PRIVACY POLICY – YOUR PRIVACY RIGHTS

Interactive Communications International, Inc.

  • We are committed to safeguarding the privacy of our website visitors.
  • This policy describes how we treat personal information we collect on the websites where this policy appears. This includes our mobile websites and apps where this policy appears.
  • Certain of our platforms may also contain a privacy policy of a bank servicing one or more of our products. To learn about the privacy practices of these banks (which may differ from our privacy practices), please refer to the bank’s policy.
  • We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services we will ask you to consent to our use of cookies when you first visit our website. Cookies do not typically contain any information that personally identifies a user.

We collect information from and about you.

  • The device a person uses to browse our sites or third-party sites or to access our apps (e.g., the operating system or browser version and the type of device a person uses to open electronic communications from us);
  • The IP address and information related to that IP address (e.g., domain information, the internet provider and general geographic location);
  • Browsing history on our sites or third-party sites or in our apps (e.g., search history, viewed pages, how long a user stays, and how often a user returns);
  • How a user searches for our sites or third-party sites, from which websites a user links to our sites or third-party sites, and which of our partners’ websites a user visits;
  • Which ads or online content from us and our business partners a user views, accesses, or clicks on;
  • A user’s browsing and app use activities over time, and across other websites and apps, following the user’s visit to one of our sites or third-party sites or apps;
  • The likely associations among different browsers and devices;
  • Whether a user opens our electronic communications and which parts a user clicks on; and
  • Mobile device location information (e.g., when a person uses a mobile websites or app to register to receive location-based content).

We collect information in different ways.

  • Site Analytics Cookies, to allow us to understand how people reach and use our sites and track the sites’ performance to provide us with insight into improvements we need to make to our sites and services.
  • Personalized Advertising Cookies, which includes performing retargeting based on a user’s preferences or interests and measuring the effectiveness of ads. For example, we might use a cookie to help prevent a user from seeing the same advertisement multiple times or to measure how many times an advertisement is viewed or clicked on.
  • Web Beacons, to track the actions of users, measure the success of our marketing campaigns and compile statistics about usage of the site and services and response rates. Web beacons may tell us, for example, whether a user has visited our site before or whether a user is a new visitor.
  • Third-Party Analytics, such as Google Analytics, for analytics and service improvement.
  • Flash Cookies, including [e.g., Adobe Flash] and other technologies to collect and store information about a user’s use of the Sites and Services
  • Learn more about these tools and how you can control them, here

We use information as disclosed and described here.

  • We might use your information to customize your experience with us. We may use your information to make our websites and products better.
  • We may use your information to make our website and products better. We may combine information we get from you with information about you we get from third parties.
  • We may use information to protect our company, our customers, or our websites.
  • We use information as otherwise permitted by law.

We may share information with third parties.

  • We will share information within the Interactive Communications International, Inc. family of companies.
  • We will share information with third parties who perform services on our behalf. For example, information with third parties that assist us in marketing our products or services.
  • We may share information if we think we have to in order to comply with the law or to protect ourselves. For example, we will share information to respond to a court order or subpoena. We may also share it if a government agency or investigatory body requests. Or, we might also share information when we are investigating potential fraud. We will also include your information in a winner’s list if you are the winner of a sweepstakes or promotion. This list may be shared publicly.
  • We may share information with any successor to all or part of our business. For example, if part of our business was sold we may give our website use and browsing lists as part of that transaction.

You have certain choices about how we use your information.

  • Do Not Track Disclosure: Some internet browsers allow users to send a “Do Not Track” signal to websites they visit. We do not respond to this signal at the present time.
  • You can control tools on your mobile devices. For example, you can turn off the GPS locator or push notifications on your phone.

These sites and apps are not intended for children.

Our sites and apps are meant for adults. We do not knowingly collect personally identifiable information from children under 13 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 13 has given us information, please email us at incommprivacy@incomm.com. Please mark your inquiries “COPPA Information Request.” Parents, you can also learn more about how to protect children’s privacy online at the Federal Trade Commission’s consumer website.

We may link to third party sites or services we don’t control.

If you click on one of those links, you will be taken to websites or apps we do not control. This policy does not apply to the privacy practices of those websites or apps. Read the privacy policy of other websites and services carefully. We are not responsible for these third-party sites or services

You have certain choices about how we use your information.

  • The Internet is not 100% secure. We cannot promise that your use of our sites will be completely safe. We encourage you to use caution when using the Internet. This includes not sharing your passwords.
  • We keep personal information as long as it is necessary or relevant for our business. We also keep information as otherwise required by law.

Your California Privacy Rights

The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative for a person from whom we collected personal information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Once we receive and confirm your verifiable consumer request, we will disclose to you, upon your request:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request for deletion, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at 833-774-8223
  • Clicking here

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Feel free to contact us if you have more questions.

If you have any questions about this Policy or other privacy concerns, please email us
at incommprivacy@incomm.com. You can also write to us at: InComm, Attn: Chief Privacy Officer, 250 Williams Street NW, 5th Floor, Atlanta, GA 30303 or call us at 833-774-8223.

What we will do if there is an update to this policy.

From time to time we may change our privacy practices. We will notify you of any material changes to this policy as required by law. We will also post an updated copy on our website. Please check our site periodically for updates.

Last updated 21 Aug 2019