Terms Of Service

Effective Date: January 2024 Last Updated: January 1, 2024 See Previous

Privacy Notice

1. About CreditMonitoring HQ

CreditMonitoring HQ and its subsidiaries (“CreditMonitoring HQ,” “we” or

“us”) offers various products and services to businesses and individuals to

assist them in maximizing their everyday life, from financial progress data to

roadside assistance. As a company that handles important personal information

about our customers, we understand that privacy is of fundamental importance.

We are committed to doing our part to protect your privacy and being

transparent about how we collect, process, and use your personal information.

2. About this Policy

This is our global Privacy Notice that describes how CreditMonitoring HQr

collects, uses, and discloses information about you use the “CreditMonitoring

HQ Services,” which include:

• Our mobile applications and Websites, including but not limited to

CreditMonitoringHQ.com, (each a “Site” and collectively, the “Sites”)

• The services offered through our Sites, including our subscription

services plans and one-time offerings

• User Accounts offered in connection with our Sites

• Our communications with you

• Our partner/affiliate relationships

• Our social media pages

• Anywhere we collect information from you and refer to this Privacy Notice.

More information about the Service can be found in our Terms of Service. It

also applies to personal information we collect from third parties about you.

Please read this Notice carefully.

A. The Scope of This Privacy Notice

How we process your personal information depends on the specific

CreditMonitoring HQ Services you use and how you use them. As a result, not

every description about how we process personal information broadly may apply

to you or your personal information. Moreover, some of the personal information

we process is subject to specific regulation, and some users of our

CreditMonitoring HQ Services may have additional rights under applicable laws

depending on where the user resides. Please see our “Supplemental Disclosures”

for additional information about personal information and privacy rights that

may apply to you.

B. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. If we make changes, we

will notify you by revising the date at the top of the policy and, in some

cases, we may provide you with additional notice (such as adding a statement to

our website homepage or sending you a notification). We encourage you to review

the Privacy Notice whenever you access the CreditMonitoring HQ Services or

otherwise interact with us to stay informed about our information practices and

the choices available to you.

3. Information We Collect

The personal information we collect about you depends on the nature and

context of your interaction with CreditMonitoring HQ and its services. It may

also depend on various choices you make about how to use the Services we offer,

the functionality and features you choose or enable, your location, the devices

you us to interact with our services, and applicable law.

A. Information You Provide to Us

We may collect information about individuals in various ways, including

directly from you when you provide it to us, including through online forms,

customer service communications (web, email, or phone), or in other ways. In

some cases, it is necessary for you to provide personal information so that we

can provide you the products and services we offer. The following describes the

type of personal information we collect from you when you interact with the

CreditMonitoring HQ Services and the various contexts in which we collect it.

• Consumer Contact Information. We collect information when you inquire

about our CreditMonitoring HQ Services.

Personal information may include your name, physical address, phone number,

email address, state of residence, and other personal information you provide

to us. We may collect this information via web form, email, over the phone, or

any other method by which you provide it.

• Business Contact Information. We collect information about individuals who

interact with us on behalf of a business or other organization, including

information such as your name, company affiliation, job title, business

address, phone number, business email address, and other personal information

you include in a communication to us.

• Account Information. We collect information when you create an account

with us (or one is created by an organization on the user’s behalf). Personal

information may include a username (which may also be an email address or phone

number) and/or member identification number, password, enrollment and

cancellation dates, and your contact information, along with metrics about how

you use your account.

• Billing Information. We collect billing information in order to process

payment. This may include your payment card numbers, expiration date, billing

address, and transaction information.

• Location Information. In addition to your mailing/billing address, we may

request your location (including your precise geolocation) from you. For

example, we may ask you to provide a location for roadside assistance purposes.

• Vehicle Information. We collect vehicle information related to our

roadside assistance products, in credit reports, and form third parties.

• Telephone Call Recordings. As part of our customer service and quality

assurance commitments, we may record telephonic conversations you have with our

customer service representatives or leave on our voice mailboxes. Personal

information you provide over the phone may be collected in these recordings, as

well as a record of the phone number from which you called.

• Email Notification Information. If you request that we provide you with

email communications, we will collect your email address in order to send you

the requested communications.

• Electronic Communications. If you send us electronic communications

(emails, text/SMS messages, chat messages, etc.) then we will collect personal

information pertaining to that communication. For example, we will collect the

identifiers associated with the electronic communication (email address,

telephone number, IP address, etc.), the content of the communications, and any

personal information provided as part of the communication.

• Resident Information. Some of our CreditMonitoring HQ Services allow you

to provide rental payment information to credit bureaus. Personal information

associated with this reporting includes contact information, resident address,

and rental payment information.

• Debt and other financial information. Some of our CreditMonitoring HQ

Services may give you the option to provide certain debt-related and other

financial information to us in connection with the CreditMonitoring HQ

Services, such as your unsecured debt amount.

• Social Media Content. If you interact with our social media pages, we will

receive information related to those interactions.

• Employment Candidate Information. Individuals applying for employment or

other positions in our workforce may provide personal information in connection

with the candidacy for

employment. Personal information may include contact information, work

history, education history, salary preferences, résumé information, C.V.

• Identity Verification Information. In order to verify your identity prior

to using our Services, we may request personal information including your

Social Security number, Date of Birth, and phone number, and recent residential

history. We submit Social Security numbers to the credit reporting agencies to

accurately identify your credit information.

• Other Personal Information You Provide. If you provide us personal

information other than that described above, we will collect it and use it for

the purposes for which you provide it or other consistent purposes.

B. Information We Collect About You from Others

A primary part of the CreditMonitoring HQ Services we provide requires us to

gather personal information about you from third parties. This section

describes what information we collect from third parties and why we collect it.

