Privacy Policy
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This Privacy Policy governs how National Disability Alliance, its affiliated entities, and its partnered professional corporations (“we”, “our”, “us”) collect, store, and use your personal data (as defined below), as well as other data and information arising out of and/or relating to you and/or your use of nationaldisabilityalliance.com and any related websites (the “Sites”) and any other technologies, features, mobile applications, content, and other services we offer (collectively, the “Services”).
Although we are not a health care provider and are not a covered entity under HIPAA, in some cases we may be a “business associate” to covered entities under the Health Insurance Portability and Accountability Act (“HIPAA”), and as such we may have certain federal, state, and contractual restrictions on how we can use your health or medical information (collectively, your “Protected Health Information” or “PHI”). With respect to any PHI that we receive from covered entities, we will comply with our obligations under HIPAA as a business associate. This Privacy Policy is not intended to include information about how we handle HIPAA-regulated personal health information (“PHI”). We encourage you to review the privacy policies and notices of privacy practices of your health care provider or other covered entity with which we may partner.
We may also collect, store, and use personal data (defined below) that is linked or reasonably linkable to you and that identifies your past, present, or future health status or mental health status, as may be applicable (“consumer health data”). If you are a resident of Connecticut, Nevada, or Washington, we provide information about consumer health data collected about you, as well as the rights you may have related to this data, in our Consumer Health Data Privacy Notice.
This Privacy Policy does not apply to third-party websites, applications, products, services, or other properties, even if they may link to our Sites or our Sites may link to them. We recommend you review the privacy practices of those third parties before connecting with and/or accessing third-party offerings, and before sharing any personal data with those third parties.
If you are a visually-impaired individual, an individual with another disability, or seek support in another language, you may access this Privacy Policy by emailing us at privacy@ndallc.com.
Linkable Table of Contents
It is important that you read and understand the entire Privacy Policy before using our Services. For ease of review, below is a table of contents that links to each section. You can click on the headings to be taken to the full explanation.
1. Personal Data We May Collect, Use, and Disclose | We collect, use, and disclose information that may be used to uniquely identify you in various ways in accordance with applicable law. |
2. Sources of Personal Data | We may collect personal data from various sources. |
3. Disclosure of Personal Data | We may disclose your personal data to certain third parties, such as Government Disability Agencies, our service providers, and our advertising partners. |
4. Cookies & Other Tracking Technologies | We collect information about your use of our Sites through cookies and other tracking technologies. |
5. Data Security | We use reasonable and appropriate technical and organizational measures to protect your personal information. |
6. Data Retention | We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy, and use reasonable and appropriate technical and organizational measures to protect your personal data. |
7. International Transfers of Data | If you are located outside of the United States and choose to provide information to us, we transfer the data to the United States and process it there. |
8. Children’s Privacy | Our Services are not intended for use by children under the age of 18, but we may collect certain data from parents or guardians. |
9. Your Choices & Rights | We explain how you may exercise choices and rights related to your personal data. |
10. California Privacy Notice | We provide additional disclosures and rights to California residents. |
11. Nevada Privacy Notice | We provide additional disclosures and rights to Nevada residents. |
12. Privacy Notice for Residents of Other States | We provide additional disclosures and rights to residents of certain other states. |
13. Changes to This Policy | Changes to this Privacy Policy will become effective on the date they are posted. |
14. Contact Us | You may contact us for comments or questions in various ways. |
* * *
1. Personal Data We May Collect, Use, and Disclose
“Personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual. Personal data includes “personal information” as that term is defined in applicable privacy laws.
Personal data does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified, or aggregate consumer information. “Publicly available information” includes information that 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 individual; and information that is made available by a person to whom the individual has disclosed the information if the individual has not restricted the information to a specific audience.
“Self-Reported Information” refers to personal data that you provide directly through your interactions with us, including without limitation when you provide us information for us to assess your eligibility for/represent you in claim(s) for Social Security Disability Insurance (SSDI) and/or Supplemental Security Income (SSI) benefits before the Social Security Administration (SSA); acquire medical records, forms or narratives from medical treating sources, or special medical or vocational examinations; use the Services; or otherwise contact us. Note that personal data collected via Cookies & Other Tracking Technologies is not categorized as Self-Reported Information for the purposes of this Privacy Policy.
We may create aggregated, de-identified, or anonymous information from data by removing certain data components (such as your name, email address, or linkable tracking identifier) that make the data identifiable, or through aggregation, obfuscation or other means. Subject to applicable law, our use and disclosure of such aggregated, de-identified, or anonymized information is not personal data or subject to this Privacy Policy.
