California Consumer Privacy Notice/Notice at Collection
Updated April 2024
Table of Contents
- CCPA Privacy Notice at Collection
- Collection and Use
- Sources of Personal Information
- Notice of Right to Opt Out of Sale/Sharing
- Notice of Right to Limit Use of Sensitive Personal Information
- Retention of Personal Information
- Consumer Access Requests
- “Right to Know” Requests
- “Right to Correct” Requests
- “Right to Request Deletion” Requests
- Opt Out Preference Signals
- Non-Discrimination
- Consumers Under 16 Years of Age
- Updates
- Contact Us
Overview
Maintaining the privacy and security of your personal information is TIH’s highest priority. In doing so, we want to provide transparency regarding how and why your data is collected, how it is used, and with whom it may be shared. This TIH California Consumer Practices Privacy Notice/Notice at Collection, (CA Notice) , as well as TIH’s Statement of Online Privacy Practices, set forth how we will interact with your personal information. Specifically, it provides information on how you may exercise your rights under California law. This TIH Notice is directed to consumers who reside in the state of California. That said, all of our clients are welcome to submit questions or requests about their data.
To help ensure transparency around our handling of consumer data, we have established a Consumer Submission template to facilitate requests related to accessing, correcting and potentially deleting your information. This template helps us meet certain legal and compliance requirements such as those under the California Consumer Privacy Act (CCPA). It also provides non-CA clients a mechanism to make similar requests.
CCPA Privacy Notice at Collection
This notice provides further information about our practices, along with details concerning how “Consumer Access” Rights can be exercised: “Right to Know”, “Right to Correct” and/or “Right to Request Deletion” requests may be submitted. This notice is designed to provide additional information not covered elsewhere on our site, and to ensure compliance with the notice provisions of the CCPA.
The following are some general notes about this website practices related to the collection, use and sharing of consumer data.
Collection and Use
It is necessary for us to collect certain personal information from and/or about our consumers and clients in order to provide our products and services, fulfill consumer requests, to comply with the federal and state laws and other legal obligations. Below is a list of categories of data we may collect:
- Personal Information (“information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household,” as defined in the CCPA)
- Demographic/Protected class information
- Commercial information
- Professional or employment-related information
- Education Information
- Geolocation (ex: your IP address when visiting a TIH website)
- Internet or other electronic network activity information
- Marketing opt-out/preference information
- Inferences drawn from any of the above information
It may be necessary for TIH to share certain personal information with affiliates and/or trusted service providers in order to provide our products and services, and to comply with legal and contractual obligations. When engaging such service providers, TIH ensures that such partners will maintain the information in accordance with our privacy and security standards, and only use the data for the use(s) specified in the contract. While certain TIH activities and responsibilities may be outsourced, TIH recognizes and embraces ultimate accountability for the privacy and security of the data entrusted to us.
TIH does not share consumer information with non-affiliated third parties for their marketing purposes. Consumer information will not be shared with third parties (non-service providers) absent prior authorization from the client or their agents. Below are categories of third parties with whom we share personal information:
- Affiliates and other entities in the TIH family
- Service Providers that provide various services to us
- Other parties when you authorize or direct us to share your information
- Government entities and other third parties as needed for legal or similar purposes
- Ad servers, networks, & exchanges
- Social media platforms
- Online publishers
- Data analytics providers
- Data providers and aggregators
- Advertising services platforms
- Market research companies
- Consumer survey companies
Purpose for Collection and Use
We collect information directly from you and from other sources in order to provide the products and services you have requested, , maintain operational functions, to determine your eligibility for other products and services or to comply with federal and state laws and other legal obligations. In the past 12 months, we may have collected and used personal information for the following purposes:
- Deliver, manage, and support products and services (ex: account information, statements, notifications);
- Manage business operations;
- Meet legal, regulatory, or compliance requirements;
- Manage fraud and financial crimes;
- Support and optimize channels and interactions (ex: improving website performance);
- Identify and recommend new products and services;
- To manage hiring and ongoing employment, and to manage teammate / organizational performance and staffing
- Perform services on behalf of another entity or business;
- Provide employee benefits and other services (ex: retirement, health, manage hiring, employment, performance, and staffing).
Sources of Personal Information
We may collect personal information about you from various sources in the course of providing products and services to you. Below is a list of the categories of sources from which we may obtain data:
- Directly from you or your family, guardians/representatives;
- Outside service providers, vendors, and third parties (such as insurance companies, intermediaries, brokers, or agents) from which we
- collect personal information or market data as part of providing products and services, completing transactions, or supporting operations;
- Outputs from analytics;
- Websites, mobile applications, and social media;
- Our affiliates or subsidiaries;
- Public records or publicly available data.