• Consumer Reporting Information. Our services provide you with access to

credit information from credit bureaus like Equifax, Experian, and TransUnion.

Much of the personal information we receive about you, including personal

information contained in credit reports and credit scores, we request on your

behalf, and per your written instructions, from credit bureaus. We request

information from the credit bureaus and others to provide some of our

membership products and to present offers based on personal information

contained in your credit profile.

• Social Media Information. We may receive information from you when you

interact with our pages, groups, accounts or posts on social media platforms.

• Rental Payment Records. Some of our CreditMonitoring HQ Services allow us

to obtain personal information related to individuals’ rental payments.

• Identity Verification Information. We may obtain information from identity

verification providers intended to supplement the information you have provided

to us. We use this information to ensure we process data accurately and to

ensure the security of the CreditMonitoring HQ Services.

• Our Partners and Affiliates. We collect personal information about

end-users of our product offerings from our reseller partners and affiliates.

• Our Service Providers. We may receive information from service providers

who help us combat fraud, illegal activity and to help protect your personal

information.

• Third-Party Financial Account Information. By enrolling in a Service that

allows CreditMonitoring HQ to report your rental and/or utility payments or

allows you to track your third-party financial accounts on the Sites, you grant

CreditMonitoring HQ and its third-party providers, such as eCredable or MX

Technologies, Inc., permission to access your third-party financial accounts

designated by you. By using such Services, you agree to the third-parties’

• Publicly Available Information. We collect information from publicly

available sources, such as open government databases.

C. Information We Collect Automatically Through Our Services

We automatically collect certain information about your (and your device’s)

interaction with our Services.

• Usage information. We may collect information about your usage of the

CreditMonitoring HQ Services, such as the pages you viewed, the services and

features you used or interacted with, your browser type and details about any

links or communications with which you interacted.

• Device information. We may collect information about your device such as

Internet Protocol (“IP”) addresses, log information, error messages, device

type, and unique device identifiers. For example, we may collect IP addresses

from you as part of our sign in and security features.

• Information from cookies and other technologies. We use tracking

technologies, including cookies, web beacons, tags & scripts, software

development kids (SDKs) to track and store data about how you interact with our

CreditMonitoring HQ Services. The information may contain your Device

Information, browser information, the URLs of any pages you visit on our

websites, device identifiers, advertising identifiers, and other usage

information. For more information about tracking methods on CreditMonitoring HQ

Services, and how to manage them, read our Cookie Policy below. If your browser

doesn’t accept our cookies, you can’t access certain parts of our websites

(e.g., your account).

4. Cookie Policy.

When you visit our website, you consent to the use of cookies, and other

technologies to collect and

process information in accordance with this Cookie Policy. You may have seen

a pop up asking for your consent to this policy on your first visit to our

Sites. You may withdraw your consent at any time by following the instructions

below.

A. Information We Collect.

When you visit the Sites, our web server will temporarily record certain

information from the device you use to access our Sites, the domain name or IP

address of the requesting computer, the access date, the file request of the

client (file name and URL), the HTTP response code and the Site from which you

are visiting us, the number of bytes transferred during the connection and, if

applicable, other technical information that we use and statistically evaluate

for the technical implementation of the website’s use (such as delivery of the

content, guaranteeing the website’s functionality and security, etc.).

It is necessary to store and process the information referred to above for

the duration of your session in order to deliver our Site content to your

device. We also store some of this information in the log files of our servers.

We will not combine this information with your IP address or other personal

information relating to you except as disclosed below.

We will also use the data described above to draw conclusions about your

interests from your use and to adapt our Site’s offerings according to your

interests (profiling) in order to make our website as user-friendly, safe and

attractive as possible and thus promote the sale of Services.

B. What Is a Cookie?

A browser cookie is a small piece of data that is stored on your device to

help websites and mobile apps remember things about you. Other technologies,

including web beacons, web storage, and identifiers associated with your

device, may be used for similar purposes. In this Policy, we say “cookies” to

refer to all of these technologies. Cookies allow a website to recognize a

user’s device. Cookies allow you to navigate between pages efficiently,

remember preferences and generally improve the user experience for you. They

can also be used to tailor advertising to your interests through tracking your

browsing across websites.

Cookies are one of two variants. Session cookies are deleted automatically

when you close your browser and persistent cookies remain on your device after

the browser is closed (for example to remember your user preferences when you

return to the website). Persistent cookies, also known as permanent cookies,

are cookies that are stored on your hard drive until they expire or until you

delete the cookie.

C. We use the following types of cookies:

• Essential Cookies are required to make our Site function properly and

cannot be turned off in our systems. If you block these cookies, portions of

our Site may not function properly.

• Performance and Functional Cookies allow us to count visits and sources of

traffic on our Sites so we can measure and improve performance and

functionality. They help us know which pages of our Site are most and least

popular and how visitors move around the Site.

• Targeted Advertising Cookies may be set through our Sites by our

advertising partners. They may be used by advertising companies to build a

profile of your interests and show you relevant advertisements on other

websites.

• Social Media Cookies allow you to share information using social media

sharing buttons on social networks like Facebook, Pinterest, Instagram, or

Twitter. This information may then be used by the

social media network to deliver targeted advertising to you.

We may combine information collected automatically (as described above) from

your interactions with our website and your activity on third-party sites with

other data (including personal information).

D. Managing Cookies.

If you wish to opt out of allowing certain cookies, you may do so by

changing your browser settings so that cookies from our Site cannot be set.

Please note that if you delete, block, or otherwise restrict cookies, or use a

different computer or Internet browser, you will need to renew your cookie

management choices.

Most browsers allow you to refuse to accept cookies and to delete cookies.

