for our products
3. Conduct scientific research
4. Support company operations (e.g., quality control or fraud detecFon)
5. Develop and improve new and current products and services (e.g., analytics4 )
6. We DO NOT share your identifiable data
PPDirect may not use or disclose the information provided by you except under the following circumstances:
1. As necessary to provide services or products you have ordered;
2. In other ways described in this Policy or to which you have otherwise consented;
3. In the aggregate with other information in such as way so that your identity cannot reasonably be determined;
4. As required by law or in response to a subpoena or search warrant;
5. To outside auditors who have agreed to keep the information confidential;
6. As necessary to enforce the Terms of Use;
7. As necessary to maintain, safeguard and preserve all the rights and property of PPDirect.
Legal Obligations and Rights: We may disclose personal information to third parties:
1. In connection with the establishment, exercise, or defense of legal claims;
2. To comply with laws or to respond to lawful requests and legal processes;
3. To protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
4. To detect, suppress, or prevent fraud;
5. To protect the health and safety of us and others; or
6. As otherwise required by applicable law.
With Your Consent: We may disclose personal information about you to certain other third parties or publicly with your consent or at your direction. For example, with an individual’s consent or at their direction we may post their testimonial on our Sites or Services-related publications.

III. THIRD-PARTY DATA COLLECTION AND ONLINE ADVERTISING

We may display targeted advertisements to you on third-party websites and social media sites, such as Facebook and Instagram. We may permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on other websites or services you may use, and on other devices you may use. Information used for targeted advertisements may be collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, precise geolocation, and other information.

Targeted advertisements help us reach people who have interest in our Services or mission. In doing so, we may share your personal information with third-party advertisers to serve targeted advertisements to specific individuals, or to display ads to people who are similar to individuals who have engaged with us.

Specifically, we may engage in the following:

Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook “Like” button, Pinterest, Instagram, X (formerly known as Twitter), or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
Social Media Platforms. We may display targeted advertising to you through social media platforms, such as Facebook, X (formerly known as Twitter), Instagram, TikTok and other social media platforms. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our Site visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
Third Party Partners. We work with a variety of third-party partners to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique but anonymized identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website, “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On
here: https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available
at https://google.com/ads/preferences, or by visiting Network Advertising Initiative’s online resources at http://www.networkadvertising.org/choices. For more information about these practices and your choices regarding cookies, please refer to the Control Over Your Information section here below.

To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online Services. Rather, it means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online Services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

IV. CONTROL OVER YOUR INFORMATION

You may control your information in the following ways:

Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt- out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
Direct Mailings. From time to time, we may send you direct mail with information about issues and opportunities we think may be of interest to you. If you'd like to remove your address from future mailings, you may opt out at any time by emailing us at [email protected]. Please include your name and physical address, so that we can remove you from our direct mailings list. Please note, this opt-out does not affect any mailings that we facilitate on behalf of our third-party partners, so you may still receive direct mail sent by our third-party partners or others. You should contact the third-party partners to ask to be removed from any of their marketing, email, or mailing lists.
Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at [email protected]. We may not be able to modify or delete your information in all circumstances.

V. DATA RETENTION

We will usually store the personal information we collect about you for no longer than necessary to fulfill the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or de-identify the personal information or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store the personal information and isolate it from further processing until deletion or de-identification is possible.

VI. DATADE-IDENTIFICATION

To minimize the data in our possession, we may de-identify personal information when identifying information is no longer needed. We may also de-identify information to remove identifying information from records that must be retained for legal purposes, including when you request that we delete your information. When we de-identify information, we will use it only in its de-identified form and will not attempt to re-identify the information.

VII. HOW WE PROTECT YOUR PERSONAL INFORMATION

We maintain reasonable administrative, technical, and physical security measures to protect your personal information from unauthorized access and use. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that we become aware that personal information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the incident and where appropriate, notify those individuals whose information may have been compromised, and take other steps, in accordance with applicable laws and regulations.

