Last Updated, June 28, 2024
Welcome! This Privacy Notice explains how VMS collects, uses, discloses, and otherwise processes personal information in connection with the Services. This Privacy Notice does not address our privacy practices relating to VMS job employees and other personnel.
For purposes of this Privacy Notice, "VMS," "us," "we," and "our" means Lead Intelligence, Inc. (dba Verisk Marketing Solutions) ("Verisk Marketing Solutions"), and its affiliated entities, including Infutor Data Solutions, LLC ("Infutor").
When we use the term "Services," we are referring to our internet websites and end-to-end engagement and membership programs and services that we offer and manage on our own behalf, including:
- Websites, Apps, Online Services, and Business Activities: our websites, apps, and online services that we own and operate that link to this Privacy Notice, and other activities that support the VMS business lines (such as marketing and advertising practices);
- Data Services: our data solutions and consumer analytics products provided by Verisk Marketing Solutions and Infutor ("Data Services");
- Platform Services: our proprietary technology platform, including the Create Script ("Create Script") used to create Universal LeadiDs ("LeadiD"), and any products/services provided as part of the platform services (the "Platform Services").
Our Role in Processing Personal information
US state privacy laws differentiate between "controllers" and "processors" of personal information. A "controller" determines the purposes and means (the why and how) of processing personal information. A "processor," which is sometimes referred to as a "service provider," processes personal information on behalf of a controller subject to the controller’s instructions.
This Privacy Notice describes our privacy practices where we act as the controller of personal information. This Privacy Notice does not cover or address how our customers (companies) may process personal information when they use our Services, or how we may process personal information on their behalf in accordance with their instructions where we are acting as their processor. As a result, we recommend referring to the privacy notice of the company with which you have a relationship for information on how they engage processors, like us, to process personal information on their behalf. In addition, we are generally not permitted to respond to individual requests relating to personal information we process on behalf of our customers, so we recommend directing any requests to the relevant customer.
1. OUR COLLECTION AND USE OF PERSONAL INFORMATION
a. WEBSITES, APPS, ONLINE SERVICES, AND BUSINESS ACTIVITIES
We collect personal information in a variety of ways. For example, you may provide us your personal information when you visit our websites, use our apps, send us a message, subscribe to our mailing list, newsletters, or other forms of marketing communications, participate in a survey, redeem a promotion, or use our Services such as the Data Services or Platform. We may link or combine the information collected from you with information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below).
The following sections provide more detail on the personal information collected through each of our Services, and our use of such information.
Personal Information Collected from You
- Inquiry and Communications Information, including information provided when you submit a contact or service request through one of our forms, including requests to join one of our programs, a request made through our applications including Member Portal or MyJornaya, or schedule a demo. The personal information we may collect in response to a request may include name, job title, company name, corporate website, email address, and/or phone number. We may also collect any personal information you provide in custom messages sent through the forms, in communications with through our chatbot (which is provided by a vendor), or to one of our email addresses. We use this information to review and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.
- Business Representative Contact Information. If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g., email, phone, address), job title, and any other information related to the performance of the agreement with us.
- Account Information. If you sign up for our Data or Platform Services and create an account, we may collect information such as your email address, user ID and password, and any other information you provide to us. We use this information to administer your account, provide you with the relevant service and information, communicate with you regarding your account and your use of the Services, and for customer support purposes.
- Payment Information. . If you sign up for our Data or Platform Services, we collect the information provided in connection with such payment. Depending on the type of engagement, you may be able to pay via wire transfer, credit card, or check and we may collect the financial information associated with such payment (e.g., routing and account number, wire transfer information details). Please note that we use third party payment processors, including VersaPay, to process credit card payments made to us. As such, we do not retain any personally identifiable financial information in connection with credit card payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party processor. The payment processor’s use of your personal information is governed by their privacy notice. To view VersaPay’s privacy policy, please click here
- Newsletter and Marketing Emails. We may use your name and email address to manage our communications with you and send you information about products and services we think may be of interest to you. 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 including updates to our terms and services).