The methods for doing so vary from browser to browser, and from version to

version. You can however obtain up-to-date information about blocking and

deleting cookies via these links:

• (i)

https://support.google.com/chrome/answer/95647

(Chrome);

• (ii)

https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop

(Firefox);

• (iii)

https://help.opera.com/en/latest/security-and-privacy/

(Opera);

• (iv)

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-

cookies (Internet Explorer);

• (v)

https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-

sfri11471/mac (Safari); and

• (vi)

https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-

privacy (Edge).

5. Behavioral Tracking and Web Session Recording

Technologies on Our Sites.

When you visit our website, we use site visit recordation technologies, to

memorialize site visits, third-party cookies, beacons, tags, and scripts to

help collect the categories of information described above and aggregated

information from your internet browser such as your behavior on our Sites. You

may have seen a pop up asking for your consent to the use of web session

analytics and recording technologies on your first visit to our Sites.

We as well as the third-party entities use Cookies, pixels and other

tracking technology (collectively, “Tracking Technology”) in connection with

our Site for purposes of tracking users’ activities (such as websites visited,

advertisements selected, and pages viewed) after they leave our Site. We and

our third-party partners use this Tracking Technology to target applicable

users with advertisements featuring our products and/or services, as well as

third-party products and/or services, that may be of interest to applicable

users and to collect and analyze data on visitor interactions for our website

to help make the sites more useful to visitors. These technologies collect

information about your interaction with the Services, including the resources

that you access, pages viewed, how much time you spent on a page, and how you

reached our website. We also log the details of your visits to our website and

information generated in the course of using our website, such as mouse

movements, scrolling, API calls, user behavior, tracking errors, links clicked,

clicks, page visits, text entered, how long you spent on a page, and other

details of your actions on our website.

Some of this information is collected through cookies, web beacons, and

other tracking technologies, which may be operated by our partners who assist

us in serving ads or providing other services to you.

We may use following technologies across our Sites:

We use Google Analytics, a web analysis service provided by Google, and some

similar services to better understand your use of our Sites and apps. Google

Analytics collects information such as how often users visit the website, what

pages they visit, and what other sites they used prior to visiting. Google uses

the data to track and examine the use of the Site, to prepare reports on its

activities and share them with other Google services. Google’s ability to use

and share information collected by Google Analytics about your visits to the

Site is restricted by the Google Analytics Terms of Service and the Google

available here.

We use Google Optimize, a web optimization tool by Google that helps

increase conversion rates by working as a platform to build and run A/B test

experiments. Google Optimize allows us to test variants of web sites and see

how they perform. Google’s ability to use and share information collected by

Google Analytics about your visits to the Site is restricted by the Google

We use a tool called

Heap.io

, a

user behavioral analytics product and service, to monitor and improve our

Services by tracking and analyzing your engagement with our Sites.

Heap.io

may collect anonymous data on

our users’ interactions, which includes pages users visit, tracking errors and

events, user behavior, searches users make, users’ IP address and users’ device

information (device model, operating system, and version). For more information

about

Heap.io

’s policies and

practices, please see

Heap.io

’s

https://www.heap.io/privacy

We use a tool called Lucky Orange, a user behavioral analytics product and

service, to monitor and improve our Services by recording and analyzing your

engagement with our Sites. Lucky Orange may collect anonymous data on our

users’ interactions, which includes pages users visit, tracking errors and

events, user behavior, searches users make, users’ IP address and users’ device

information (device model, operating system, and version). For more information

about Lucky Orange’s policies and practices, please see Lucky Orange’s privacy

policy

https://www.luckyorange.com/legal/privacy

We use a tool called Lucky Orange, a user behavioral analytics product and

service, to monitor and improve our Services by recording and analyzing your

engagement with our Sites. Lucky Orange may collect anonymous data on our

users’ interactions, which includes pages users visit, tracking errors and

events, user behavior, searches users make, users’ IP address and users’ device

information (device model, operating system, and version) and provide session

replays and heatmaps. For more information about Lucky Orange’s policies and

practices, please see Lucky Orange’s privacy policy at

https://www.luckyorange.com/legal/privacy

We use a tool called Mouseflow, a website analytics tool that provides

session replay, heatmaps, funnels, form analytics, feedback surveys, and

similar features/functionality. Mouseflow may record your clicks, mouse

movements, scrolling, form fills (keystrokes) in non-excluded fields, pages

visited and content, time on site, browser, operating system, device type

(desktop/tablet/phone), screen resolution, visitor type (first time/returning),

referrer, anonymized IP address, location (city/country), language, and similar

meta data. Mouseflow does not collect any information on pages where it is not

installed, nor does it track or collect information outside your web browser.

If you’d like to opt-out, you can do so at

https://mouseflow.com/opt-out

If you’d like to obtain a copy of your data, make a correction, or have it

erased, please contact us first or, as a secondary option, contact Mouseflow at

[email protected]

For more information, see Mouseflow’s Privacy Policy at

https://mouseflow.com/legal/company/privacy-policy/

We use a tool called

Branch.io

in order to create short and deep links for our Service and analyze the user’s

engagement to these links.

Branch.io

uses cookies and other technologies to collect data on our users’ behavior and

their devices (in particular device’s IP address (captured and stored only in

anonymized form), device type (unique device identifiers), browser information,

geographic location, preferred language used to display our website), among

others.