Category of Personal Data |
Processing Purposes |
Categories of Third-Party Recipients (excluding our service providers and processors) |
Identifiers, including: ● Name ● Address ● Email address ● Phone number ● Date of birth ● Signature ● Certain social media account information including user ID ● IP address ● Unique device identifiers ● Mobile app identifiers ● Device operating system information |
● Contact you and provide information ● Assess your eligibility for/represent you in claim(s) for Social Security Disability Insurance (SSDI) and/or Supplemental Security Income (SSI) benefits before the Social Security Administration (SSA) ● Provide customer service ● Develop, provide, and maintain our Services, including for training purposes related to our own artificial intelligence technology ● Facilitate interactive features ● Internal analytics ● Market our products and Services directly to you ● Internal business purposes, including general business administration ● Audit, compliance, legal, policy, procedure, and regulatory obligations ● Customer claims and fraud investigation and prevention ● Systems and data security ● Protecting the safety of our employees and others ● Targeted Advertising● Any other purpose consistent with your consent, expressed preferences, and/or applicable law |
● Third-party advertising platforms ● Third-Party Business Partners (defined below in Section 3) ● Government Disability Agencies (defined below in Section 3) and legal representatives ● Insurance brokers |
Commercial information, including: ● Information about your interests and preferences |
Same purposes as noted for “Identifiers” |
● Third-party advertising platforms ● Third-Party Business Partners |
Financial information, including ● Bank account number ● Income and compensation information ● Any other financial information |
● Assess your eligibility for/represent you in claim(s) for Social Security Disability Insurance (SSDI) and/or Supplemental Security Income (SSI) benefits before the Social Security Administration (SSA) to facilitate direct payment of claimant’s benefits by the U.S. Department of the Treasury ● Provide and maintain our Services ● Internal business purposes, including general business administration ● Any other purpose consistent with your consent, expressed preferences, and/or applicable law |
● Government Disability Agencies and legal representatives |
Internet or other electronic network activity information, including:
|
Same purposes as noted for “Identifiers” |
● Third-party advertising platforms ● Third-Party Business Partners |
Geolocation data, including:
|
Same purposes as noted for “Identifiers” |
● Third-party advertising platforms ● Third-Party Business Partners |
Professional or employment-related information, including:
|
Same purposes as noted for “Identifiers” |
● Third-party advertising platforms ● Third-Party Business Partners ● Government Disability Agencies and legal representatives |
Audio, electronic, visual, or similar information, including:
|
Same purposes as noted for “Identifiers” |
● Third-Party Business Partners |
Characteristics of protected classifications, including:
|
● Assess your eligibility for/represent you in claim(s) for Social Security Disability Insurance (SSDI) and/or Supplemental Security Income (SSI) benefits before the Social Security Administration (SSA) ● For internal business purposes, including general business administration ● Develop, provide, and maintain our Services, including for training purposes related to our own artificial intelligence technology ● Any other purpose consistent with your consent, expressed preferences, and/or applicable law |
● Third-party advertising platforms ● Third-Party Business Partners ● Government Disability Agencies and legal representatives |
Sensitive data, including:
(Residents of Connecticut, Nevada, and Washington should review our Consumer Health Data Privacy Policy for more information) |
● Assess your eligibility for/represent you in claim(s) for Social Security Disability Insurance (SSDI) and/or Supplemental Security Income (SSI) benefits before the Social Security Administration (SSA) ● For internal business purposes, including general business administration ● Develop, provide, and maintain our Services, including for training purposes related to our own artificial intelligence technology ● Any other purpose consistent with your consent, expressed preferences, and/or applicable law |
● Third-party advertising platforms ● Third-Party Business Partners ● Government Disability Agencies and legal representatives |
Inferences about you using any of the above |
Any of the above purposes |
● Third-party advertising platforms ● Third-Party Business Partners ● Government Disability Agencies and legal representatives |
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. Sources of Personal Data
We may collect personal data about you from the following categories of sources:
- Directly from you through Self-Reported Information.
- From potential and current clients, if they list you as a spouse, child, dependent, or prior employer in their claim(s) for Social Security Disability Insurance (SSDI) and/or Supplemental Security Income (SSI) benefits before the Social Security Administration (SSA).
- Through cookies and other tracking technologies, as discussed in more detail in Cookies & Other Tracking Technologies.
- From other third parties, including service providers, business and marketing partners, affiliates, analytics providers, ad network providers, ad agencies, and advertisers.
- From government agencies or public records.
- From social media and other content platforms, such as Google and Meta, if you interact with us on these platforms.
3. Disclosure of Personal Data
We may disclose personal data that we collect to the following, consistent with applicable law:
- Our affiliates. We may disclose personal data among our affiliates to provide our Services, and for internal administrative purposes.
- Our service providers. We disclose personal data with our service providers to provide services on our behalf, such as payment processing, analytics, advertising, hosting, marketing, customer and technical support, and other services. These third parties are aligned with our commitment to safeguarding your information, and have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use the information for any other purpose.
- Third-party platform advertisers. We may partner with third parties 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.
- Third parties related to compliance and harm prevention. Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities, and/or in response to a threat of harm involving an individual’s health and/or safety.