Notice of Right to Opt Out of Sale/Sharing
You may at any time direct TIH to stop selling or sharing your personal information, which is called the “Right to Opt Out.” Once you make an opt out request, TIH will comply within 15 business days and will wait at least 12 months before asking you to reauthorize sales or sharing. You may exercise your right to opt out of sale/sharing by clicking the Do not sell or share my personal information link in the banner on the bottom of the TIH home page or by enabling a preference signal, described further in the section titled “Opt Out Preference Signals.
Notice of Right to Limit Use of Sensitive Personal Information
TIH only collects/processes sensitive personal information for permissible purposes that do not infer characteristics about a consumer, therefore there is not an opt out for the use of sensitive personal information.
Retention of Personal Information
TIH has established product and business-level criteria for retention and disposal according to business requirements, laws, regulations, and applicable industry standards.
Consumer Access Requests
Consumers may exercise their “Right to Know” under the CCPA to request that TIH disclose categories of information we may have collected about them over the last 12 months, the categories of sources from which that information was collected, the business or commercial purpose(s) for which the information was collected, and the categories of third parties with whom we share personal information.
“Right to Know” Requests
Consumers may exercise their “Right to Know” under the CCPA to request that TIH disclose certain information we may have collected about them over the last 12 months, the categories of sources from which that information was collected, the business or commercial purpose(s) for which the information was collected, and the categories of third parties with whom we share personal information.
“Right to Correct” Requests
You have the right to request correction of inaccurate information maintained by TIH. In many instances, such updates are best made by calling 866-858-5158. Some corrections may require specific documentation to be provided as required by law. If you provide us documentation, it will only be used or maintained for the purpose of correcting the information and complying with our recordkeeping requirements under the CCPA.
“Right to Request Deletion” Requests
You have the right to request deletion of personal information that TIH has collected, subject to certain exceptions. For example, we may deny your request if retaining the information is necessary for us to complete a transaction you requested or comply with our legal obligations.
Consumers are welcome to submit requests for more information:
- Submit a data access request for yourself
- Submit a data access request on behalf of another individual
- Submit a data access request on behalf of a company
Consumers are also welcome to submit requests by calling 866-858-5158.
All requests must be verified prior to receiving a response, using TIH authentication protocols. Requesters will be asked to supply certain basic Personal Information to enable us to validate the requestor is the consumer who is subject to the request, such as name, social security number and address. Information submitted for verification purposes will only be used to verify the requestor’s identity and/or authority to make a request on another’s behalf.
Requests made on another person’s behalf can only be accepted upon receipt of documentation that the requestor is an authorized agent, parent or legal guardian of the consumer whose information is being requested. This will require the submission of a valid Power of Attorney, Birth Certificate, approved TIH authorization form, Guardianship Order or other court order granting authority to receive information, as appropriate.
Upon submission of a request, CA consumers will receive an initial response confirming receipt within 10 days. A full response will be provided to CA consumers within 45 days (unless an extension of up to 45 additional days is requested, upon which the consumer will receive notice and an explanation for the extension).
Opt Out Preference Signals
Your internet browser may give you more control over your privacy preferences via a Global Privacy Control (GPC) signal. This is a setting in your browser that notifies the websites you visit of your preferences to opt out of selling or sharing your personal information under California law. If you have opted out via the GPC signal, sites will recognize this signal and process your preference automatically as it pertains to tags, cookies and pixels that collect personal information when you visit TIH websites. Please note, you will need to enable the signal on each browser that you use, as the signal is processed at the browser-level and is not applied if you visit TIH websites from a different browser or device that does not have the GPC signal enabled. When you have been authenticated into the TIH website from a browser which is GPC enabled, TIH will automatically apply that opt out preference to offline data that we have about you. To opt out without GPC enabled, see the section Notice of Right to Opt Out of Sale/Sharing above.
Non-Discrimination
The submission of a “Right to Know”, “Right to Correct” or “Right to Request Deletion” request or exercising any of the above rights, will have no impact nor will it result in retaliation against an employee, applicant, or independent contractor.
Consumers Under 16 Years of Age
TIH does not knowingly sell the personal information of minors under the age of 16 or share such information for cross-contextual advertising.
Updates
This California Consumer Privacy Notice may be revised from time to time, so please review this page periodically. Any changes will become effective when we post the revised notice on the site (please note the effective date listed at the bottom of this page). If we revise this or other privacy notices in a manner that materially changes our privacy practices, we will provide conspicuous notice on our website.
Contact Us
If you have any questions or comments on this notice or our privacy practices generally, please contact us at 866-858-5158.