Branch.io

stores this

information in a pseudonymized user profile. For more information about

branch.io

’s privacy policy please

see

https://branch.io/policies/#privacy

We use a tool called Prove Identity, Inc., that provides digital identity

verification and authentication services to help prevent fraudulent

transactions on our Sites. Prove Identity, Inc. may collect and process

Personal Information you provide on our Sites or applications to help verify

your identity and/or authenticate you into our applications. For more

information about Prove Identity, Inc.’s, please see the privacy policy at

https://www.prove.com/legal/overview#Privacy-Policy

We also use Active Prospect’s TrustedForm, a site visit recordation

technology to memorialize site visits. We use TrustedForm to independently

document users’ consent to be contacted. We use TrustedForm to independently

document users’ consent to be contacted. The TrustedForm Script is embedded on

our website and collects the following information when you interact with the

page(s) where the script is present: page URL, mouse movements and clicks,

contact information inputted by the user, a snapshot of the page, including IP

address of the user’s computer, time on the page, date and time that the

TrustedForm Script was loaded, as well as the date and time of the various user

interactions with the page, and HTTP headers from the user’s browser. For more

information about ActiveProspect’s data use and collection policies and

practices, please see ActiveProspect’s Privacy Policy, located at

https://activeprospect.com/privacy-policy/

These site visit recordation technologies help us provide the best digital

experience, diagnose usability problems, identify areas for improvement, help

personalize user experience on our website, to better understand your

preferences, and operate our business.

We reserve the right to remove or add new analytic technologies.

6. Chat Bot Technology

We may also use third-party service providers, such as Adobe Engage Chat Bot

and Marketo ChatBot to provide chat services for our clients to communicate

with us regarding your account, payments, and other general questions you may

have. As you navigate our websites and use the chat systems with us, we attempt

to protect your privacy to the maximum extent possible. However, some of the

information that we receive through this website and your interactions with the

chat systems may be tracked, such as the date you communicate with us, the last

day you contacted us, and other messages, comments and conversations made

through the chat messages. The chat system collects the information that you

voluntarily type in the chat bot when you initiate a query through the chat

system and respond to a query from the chat system. Additionally, when you are

using our chat system, it collects interactions that you have made into the

chat system while communicating with a customer service representative. You can

maximize the benefits of your privacy partnership with us by making informed

decisions about whether to share personally identifiable information with us

through our website. Third party chat bot systems may capture, record, or

analyze your chat bot communications with us.

Under no circumstances shall CREDITMONITORING HQ be liable for any direct,

indirect, special, incidental, or consequential damages arising out of or in

connection with the use of the chat bots on its Sites. This includes, without

limitation, any damage, loss, or injury caused by error, omission,
interruption,

deletion, defect, delay in operation or transmission, computer virus,

communication line failure, theft or destruction, or unauthorized access to,

alteration of, or use of the chat bot.

While we make efforts to ensure the availability and reliability of the chat

bot, there may be instances where it is unavailable or experiences technical

issues. CREDITMONITORING HQ shall not be held responsible for any inconvenience

or damages arising from such occurrences.

For more information about Adobe’s data use and collection policies and

practices, please review the Adobe Privacy Policy, located at

https://www.adobe.com/privacy/policy.html

7. Your Sensitive Information

We process sensitive personal information about you for limited purposes.

For example:

• We collect your social security number and transmit it to the credit

reporting agencies to ensure that we are providing you with accurate credit

reporting information and not someone else’s information.

• If you enroll your children in our family plan, we collect your child’s

social security number to verify their identity and provide products and

services you request on behalf of your children.

• We require account log-in credentials to ensure the security of your

account. To protect the security of your log-in credentials, we store passwords

in an encrypted and obfuscated format.

• We generally don’t collect or disclose information about your

racial/ethnic origin, religious beliefs, union membership, sexual orientation,

trade union membership, criminal background history, or similar information.

However, such information may be contained within your credit or other report

prepared by a consumer reporting agency. We process this information only to

display it to you. Otherwise, we don’t intentionally collect any sensitive

personal information about you, and we prefer that you not share this

information with us.

8. How We Use Your Personal Information

We use information that we collect about you or that you provide to us,

including any personal information:

• To deliver our CreditMonitoring HQ Services, products, and other

offerings, including information such as insights and recommendations, as

necessary to perform our contract with you.

• To validate your identity as necessary to perform our contract with you.

• To send you important information, such as about your account and

membership options, including

expiration and renewal notices.

• To respond to your requests related to our CreditMonitoring HQ Services.

• To maintain and improve the security and performance of the
CreditMonitoring

HQ Services.

• To anonymize, aggregate, or de-identify your personal information so it

can no longer identify you in

furtherance of our interest in conducting research and analysis.

• To develop and improve our current and future offerings and your

experience.

• To make strategic decisions concerning our business operations.

• To send you promotional offers, advertising, or other marketing content.

• To enforce, and review compliance with, the legal terms that govern our

offerings in furtherance of

our legitimate interest in ensuring adherence to the relevant terms.

• To comply with our legal obligations under applicable laws.

• To protect the rights, safety, and property of CreditMonitoring HQ, our

users, and third parties.

• In any other way we may describe when you provide the information.

• For any other purpose with your consent.

When we process personal information about you to comply with legal

requirements or to perform our obligations under a contract with you or with

our customer through whom you use our offerings, failure to provide such data

may prevent or delay our fulfillment of these obligations.

9. Sharing Your Personal Information

We disclose the categories of personal information described above to the

following categories of persons:

• Our service providers. We share personal information with our third-party

service providers, including vendors, consultants, and other parties who assist

in our operations, and who perform services or functions on our behalf. Our

service providers include companies who support us with marketing, sales, data

storage, web management, communications, software maintenance and support,

analytics, social media, market research, auditing, security, user

verification, localization, and payment processing. Our service providers

process your information subject to contractual terms that restrict their

ability to use your information.

• Our affiliates. We may share personal information with our affiliates to

provide our CreditMonitoring HQ Services and for internal administrative

purposes.

• Our third-party business partners. We may share personal information with

one or more of our third party business partners, such as resellers, event

sponsors, marketing partners (our “Third Party Partners”). This may include

sharing of personal information at a point in time after the personal

information is initially collected.