Personal Information Collected from Third Parties
We may also combine the information we receive from you with personal information we obtain from third-party sources, including the following:
- 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 Facebook, X (formerly Twitter), LinkedIn or other social networks, we may receive some information about individuals that they permit the social media network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
- Service Providers. Our service providers that perform services solely on our behalf, such as website hosting providers and certain advertising/marketing providers, collect personal information and may share some or all of this information with us.
- Information from Other Sources. We may obtain information from other sources, including through third-party information providers, our shareholders, our affiliated companies, customers, or through transactions such as mergers and acquisitions. We may combine this information with other information we collect from or about you. In these cases, our Privacy Notice governs the handling of the combined personal information. We use this information to operate, maintain, and provide to you the features and functionality of the Services, 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.
b. DATA SERVICES
The personal information we collect in connection with our Data Services is as follows:
Personal Information Collected from Third Party Sources When we provide our Data Services, we leverage personal information data we receive from a variety of sources, including through websites and mobile apps, public records and other publicly available sources, government entities, social networks, our customers, consumer data resellers, and other data compilers.
The personal information we collect from the various sources may include (on the individual, household, or geographic level), such as:
- Contact information, such as your name, address, and other contact information.
- Professional information, including occupation and job title.
- Particular interests, such as (for instance) home improvement, music, online shopping, health and beauty sport, or travel, or political leanings, and the organizations to which you belong or have belonged, or to which you have contributed.
- Demographic information, such as age, gender, level of education, or likely income range.
- Publicly available information, such as information that available in the public domain or from government public records.
- Inferences, which may include any of the categories of personal information listed in this section – for instance, if a household is in a particularly wealthy area, we might infer a particular income range; if a person’s name is "Catherine" we might infer gender as likely female.
Our Uses of Personal Information in Connection with Our Data Services. We use the information collected through our Data Services for various purposes, including the following:
- Data Marketing Services. Our Services include providing marketing information to our customers, generally regarding which of their customers or prospective customers are most likely to be interested (or disinterested) in certain offers, or how to best contact or identify those customers. Similarly, we help our customers identify and understand their customers better, by providing certain insights about them.
- Online Targeting. We sometimes create defined audience segments based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., households with health care professionals, or with an interest in international travel) ("Audience Segments"). When we do this, we may work with data partners that "match" our information, including through de-identification techniques (such as through coded data "hashing"), with online cookies and other identifiers in order to target and measure ad campaigns online across various display, mobile and other media channels. You may learn more about how to opt out of this and other online ad targeting in the Control Over Your Personal Information section of this Privacy Notice.
- Identity Products. We sometimes use the information we collect to create (or to help our customers create) "identity" graphs, to help locate users across various channels, such as based on common personal, device-based, or network-based identifiers (e.g., IP address, email address).
- Academic and Market Research. We sometimes use the information to help our customers understand specific markets and what influences the purchase decision and behavior of their target audiences.
- General Geolocation and Spatial Analysis. We sometimes use the information to help our customers better understand market opportunities at proposed physical site locations.
- Additional Marketing Services. Other Services we may provide to our customers (or that they may provide to their own customers), which may overlap with or supplement the above, may involve (i) help with targeting and optimizing direct mail, email campaigns, display, social and mobile marketing; (ii) measuring how effective marketing campaigns have been by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases; (iii) analyzing and optimizing our customers’ (or their service providers’) proprietary databases, or helping customers to detect and prevent crime and fraud; or (iv) providing "validation" or data hygiene services, which is how companies update and/or correct their databases by verifying, removing or correcting old, incorrect or outdated information.
- To Operate Our Services: We also use the information for our own internal purposes – such as to improve, test, update and verify our own database; to develop new products; and to operate, analyze, improve, and secure our Services and our databases and servers.
c. PLATFORM SERVICES
The Platform Services allows our customers to: (i) verify certain data origin and history; (ii) help advertisers, vendors, and marketers analyze first, second, and third party consumer interactions to, for example, focus their attention and efforts on consumers who may be interested in certain products and/or services; (iii) supplement our Services with related services provided by our strategic partners; and (iv) verify that an event was or was not TCPA Compliant to the customers’ standards by identifying if there was active or passive consent to a TCPA disclosure.