VIII.CHILDREN’S PERSONAL INFORMATION

Our website and services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If it is determined that such informaFon has been inadvertently collected on anyone under the age of thirteen(13), we shall immediately take the necessary steps to ensure that such informaFon is deleted from our system’s database, or in the alternaFve, that verifiable parental consent is obtained for the use and storage of such informaFon. Anyone under the age of thirteen (13) must seek and obtain parent or guardian permission to use this website.

IX. LINKS TO THIRD-PARTY WEBSITES OR SERVICES

Our Services may include links to third-party websites, plug-ins, and applications. Except where we post, link to, or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites or services. To learn about the personal information practices of third parties, please visit their respective Privacy Notices.

X. CALIFORNIA SHINE THE LIGHT DISCLOSURE

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined under the Shine the Light law) with third parties for their direct marketing purposes. To opt out of this type of sharing, please complete our Individual Rights Form.

XI. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If the changes are significant, we will provide a more prominent notice on our Sites or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise specified.

XII. SECURITY

PPDirect takes precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline. Whenever we collect sensitive information (e.g., credit card inform information), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in this address bar and looking for “https” at the beginning of the address of the webpage.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to your personal information. The computers and services in which we store personal information are kept in a secure environment. This is all done to prevent any loss, misuse, unauthorized access, disclosure or modification of the user’s personal information under our control.

The company also uses Secure Socket Layer (SSL) for authentication and private communications to build users’ trust and confidence in the intern and website use by providing simple and secure access and communication of credit card and personal information. In addition, PPDirect is a licensee of TRUSTe. The website is also secured by VeriSign.

XIII.ACCEPTANCE OF TERMS

By using this website and the apps described herein, you are hereby accepFng the terms and condiFons sFpulated within the Privacy NoFce Agreement. If you are not in agreement with our terms and condiFons, then you should refrain from further use of our sites. In addiFon, your conFnued use of our website following the posFng of any updates of changes to our terms and condiFons shall mean that you agree and accept such changes.

XIV.CONTACT US

If you have any questions or concerns regarding the Privacy NoFce Agreement related to our website, please feel free to contact us at the following email, telephone number or mailing address:

Email: [email protected]
Telephone Number: (302) 597-9166
Mailing Address: Planned Parenthood Direct, 2810 N. Church St., Suite 19204, Wilmington, DE, 19802

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COLORADO PRIVACY DISCLOSURES

For residents of the State of Colorado: these additional disclosures supplement the information contained in our Privacy Notice by providing additional information about our personal information processing practices relating to individual residents of Colorado.
For the purposes of these disclosures, personal information does not include publicly available information or de-identified, aggregated, or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.

1. Collection and Use of Personal Information.
We may collect the following categories of personal information: identifiers, donation information, commercial information, internet/network information, geolocation data, and inferences generated from your use of our sites. For more information about our collection of personal information, the sources of personal information, and how we use this information, please see Our Collection and Use of Personal Information section of our Privacy Notice.

2. Disclosure of Personal Information.
We may disclose all of the categories of information we collect with third parties for a business purpose, as described in the Our Disclosure of Personal Information section of the Privacy Notice. The categories of third parties to whom we disclose your personal information for a business purpose may include:

Service providers and advisors that perform services for us, on our behalf, which may include providing marketing and advertising services, providing mailing or email services, tax and accounting services, data enhancement services, fraud prevention, web hosting, or similar services;
Other Planned Parenthood Organizations;
Select marketing and strategic partners who use this information to market to you, to perform analytics and conduct research, or for other purposes;
Ad networks and advertising partners, including social networks, to deliver advertising and personalized content to you on our Services, on other sites and services you may use, and across other devices you may use, as well as provide advertising-related services such as reporting, attribution, analytics, and market research;
Analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our Service;
We may also disclose personal information to other third parties at your direction or upon your request, or to comply with legal process or contractual obligations, as described in our Privacy Notice.