• Third-party platform advertising. We may share your information with

third-party platform providers who assist us in serving advertising regarding

the CreditMonitoring HQ Services to others who may be interested. We also

partner with third party platforms (such as Facebook and Google) who use

cookies to serve interest based advertising and content on their respective

third-party platforms that may be based on your preferences, location and/or

interests.

• Social networking services and platforms to connect with or share

information publicly, with service providers, or with your contacts on such

services or platforms.

• Affiliate and business transfer. If CreditMonitoring HQ is involved in a

merger, acquisition or asset sale, your personal information may be

transferred. We will provide notice before your personal information is

transferred and becomes subject to a different privacy policy.

• Compliance and harm prevention. We may share personal information as we

believe necessary (i) to comply with applicable law, rules and regulations;

(ii) to enforce our contractual rights; (iii) to investigate possible

wrongdoing in connection with the Site and Services; (iv) to protect and defend

the rights, privacy, safety and property of CreditMonitoring HQ, you or others;

and (v) to respond to requests from courts, law enforcement agencies,

regulatory agencies, and other public and government authorities.

The selection of a Third-Party Partner to acquire your personal information

may be determined by a comparison with available products and services. The

position of each potential purchaser may also be determined primarily by the

price the purchaser is willing to pay for the information (e.g., the higher the

price, the better the purchaser’s position).

We may create aggregated, anonymous or de-identified data from personal

information by removing data components that make the data personally

identifiable to you or through obfuscation or other means. Our use of

aggregated, anonymized, and de-identified data is not subject to this Privacy

Policy.

We may also disclose your personal information to other parties when we have

your consent to do so or when you direct us to, for any purposes requested or

permitted by you.

We may share aggregate, anonymous, or de-identified demographic,

statistical, and other information regarding use of our offerings with third

parties for marketing, analytics, planning, and other purposes. Such

information will not specifically identify any user.

We do not market any products or services to children under the age of

eighteen or knowingly collect any information from children under the age of

eighteen. Parents or legal guardians may provide information about their

children to use certain family plan services. Our Sites are not meant for

children, and we request that individuals under the age of eighteen not provide

personal information through the Sites. If you are under the age of eighteen,

you may not provide personal information to use such as name, address, or email

address, and you may not register for, enroll in, and/or make product

purchases.

10. Your Privacy Rights and Choices

A. Accessing, Updating, and Downloading Your User Account Information.

Depending on your jurisdiction or location of residence, you may have the

right to access, update, and obtain a copy of your personal information. These

rights may be limited in some circumstances by applicable law in your

jurisdiction or location of residence. For example, you do not have the right

to ask us to update information contained in your credit report, since this

information is controlled by the credit reporting agencies (See “Correcting

your Credit Information,” below).

If you have an account with us, you may view and edit some of your personal

information by logging into your account and navigating to the account profile

page. You may also contact us during regular business hours using the

appropriate phone number found below under “Contact Us”.

We may need to verify your identity before completing your request. How we

verify your identity depends on whether you hold an account with us.

• Individuals with CreditMonitoring HQ accounts can verify their identity by

logging into their account.

• Individuals without CreditMonitoring HQ accounts (non-accountholders) will

need to provide information

establishing their identity. We will use this information for verification

purposes only.

Unless required by applicable local law in your jurisdiction or location of

residence, we do not permit agents to submit requests on behalf of individuals.

B. Deleting and Disputing the Accuracy of Your Personal Information.

You have the right to request that we delete personal information we process

about you and close your account. We may retain certain data about you for

legal and internal business purposes, such as fraud prevention, in accordance

with applicable laws. Please note, we are not able to delete any personal

information about you contained in a credit report, credit score, credit

history, or otherwise provided by a credit reporting agency pursuant to the

Fair Credit Reporting Act.

C. Opting-Out of Cross-Contextual Behavioral Advertising.

We may share your personal information with third parties to allow for

targeted advertising to you. These ads may be based on your interactions with

multiple businesses, including ours, and their websites and applications. We do

this so that you see our ads when you visit other websites. You can find out

more about this practice or opt out of your web browsing activity for

interest-based advertising purposes by visiting

https://aboutads.info/choices

You can opt out of Google Analytics by visiting

https://tools.google.com/dlpage/gaoptout

D. Digital Advertising and Analytics Services Provider by Others:

We may allow others to provide analytics services and display advertisements

for our CreditMonitoring HQ Services. These providers (for example, Google

Analytics) may use cookies, web beacons, device identifiers, and other tracking

technologies that collect information about your use of our Services. This

information may be used by us and others to determine the popularity of our
CreditMonitoring

HQ Services, deliver advertising and content targeted to your interests in the

Services, and on other websites, apps, and other services, and to better

understand your online activity.

E. Opting Out of Email and Text Messages.

You can opt-out of certain commercial marketing emails at any time by

clicking the “Unsubscribe” or “Opt-Out” link in the email you received. You can

also email us your opt-out request

[email protected]

We are not, however, able to accept requests to cancel an existing membership

account through email. We may send you other types of transactional and

relationship email communications, such as service announcements,

administrative notices, and surveys, without offering you the opportunity to

opt-out of receiving them. You can opt out of text alerts any time by replying

“STOP,” or any alternative keyword we’ve shared with you. We complete any

opt-out request as quickly as we can. This opt-out request won’t prohibit us

from sending you important nonmarketing notices.

F. Correcting your Credit Information.

Credit Information is provided by one or more of the three major credit

reporting agencies that each provide their own score. If you think there are

errors in your credit report, contact the appropriate credit reporting agency

directly. You are also entitled to a free credit report every year that

includes info from each of the three reporting agencies at

www.annualcreditreport.com

If you wish to dispute the completeness or accuracy of any item of information

contained in your file at a consumer reporting agency, you may do so by

contacting the applicable consumer reporting agency. Information about how to

submit a dispute may be found here:

https://www.consumerfinance.gov/ask-cfpb/how-do-i-dispute-an-error-on-my-credit-report-en-

314/.