Our Platform Services are facilitated through the use of the VMS unique online identifier called "LeadiD." When a consumer visits, enters information into, or otherwise interacts with a customer website or online platform, the technology associated with our Services (which includes the Create Script installed by the customer at a customer website or platform) captures certain information about a consumer who is assigned a LeadiD. If the consumer’s browser allows it, a persistent cookie is dropped so that the same browser can be identified in future events and tied to the LeadiD or other identifiers.
In providing the Platform Services to our customers, VMS may provide specific services as a processor or as a controller depending on the type of service. The personal information collected and processed will vary depending on such classification, as follows:
VMS as a Controller. In providing the Platform Services to our customers, we may collect or otherwise process personal information as a controller, including:
- Event Data: The Platform facilitates the use of Create Script to capture data from unique consumer events that are connected to the specific LeadiD assigned to that particular consumer ("Event Data"). The Event Data captured includes but is not limited to, consumer age and history information; integrity information; customer’s account number, name, and referrer URL; and information that consumers may submit in the open text fields of customer platforms, such as name, contact information (e.g., email, phone, address), annual income, and other information provided in connection with the requested service offered by the VMS customer.
- Inferences: We may generate inferences that are derived from Event Data or other personal information collected by VMS, as further described in this "Our Collection and Use of Personal Information" section. Such inferences may be (i) related to an event associated with a LeadiD (for example, consumer age, data integrity, and origin of information); or (ii) related to a consumer associated with a unique identifier.
- Predictive Insights: We may use Event Data to make predictions about certain likely behaviors or outcomes, such as your interest in a particular product or service.
We may use this information to provide the Services to our customers, and to facilitate and enhance our other services and offerings.
VMS as a Processor. VMS may also act as a data processor in providing the Platform Services, such as when our customers use the "TCPA Guardian" services to, for example, verify that an event was or was not TCPA Compliant to the customers’ standards by identifying if there was active or passive consent to a TCPA disclosure. In the provision of such processor services, we have contractually committed ourselves to only processing such customer information on behalf of and under the instruction of the respective customer, who is the controller. This Privacy Notice does not apply to such processing, and we recommend you read the privacy notice of the respective customer if their processing concerns your personal information.
Additional Uses of Personal Information For all of our Services, we may also use the personal information we collect to:
- Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations and to deliver the Services you have requested;
- Manage our organization and its day-to-day operations;
- Verify your identity and entitlement to products or Services, when you contact us or access our Services;
- Communicate with individuals, including via email, direct mail, social media and/or telephone calls;
- For marketing and advertising purposes, including to market to you or offer you through email information and updates on products or services we think that you may be interested in;
- Identify and analyze how individuals use our Services;
- Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
- Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
- Help maintain the safety, security and integrity of our property and Services, technology assets and business;
- To enforce our contracts, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
- Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
- Comply with contractual and legal obligations and requirements;
- To fulfill any other purpose for which you provide personal information; and
- For any other lawful purpose, or other purpose that you consent to.
Where 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 where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.
Through the provision of our Services, we may process de-identified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. VMS will maintain and use the information in de-identified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the de-identification process used by VMS satisfies the requirements under applicable law.
We may also aggregate data for reporting, analytics, and other business reasons, including to promote or describe the use of our Services.
2. DISCLOSURE OF PERSONAL INFORMATION
We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:
- VMS Entities: We may share personal information with other companies owned or controlled by Verisk Marketing Solutions, and other companies owned by or under common ownership as Verisk Marketing Solutions, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
- Your Employer: If you interact with our Services through your employer, we may disclose your information to your employer, including another representative of your employer or company.
- Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
- Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
- Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, and administrative services.
- Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see the Third-Party Data Collection and Online Advertising section for more information.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, restructuring, bankruptcy or receivership.
- Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
- to detect, suppress, or prevent fraud;
- to protect the health and safety of us and others; or
- as otherwise required by applicable law.
- With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or marketing-related publications.
Additional Disclosures of Personal Information – Data Services In the provision of the Data Services, VMS may also share personal information with customers, marketing services and platforms, as well as service providers that help us to provide the Data Services we’ve described above (or other services we may add in the future). This includes sharing in the following ways:
- With Our Customers: As described above, we share personal information in various ways with our customers (and sometimes with partners and resellers, who license the Information to their customer), when we provide our Data Services. We may sometimes share the personal information with those customers’ service providers (for instance, a provider that prints or sends mailings for a customer), or ad agencies that they work with.
- With Our Partners: We may also share personal information, including Audience Segments, with business and data partners to help provide more tailored targeted marketing, advertising and communications. Likewise, we may do so for analytical purposes, including to help these other parties measure campaign performance, inform future campaigns, or to handle, analyze, or segregate this Information on our or our customers’ behalf.
- With Our Service Providers: We share personal information with a variety of service providers in order to operate, protect and advertise our Data Services and maintain our website(s). For instance, we may share the personal information with tech and customer support providers, marketing and advertising providers, other data providers (such as to enhance or verify our personal information), security vendors, payment vendors (as to our business-to-business information), and other companies help us deliver or develop Data Services.
Additional Disclosures of Personal Information – Platform Services In the provision of the Platform Services where VMS acts as a controller, VMS may also share with third parties, business partners, or other VMS customers Event Data, predictive insights (such as insights and/or a scoring model to help predict a requested customer outcome), and information related to the VMS "Activate Services" such as consumer behavior (e.g., whether a consumer visited a website that share commonality of services).
3. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION
We, and our third-party partners, may automatically collect certain types of usage information when you visit our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, "tracking technologies").
We, and our third-party partners, use tracking technologies to automatically collect usage and device information, such as:
- Information about your device and its software, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
- When you access our Services from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers ("IDFA"), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.
- Information about the way you access and use our Services, for example, the website from which you came and the website to which you are going when you leave our Services, the pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the services from multiple devices, and other actions you take on the Websites.
- We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the services and to understand more about the demographics of our users. You can learn more about Google’s practices at https://policies.google.com/technologies/partner-Websites and view its opt-out options at https://tools.google.com/dlpage/gaoptout.
We use the data collected through tracking technologies to:: (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the Websites; (ii) provide custom, personalized content and information, including targeted content and advertising; (iii) identify you across multiple devices; (iv) provide and monitor the effectiveness of our Services; (v) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Websites; (vi) diagnose or fix technology problems; and (vii) otherwise to plan for and enhance our Services.
For more information on how to manage your cookies preferences, please see Cookies and Other Tracking Technologies Opt-Out of the Control Over Your Information section below.
We and our third-party partners may also use tracking technologies for advertising purposes. For more information about tracking technologies, including your choices regarding this technology, please see Third-Party Tracking and Online Advertising below.
4. THIRD-PARTY TRACKING AND ONLINE ADVERTISING
We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We 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 our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is 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 Websites, AdID, general geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.
Please see Online Ads in the Control Over Your Information section below to learn how you can opt out of interest-based advertising.
We may engage in the following:
- Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook "Like" button, X, LinkedIn, YouTube, 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, Instagram, LinkedIn, and other social media forums. 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 website 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 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 NAI’s online resources at http://www.networkadvertising.org/choices.
For more information about these practices and your choices regarding cookies, please see the Control Over Your Information section below.
5. 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, or updates to terms and services).
- Modifying or Deleting Your Information. . If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly by clicking here. We may not be able to modify or delete your information in all circumstances.