3. Sales and Sharing for Targeted Advertising.
We do not “sell” personal information as most people would typically understand that term. However, on certain portions of the Planned Parenthood Sites, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services, displaying ads on third party sites, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. This practice may be interpreted to constitute a “sale” under the Colorado state privacy law or may constitute the “sharing” or processing of your personal information for cross-context behavioral advertising purposes (targeted advertising) under the same. Unless you have exercised your right to opt-out, we may

disclose or “sell” your personal information, or “share” your personal information with third parties for cross-context behavioral advertising purposes. These third parties may use such information for their own purposes in accordance with their own privacy policies and as limited by any data privacy and security requirements in any agreements we may have with them.

We have “sold” or “shared” the following categories of personal information for the purposes described in our Privacy Notice, subject to your settings and preferences and your Right to Opt-Out: Identifiers, Commercial Information, and Internet/Network Information.
The categories of third parties to whom we may “sell” or “share” the personal information include: Online Advertising Networks, Analytics Providers, and Social Networks

4. Collection of Sensitive Information
The following personal data elements we may collect are classified as “sensitive information” under Colorado law:

racial or ethnic origin;
health information; and
information concerning sex life or sexual orientation.

We use this sensitive information for the purposes set forth in the Our Collection and Use Personal Information section of our Privacy Notice. As a Colorado Resident, you may be able to withdraw your consent for our processing of sensitive information (as described in the Your Privacy Choices section below).

5. Profiling
We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

6. Your Colorado Privacy Choices
If you are a Colorado resident, you may be able to exercise the following rights in relation to the personal information that we have collected about you (subject to certain limitations at law):

Right of access. You may have the right to obtain:
1. confirmation of whether, and where, we are processing your personal information;
2. information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
3. information about the categories of recipients with whom we may share your personal information; and
4. a copy of the personal information we hold about you.
Right of portability. You may have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
Right to correction. You may have the right to obtain rectification or correction of any inaccurate or incomplete personal information we hold about you.
Right to deletion. You may have the right, in some circumstances, to require us to delete or erase your personal information.
Right to opt-out. You may have the right to opt-out of certain processing activities. For example, you may have the right to opt-out of the use of your personal information for targeted advertising purposes, or to “sell” or “share” your personal information with third parties in certain contexts.
Right to withdraw consent. If you have provided consent for the processing of your personal information, you may have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.
Right to appeal. If we decline to take action on a request exercising one of your rights set forth above, you have the right to appeal our decision. If your appeal is denied, you may contact the Colorado Attorney General.
How to Exercise Your Privacy Rights Please submit a request by either:
- Completing our Individual Rights Form; or
- Calling 1-800-430-4907
  Before processing your request, we will need to verify your identity and confirm that you are a resident of Colorado. To verify your identity, we will generally require matching a minimum amount of information you provide us with the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address and phone number. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
To Exercise Your Opt-Out Rights
To exercise your right to opt-out of the “selling” or “sharing” of certain types of information, you may complete our Individual Rights Form or call 1-800-430-4907.

You do not need to create an account with us to exercise your right to opt out. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use personal information provided in an opt out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

Unless you exercise your right to opt out as described above, we may “sell” your personal information with third parties for “other valuable consideration” and we may “share” your personal information with third parties for cross-context behavioral advertising purposes (targeted advertising), as qualified in Section 3 above. The third parties to whom we share personal information may use such information for their own purposes in accordance with their own privacy policies.

Submitting Authorized Agent Requests. In certain circumstances, you are permitted to use an authorized agent to submit an “opt out” request on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and whether you are a Colorado resident, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

j) Appealing Privacy Rights Decisions
In the event that we decline to take action on a request to exercise one of your rights set forth above, you may have the right to appeal our decision. All appeal requests should be submitted by email at [email protected] with the subject line, “Privacy Request Appeal.” If your appeal is denied, you may contact the Colorado Attorney General to address your
concerns here.