G. Do Not Track Signals.

Because the “Do Not Track” browser-based standard signal has yet to gain

widespread acceptance, we don’t currently respond to those signals unless

stated otherwise elsewhere in this Privacy Notice.

11. Data Retention

We will retain your personal information only for so long as necessary to

fulfil the purposes for which we collected it, including for the purposes of

satisfying any legal, accounting, or reporting requirements. To determine the

appropriate retention period for personal information, we consider the amount,

nature, and sensitivity of the personal information; the potential risk of harm

from unauthorized use or disclosure of your personal information; the purposes

for which we process your personal information and whether we can achieve those

purposes through other means; and the applicable legal requirements. In some

circumstances you can ask us to delete your data. In some circumstances we may

anonymize your personal information (so that it can no longer be associated

with you) for research or statistical purposes, in which case we may use this

information indefinitely without further notice to you.

12. Security

We protect your personal information with a series of organizational,

technological and physical safeguards. However, we cannot guarantee the total

and complete security of your personal information. We recommend that you use

complex and unique passwords for your CreditMonitoring HQ accounts. Do not

share your password with anyone. If you have reason to believe your interaction

with us is no longer secure, notify us immediately.

13. Children’s Data

Our Services are not intended for persons under 18 years of age. We do not

knowingly collect or process the personal information of individuals under the

age of 18. If you are a parent or guardian and you believe we have collected

information from your child in a manner not permitted by law, contact us using

the information below and we will remove the data to the extent required by

applicable laws.

14. Supplemental Disclosures

A. Gramm-Leach-Bliley Act Information.

Certain of your personal information is protected by federal law, including

the Gramm-Leach-Bliley Act (“GLBA”). Personal information that is subject to

the GLBA may not be subject to certain of the other laws referenced in this

Section 11. By accessing or using CreditMonitoring HQ Services, you agree to

receive notices about your financial privacy electronically. Please see our

GLBA Policy for more information about your financial privacy.

B. California Privacy Notice

The California Consumer Privacy Act of 2018 and California Privacy Rights

Act of 2020 (together, the “CCPA”) provides California residents with rights to

receive certain disclosures regarding the collection, use, sale, and sharing of

personal information, as well as rights to access, delete, correct, and

restrict the use, disclosure, and sale of certain personal information we

collect about them. Additionally, California residents have the right to

opt-out of the sale/sharing of their personal information, including for

purposes of cross-context behavioral advertising and targeted advertising.

California residents also have the right not to receive discriminatory

treatment for the exercise of their privacy rights under the CCPA. These rights

do not apply to certain personal information that is already subject to certain

federal and state regulation.

The CCPA does not apply to personal information that is already protected by

certain federal privacy laws, including the Fair Credit Reporting Act (FCRA)

and the Gramm-Leach-Bliley Act (GLBA). As such, this California Privacy Notice

does not apply to personal information: (i) obtained from or transmitted to a

consumer reporting agency; (ii) contained in a credit report, credit score, or

credit profile provided by a consumer reporting agency; and (iii) otherwise

regulated under FCRA or GLBA.

This may include personal information obtained in connection with
CreditMonitoring

HQ’s credit monitoring services, identity theft protection and insurance

products, and counseling and advisory services, including debt, student loan,

and refinancing counseling, as well as related CreditMonitoring HQ Services.

Personal Information We Collect For the purposes of this California Privacy

Notice, except where a different definition is noted, “personal information”

means information that identifies, relates to, describes, is reasonably capable

of being associated with, or could reasonably be linked, directly or

indirectly, with a particular California consumer or household. Personal

information does not include (i) publicly available information; (ii) lawfully

obtained, truthful information that is a matter of public concern; (iii)

information that has been de-identified; (iv) or aggregated consumer

information. For purposes of this section, “publicly available information”

includes: information is made available from federal, state, or local

government records information that a business has a reasonable basis to

believe is lawfully available to the general public, either through widely

distributed media, or by the consumer and information that is made available by

a person to whom the consumer has disclosed the information if the consumer has

not restricted the information to a specific audience.

Category of Personal Information Identifiers Personal information categories

listed in the California Civ Code § 1798.80(e) Characteristics of protected

classifications under California or federal law

Commercial information Internet or other electronic activity information

Audio, electronic, or visual information Professional or employment-related

information Education information Examples First and last name; Social Security

and other gover birth; mailing/billing address; state of residence; em device

IDs; advertising identifiers; account userna password; and/or other similar

identifiers.

First and last name; address; telephone number; sig issued identification

numbers; bank account numbe rental payment information, and/or similar payment

and education-related information. Age and/or date of birth Payment histories;

account balances and activity; e services that you have purchased, obtained, or

cons histories, tendencies, and preferences; recent reside payment information;

some vehicle information an unsecured debt amount and related information; an

Cookie identifiers; pixel tags; embedded scripts; ta operating system and

Internet browser type, screen device manufacturer and model, language,

plug-ins, you are visiting; geolocation data, browsing history clicked,

language preferences, patterns of use, and Recordings of calls to or from our
customer

service Company affiliation; job title; business address; bus work history,

and/or other similar information.

Education history Category of Personal Information Examples Inferences about

you Inferences made using the about personal information Sensitive personal

information. Certain types of personal information that we collect, as

described above may constitute “sensitive personal information” under

California law, including:

• Social Security, driver’s license, state identification card, and passport

number; and

• Account log-in and password or other access credentials;

Please note that because of the overlapping nature of certain of the

categories of personal information identified above, which are required by

state law, some of the personal information we collect may be reasonably

classified under multiple categories.