- Cookies: Where a VMS-specific preference manager or privacy setting is not available, you may be able to utilize third-party tools and features to further restrict our use of automatic data collection technologies. For example, an individual may have the ability to change their browser settings to (for example): (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies (or certain types of cookies, such as cookies set by third parties). Note that similar controls may exist for other tracking technologies, such as pixels, SDKs, and localStorage. Please check your device or browser settings and related documentation for more information. Further, note that restricting the use of these technologies might negatively impact an individual’s experience using our Services, as some features or offerings may be less personalized or may not work as otherwise intended. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies or other tracking technologies described in this Privacy Notice. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser and device they use. An individual may also have options within their email client to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.
- Online Ads: In addition to taking the steps set forth in the Cookies section above, you may be able to further exercise control over the advertisements that you see by leveraging one or more targeted advertising opt-out programs. For example:
- Device-Specific Opt-Out Programs: Certain devices provide individuals the option to turn off targeted advertising for the entire device (such as Apple devices through their App Tracking Transparency framework or Android devices through their opt out of ads personalization feature). Please refer to your device manufacturer’s user guides for additional information about implementing any available device-specific targeted advertising opt-outs.
- Digital Advertising Alliance: The Digital Advertising Alliance allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://www.optout.aboutads.info/?c=2&lang=EN https://www.optout.aboutads.info/?c=2&lang=EN for browser-based advertising and https://www.youradchoices.com/appchoices for app-based advertising to opt out of targeted advertising carried out by our third-party partners and other third parties that participate in the Digital Advertising Alliance’s self-regulatory program.
- Network Advertising Initiative: : The Network Advertising Initiative similarly allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://www.optout.networkadvertising.org/?c=1 to opt out of browser-based targeted advertising carried out by our third-party partners and other third parties that participate in the Network Advertising Initiative’s self-regulatory program.
- Platform-Specific Opt-Out Programs: Certain third-party platforms provide individuals the option to turn off targeted advertising for the entire platform (such as certain social media platforms). Please refer to your platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.
Please note that when you opt out of receiving interest-based advertisements through one of these programs, this does not mean you will no longer see advertisements from us or on our services. Instead, it means that the online ads you do see from relevant 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, program participants may still use automatic data collection technologies to collect information about your use of our services, including for analytics and fraud prevention as well as any other purpose permitted under the applicable advertising industry program.
6. DATA RETENTION
We will usually store the personal information we collect about you for no longer than necessary to fulfil 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 deidentify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store the personal information and isolate it from further processing until deletion or deidentification is possible.
7. CHILDREN’S PERSONAL INFORMATION
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.
8. 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 and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.
9. 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 we are required by applicable data protection laws to give you enhanced notice or seek out consent to any such changes, we will do so. All changes shall be effective from the date of publication unless otherwise provided.
10. CONTACT US
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please contact us using one of our forms or send us an email to vmsprivacy@verisk.com or by postal mail at:
Verisk Marketing Solutions Privacy and Compliance 18 W 140 Butterfield Rd. Suite 400 Oakbrook Terrace, IL, 6018111. ADDITIONAL U.S. STATE PRIVACY DISCLOSURES
For residents of the States of California, Colorado, Connecticut, Montana, Nevada, Oregon, Utah, Texas, and Virginia: These Additional U.S. State Privacy Disclosures ("U.S. Disclosures") supplement the information contained in our Privacy Notice by providing additional information about our personal information processing practices relating to individual residents of these States. For a detailed description of how we collect, use, disclose, and otherwise process personal information in connection with our Services, please see the main body of this Privacy Notice. Unless otherwise expressly stated, all terms defined in our Privacy Notice retain the same meaning in these U.S. Disclosures.
For the purposes of these U.S. Disclosures, personal information does not include publicly available information or deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you. Additionally, the U.S. Disclosures set out in this Section do not describe our practices when we process customer data as a service provider/processor on behalf of our customers in accordance with our contractual agreements with our customers.
Personal Information Disclosures, Sales and Targeted Advertising
Personal Information Collection. In the last 12 months, we may have collected the following categories of personal information: identifiers, commercial information, characteristics of protected classifications under California or US law, internet/network information, geolocation data, professional/employment information and inferences, sensitive personal information as defined under California law, inferences drawn from any of the information identified above to create a consumer profile. For more information about our collection of personal information, the sources of personal information, and how we use this information, please see How We Collect and Use Information section of our Privacy Notice.
Sales of Personal Information and Sharing for Targeted Advertising. Unless you have exercised your Right to Opt-Out, and as described in the Disclosure of Personal Information section of these U.S. Disclosures, we may disclose or "sell" your personal information to third parties for monetary or other valuable consideration, or "share" your personal information to third parties for cross-context behavioral advertising purposes. The third parties to whom we sell or share personal information may use such information for their own purposes in accordance with their own privacy policies. In the previous 12 months, we have sold or shared for targeted advertising purposes the following categories of personal information to third parties, subject to your settings and preferences and your Right to Opt Out:
- Identifiers;
- Commercial or transactions information;
- Characteristics of protected classifications under California or US law (inferenced or actual, including self-reported), e.g., race; color; religion; sex/gender; pregnancy, marital status; military or veteran status; national origin; ancestry; age (over 40) (may be inferenced, actual or self-reported);
- Internet / Network Information;
- Geolocation data;
- Professional or employment-related information; and
- Inferences data, e.g., consumer information or preferences.
In addition, please see Third-Party Tracking and Online Advertising section of the Privacy Notice to learn more about how third-party advertising networks, social media companies and other third-party businesses collect and disclose your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us.
Disclosure of Personal Information. In the last 12 months, we may have disclosed all of the categories of information we collect with third parties for a business purpose, as described in the Disclosure of Personal Information section of the Privacy Notice. The categories of third parties to whom we sell or disclose your personal information for a business purpose include:
- Our customers;
- Commercial recipients, which may include data compilers and consumer data resellers, consumer goods retailers and informational and retail websites, content publishers, non-profit organizations; business-to-business services and organizations, and affiliate networks;
- Advertising networks and media platforms;
- Political campaigns;
- Internet service providers;
- Data analytics providers; and
- Social media networks.
Automated Decision-Making and Profiling
We do not conduct automated processing of personal information for the purposes of evaluating, analyzing, or predicting an individual’s personal aspects in furtherance of decisions that produce legal or similarly significant effects. As a result, we do not provide a right to exercise control over such forms of automated decision-making and profiling.
Your Additional Privacy Rights
Depending on your state of residency, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
- The Right to Know. The right to confirm whether we are processing personal information about you and, under California law only, to obtain certain personalized details about the personal information we have collected about you in the last 12 months, including:
- The categories of personal information collected;
- The categories of sources of the personal information;
- The purposes for which the personal information were collected;
- The categories of personal information disclosed to third parties (if any), and the categories of recipients to whom the personal information were disclosed;
- The categories of personal information shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for those purposes; and
- The categories of personal information sold (if any), and the categories of third parties to whom the personal information were sold.
- The Right to Access and Portability. The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
- The Right to Request Deletion. You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions. If you are a resident of the State of California under the age of 18, you may also request and obtain removal of user-generated content you have posted on our platform (though please note that such a request does not ensure complete or comprehensive removal of all user-generated content, particularly where user-generated content has been republished or reposted by another user or third party).
- The Right to Correction. You have the right to request that any inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information.
- The Right to Control over Sensitive Information. You have the right to exercise control over our collection and processing of certain sensitive information.
- Right to Control over Automated Decision-Making/Profiling. The right to direct us not to use automated decision-making or profiling for certain purposes.
- The Right to Opt Out of Sales. The right to direct us not to sell personal information to third parties, including the right to opt-out of the disclosure of personal information to third parties for the third parties’ direct marketing purposes under California’s "Shine the Light" Law.
- The Right to Opt Out of Targeted Advertising. The right to direct us not to use or share personal information for certain targeted advertising purposes.
- Right to Appeal. In the event that we decline to take action on a request exercising one of your rights set forth above, you have the right to appeal our decision.
- Colorado Residents: If your appeal is denied, you may contact the Colorado Attorney General to address your concerns here.