2. How We Use Your Personal Information

We may collect, use, or disclose personal information about you for the

purposes detailed in Sections 3-5 of this Privacy Notice.

3. Sources of Personal Information

We may collect personal information directly from you, as well as from the

categories of sources detailed in Section 3(B) of this Privacy Notice.

We may supplement the information described above with information we obtain

from other sources, including from both online and offline data providers.

4. Disclosure of Personal Information

We disclose the categories of personal information detailed in Section

11(B)(1) above to our service providers for one or more business purposes.

“Business purposes” means the reasonably necessary and proportionate use of

personal information for our operational purposes, other purposes described in

this Privacy Notice, for the operational purposes of our service providers and

contractors, as well as other purposes compatible with the context in which the

personal information was collected.

In addition, we may “sell”/”share” personal information with third parties

to participate in cross- context behavioral advertising, as those terms are

defined by the CCPA. We may also “sell” personal information, as that term is

defined by the CCPA, to our Third Party Partners as further detailed in Section

6 of this Privacy Notice and in the information below. The following table

provides a description of the personal information that we have disclosed for

our business purposes, the personal information that we have sold/shared, and

the categories of third parties that received the personal information.

Personal Information Category Identifiers

Personal information categories listed in the California Civil Code §

1798.80(e) Category of Third-Party Recipients

Business Purpose Disclosures Business services providers, affiliates,

partners, data analytics providers, operating systems, social networks.

Business services providers, affiliates, partners, operating systems, social

networks.

Sales/Sharing

Advertisers Third Party Partners

Third Party Partners

Characteristics of protected classifications under California or federal law

Geolocation Commercial information

Internet or other similar network activity

Audio, electronic, or visual information

Professional or employment- related information

Education information

Inferences drawn from other personal information

Business services providers, affiliates, partners, data analytics providers,

operating systems, social networks.

Business services providers, affiliates, partners, data analytics providers,

operating systems.

Business services providers, affiliates, partners, data analytics providers,

operating systems, social networks.

Business services providers, affiliates, partners, data analytics providers,

operating systems, social networks.

Business services providers, affiliates, partners, data analytics providers,

operating systems, social networks.

Business services providers, affiliates, partners, data analytics providers,

operating systems, social networks.

Business services providers, affiliates, partners, data analytics providers,

operating systems, social networks.

Business services providers, affiliates, partners, data analytics providers,

operating systems, social networks.

Advertisers

Third Party Partners Advertisers

5. Your California Privacy Rights

California residents about whom we have collected personal information have

the right to submit the following requests:

• Right to Know. Right to, up to twice in a 12-month month period, to know

what personal information we collect, use, disclose, and/or sell/share, as

applicable.

• Right to Delete. Right to request under certain circumstances that we and

our service providers and contractors delete the personal information that we

collect about them.

• Right to Opt-Out of Sale/Sharing. Right to opt-out of our sale/sharing of

their personal information, as those terms are defined by the CCPA.

• Right to Correct. The right to request the correction of inaccurate

personal information.

• Right to Limit Use and Disclosure. The right to limit the use or

disclosure of sensitive personal

information to only the uses necessary for us to provide our products and

services to them, or for

certain other authorized purposes.

• Right to Non-Discrimination. The right not to receive discriminatory

treatment for the exercise of

the privacy rights described above.

How to submit a request.

You may exercise any of the rights described in this section by emailing us

[email protected]

.and by calling us at any of the phone numbers under “Contact Us.”

Any request you submit to us is subject to an identification and residency

verification process (“Verifiable Consumer Request”) as permitted by the CCPA.

We will not fulfill your request unless you have provided sufficient

information that enables us to reasonably verify that you are the consumer

about whom we collected the personal information on. In order to verify you,

you must provide us with your first and last name and email address. These

rights are also subject to various exclusions and exceptions under applicable

laws.

We will respond to your request within forty-five (45) days after receipt of

a Verifiable Consumer Request for a period covering twelve (12) months and for

no more than twice in a twelve-month period. We reserve the right to extend the

response time by an additional forty-five (45) days when reasonably necessary

and provided consumer notification of the extension is made within the first

forty-five (45) days. Authorized agents. You may also designate an authorized

agent, in writing or through a power of attorney, to request to exercise the

above rights on your behalf. If you designate an authorized agent to exercise

your various rights under the CCPA, we may require that you provide your

authorized agent with written permission to exercise your various rights and to

verify your own identity with us. If your authorized agent does not submit

proof that they have been authorized by you to submit verified requests, we

reserve the right to deny such a request that we have received and will explain

to your authorized agent why we have denied such request.

The authorized agent may submit a request to exercise these rights by

emailing the letter of authorization or power of attorney to

[email protected]

Household data.

We currently do not collect personal information at the household level. If

we receive a privacy rights request submitted by all members of a household, we

will individually respond to each request. We will not be able to comply with

any request by a member of a household under the age of 13, as we do not

collect personal information from any person under the age of 13.

Direct marketing by third parties.

We do not disclose personal information to third parties for their own

purposes, and you may opt-out of any disclosures of non-identifiable personal

information. However, because California residents have the right to request

information regarding such practices under California’s “Shine the Light” Law,

please contact us using the information provided at the end of this Privacy

Notice under “Contact Us.” You must include your full name, email address and

postal address in your email or mail request so that we can verify your

California residence and respond. “Personal information” under this California

law means any information that identified, described, or was able to be

associated with an individual at the time of disclosure.

We will continue to update our business practices as direct regulatory

guidance becomes available.

6. Notice of Right to Opt-Out

If you wish to opt-out of the “sale”/“sharing” of personal information as

described in Sections 11(B)(4) above, please email us at

[email protected]

call us at any of the phone numbers under “Contact Us.”