- Connecticut Residents: If your appeal is denied, you may contact the Connecticut Attorney General to submit a complaint here.
- Montana Residents: If your appeal is denied, you may contact the Montana Attorney General to submit a complaint here.
- Oregon Residents: If your appeal is denied, you may contact the Oregon Attorney General to submit a complaint here.
- Virginia Residents: If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint here.
Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
How to Exercise Your Privacy Rights
To submit a request to exercise one of the privacy rights identified above with regards to your personal information collected or otherwise processed pursuant to the Platform Services, please submit a request by:
- Filling out our Individual Rights Request Form; or
- Calling our toll-free number at 1 (866) 207-1399.
To exercise your right to opt-out as it relates to the use of cookies and related technologies that involve the sale of personal information or the use of personal information for targeted advertising purposes, please click the "Cookie Settings" icon on the bottom of the website and adjust your preferences accordingly. If you are visiting our site with the Global Privacy Control enabled, any cookies that constitute sales or are used for targeted advertising should already be turned off automatically in our cookie preference manager. Please note this opt-out tool is website, device, and browser specific, so you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting.
For certain rights, we may need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.
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.
Authorized Agents
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the applicable privacy law) to submit requests on your behalf through the designated methods set forth in these U.S. Disclosures where we can verify the authorized agent’s authority to act on your behalf. Before processing your request to exercise certain rights (including the Right to Know, Access & Portability, Correction, and Deletion), we may require the following for verification purposes: (a) a power of attorney valid under the laws of the state where you reside from you or your authorized agent; or (b) sufficient evidence to show that you have: (i) provided the authorized agent signed permission to act on your behalf; and (ii) verified your own identity directly with us pursuant to the instructions set forth in these U.S. Disclosures; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
For requests to opt-out of personal information "sales" or "sharing", we may require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.
Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted using the applicable Individual Rights Request Form listed in the How to Exercise Your Privacy Rights section above.
Notice of Financial Incentives
We may offer various programs and other financial incentives that may result in differences in our prices or services offered to customers. To obtain access to these offerings, we may collect and retain personal information. We have determined that the value of these programs and other incentives are reasonably related to the value of the personal information we receive and otherwise process in connection with these programs and offerings, based on our reasonable but sole determination. We estimate the value of the personal information we receive and otherwise process in connection with these programs and offerings by considering the expense we incur in collecting and processing the personal information, as well as the expenses related to facilitating the program or offering. The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer. Participating in any financial incentive program is entirely optional and participants may withdraw from the program at any time. To opt-out of the program and forgo any ongoing incentives, please follow the instructions in the program’s terms and conditions or contact us via email at vmslegal@verisk.com. Participating individuals may also opt out of receiving marketing communications by following the instructions set forth in the Control Over Your Information section of our Privacy Notice.
California-Specific Disclosures
The following disclosures only apply to residents of the State of California.
Minors. We do not sell the personal information and do not have actual knowledge that we sell the personal information of minors under 16 years of age. If we wish to do so in the future, we will first seek affirmative authorization form either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at vmsprivacy@verisk.com to inform us if you, or your minor child, are under the age of 16.
California Consumer Rights Metrics 2023. The following data reflects the California consumer rights requests that we have processed in the 2022 calendar year (January 2023 – December 2023):
2023 |
|
a. The number of requests to know (disclosures) that the business received, complied with in whole or in part, and denied. |
|
b. The number of requests to delete that the business received, complied with in whole or in part, and denied. |
|
c. The number of requests to opt-out that the business received, complied with in whole or in part, and denied. |
|
d. The median or mean number of days within which the business substantively responded to requests to know, requests to delete, and requests to opt-out. |
|
Texas Data Broker Disclosures
The entity maintaining this website is a data broker under Texas law. To conduct business in Texas, a data broker must register with the Texas Secretary of State (Texas SOS). Information about data broker registrants is available on the Texas SOS website.
Your Privacy Choices for Jornaya | Infutor