For more information about opting out of the “sale”/”sharing” of your

personal information for purposes of cross-context behavioral advertising, see

the Opting-Out Cross-Contextual Behavioral Advertising, section, above. After

12 months, we may ask you if you want to opt into the “sale” of your personal

information.

C. Virginia Privacy Notice

This Virginia Privacy Notice applies to any Virginia residents about whom we

have collected personal information. The provisions contained within this

section are intended to provide notices in compliance with the Virginia

Consumer Data Protection Act (“VCDPA”). Any capitalized term used and not

otherwise defined below has the meaning assigned to it in this Privacy Notice.

The VCDPA provides Virginia residents with rights to receive certain rights

to receive certain disclosures and access regarding collection, use, sale, and

sharing of personal information, as well as rights to delete, correct, and

affirmatively consent to the use, disclosure, and sale of certain personal data

we collect about them. Additionally, Virginia residents have the right to

opt-out of targeted advertising, sale of their personal data, and profiling.

Virginia residents also have the right not to receive discriminatory treatment

by us for the exercise of their privacy rights. This Virginia Privacy Notice

does not apply to certain personal data that is already subject to certain

federal and state regulation.

The VCDPA does not apply to personal information that is already protected

by certain federal privacy laws, including the Fair Credit Reporting Act (FCRA)

and the Gramm-Leach-Bliley Act (GLBA). As such, this Virginia Privacy Notice

does not apply to personal information: (i) obtained from or transmitted to a

consumer reporting agency; (ii) contained in a credit report, credit score, or

credit profile provided by a consumer reporting agency; and (iii) otherwise

regulated under FCRA or GLBA. This may include personal data obtained in

connection with CreditMonitoring HQ’s credit monitoring services, identity

theft protection and insurance products, and counseling and advisory services,

including debt, student loan, and refinancing counseling, as well as related
CreditMonitoring

HQ Services.

1. Personal Data We Collect

For the purposes of this Virginia Privacy Notice, except where a different

definition is noted, “personal data” means any information that is linked or

reasonably linkable to an identified or identifiable natural person. Personal

data does not include de-identified data or publicly available information. For

the purposes of this section, “publicly available information” includes:

information that is lawfully made available through federal, state, or local

government records; information that a business has a reasonable basis to

believe is lawfully made available to the general public through widely

distributed media, by the consumer; and information that is made available by a

person to

whom the consumer has disclosed the information, unless the consumer has

restricted the information to a specific audience.

We may collect personal data from or about you as detailed in Sections 3 and

11(B)(1). Sensitive data.

Certain types of personal data that we collect, as described above, may

constitute “sensitive data” under Virginia law, including:

• Social Security, driver’s license, state identification card, and passport

number;

• Account log-in and password or other access credentials;

• Precise geolocation;

• Racial or ethnic origin, religious or philosophical beliefs, and union

membership; and

• Sexual orientation.

We generally don’t collect or disclose information about your racial/ethnic

origin, religious beliefs, union membership, sexual orientation, trade union

membership, criminal background history, or similar information. However, such

information may be contained within your credit or other report prepared by a

consumer reporting agency. We process this information only to display it to

you. Otherwise, we don’t intentionally collect any sensitive personal data

about you, and we prefer that you not share this information with us. Sensitive

personal information will not be sold or shared and will only be used for

business purposes.

Please note that because of the overlapping nature of certain of the

categories of personal data identified above, which are required by state law,

some of the personal data we collect may be reasonably classified under

multiple categories.

2. How We Use Your Personal Data

We may collect, use, or disclose personal data about you for the purposes

detailed in Sections 3-5 of this Privacy Notice.

3. Sources of Personal Data

We may collect personal information directly from you, as well as from the

categories of sources detailed in Section 3(B) of this Privacy Notice.

We may supplement the information described above with information we obtain

from other sources, including from both online and offline data providers.

4. Disclosure of Personal Data

We disclose the categories of personal data detailed in Sections 11(B)(1)

and 12(B)(1) above to our service providers for one or more business purposes.

“Business purposes” means the reasonably necessary and proportionate use of

personal information, in a way that is adequate, relevant, and necessary for

specific purposes described in this privacy policy, compatible with the nature

and purpose(s) for the collection, use, and retention of the personal data.

In addition, we may “sell” personal data with third parties to participate

in targeted advertising, as that term is defined by the VCDPA, as well as with

our Third Party Partners as described in this Privacy Notice. The personal data

that we have sold and the categories of third parties that have received the

personal data is detailed in Section 11(B)(4).

5. Your Virginia Privacy Rights

If you are a Virginia resident, you have the following rights under

applicable Virginia law in relation to your personal information, subject to

certain exceptions:

• Right to Know. You have the right to, up to twice in a 12-month period,

request what personal data we collect, use, disclose, and/or sell, as

applicable;

• Right to Delete. You have the right to request under certain circumstances

that we delete your personal data.

• Right to Opt-Out. You have the right to opt-out of targeted advertising,

our sale of your personal data, and profiling decisions that could produce

legal or similarly significant effects.

• Right to Correct. You have the right to request the correction of your

inaccurate personal data.

• Right to Data Portability. When accessing your data, you have a right to

obtain that data in a

portable and, to the extent technically feasible, readily usable format that

allows you to transmit that

data to another business.

• Right to Provide Affirmative Consent. We cannot process your sensitive

data or use your

personal data for certain purposes without your affirmative consent.

• Right to Non-Discrimination. You have the right to not receive

discriminatory treatment for the

exercise of the privacy rights described above.

How to submit a request.

You may exercise any of the rights described in this section by emailing us

[email protected]

.and

by calling us at any of the phone numbers under “Contact Us.”

Any request you submit to us is subject to an identification and residency

verification process (“Verifiable Consumer Request”) as permitted by the VCDPA.