- Third parties related to a change of ownership. If we or our subsidiaries are involved in a merger, acquisition, asset sale, or other corporate combination, your personal data may be transferred to the acquiring or surviving entity; provided, your text messaging originator opt-in and consent data and information will not be shared with any third parties under any circumstances.
- Government Disability Agencies and legal representatives. We may also provide personal data to federal and state government agencies, including the Social Security Administration (“SSA”) and state disability offices (collectively, “Government Disability Agencies”) and third-party legal representatives to submit your application(s).
- Third-Party Business Partners. We may disclose personal data to our third-party business partners, which may include joint marketing partners, information aggregators, business intelligence companies, and affiliate marketing partners (collectively, “Third-Party Business Partners”).
- Third party insurance brokers. At the conclusion of your claim, we may provide the option connect you with a third-party insurance broker to explain Medicaid options and to sign up for such benefits. If you elect to be connected with a third-party insurance broker, we provide the broker with certain personal data.
4. Cookies & Other Tracking Technologies
We use cookies and similar tracking technologies and analytics services to track activity on and gauge the effectiveness of our Services. Cookies are files with a small amount of data which may include unique identifiers. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.
a. Examples of cookies we use
- Strictly Necessary. We may use cookies that we consider are strictly necessary to allow you to use and access our website, including cookies required to prevent fraudulent activity or improve security.
- Performance. We may use cookies that are useful to assess the performance of our website, including as part of our analytic practices or otherwise to improve the content, products or Services offered through our website.
- Functionality. We may use cookies that are required to offer you enhanced functionality when accessing our website, including identifying you when you sign in to our website or keeping track of your specified preferences, including in terms of the presentation of content on our website.
- Advertising. We may use cookies to deliver content, including ads, relevant to your interests on our website and third-party sites based on how you interact with advertisements or content.
b. Analytics
We may use Google Analytics or other service providers for analytics services. These analytics services may use cookies and other tracking technologies to help us analyze how users use the Services. Information generated by these services (e.g., your IP address and other usage information) may be transmitted to and stored by Google Analytics and other service providers on servers in the U.S. (or elsewhere) and these service providers may use this information for purposes such as evaluating your use of the Service, compiling statistical reports on the Service’s activity, and providing other services relating to Service activity and other Internet usage. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.
c. Third-Party Ad Networks
Certain companies may participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for Interest-based Ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com/ and its opt-out program for mobile apps at http://www.aboutads.info/appchoices.
In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt out of certain Interest-based Ads delivered by NAI members’ ad networks. To learn more about opting out of such targeted advertising or to use the NAI tool, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Ads, you will continue to receive non-targeted ads. Opting out of one or more NAI or DAA members only means that those selected members should no longer under the DAA/NAI rules deliver certain targeted ads to you. This will affect this and other services, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). If your browsers are configured to reject Cookies when you visit this opt-out page, or you subsequently erase your Cookies, use a different device or web browser(s), or use a non-browser-based method of access (e.g., mobile app), your NAI/DAA browser-based opt-out may not, or may no longer, be effective. Mobile device opt-outs will not affect browser-based Interest-based Ads even on the same device, and you must opt out separately for each device. 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.
5. Data Security
The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. We maintain appropriate technical, administrative and physical safeguards to help protect the security of your personal data against unauthorized access, destruction, loss, alteration, disclosure or misuse.
6. Data Retention
We will retain your personal data only for as long as is necessary to provide you with Services, to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain certain personal data for internal analysis purposes. This information is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable given our legal position, including with regard to applicable statutes of limitations, litigation, or regulatory investigations.
7. International Transfers of Data
Our Sites are operated exclusively in the United States and intended for users located in the United States. We may transfer, store, and use information we collect and maintain about you, including personal data outside of your state, province, country or other governmental jurisdiction. The data protection laws in the jurisdiction in which we process personal data may differ from those of your jurisdiction, and in certain circumstances, your personal data may be subject to access requests from governments, courts, law enforcement agencies or regulatory agencies in those other jurisdictions.
8. Children’s Privacy
Our Services are not intended for children under the age of eighteen (18) years and we do not knowingly collect information from such persons. However, we may collect personal data about children under the age of 18 from parents or guardians who are submitting claims on their own behalf or on behalf of their children, in accordance with applicable law.
If you become aware that a child has provided us with personal data, we strongly encourage you to Contact Us immediately, and we will do our best efforts to promptly remove such information from our records.
9. Your Privacy Choices & Rights
You may have certain choices and rights regarding our collection, use, and disclosure of your personal data, based on your location or place of residency.
a. Opting out of promotional electronic communications from us.
We may use your personal data to send you updates regarding our Services, other announcements, and inquiries. If you no longer wish to receive promotional email communications from us, you may opt out via the unsubscribe link included in such emails or Contact Us. We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required to provide you with the Services or for other reasons disclosed in this Policy.
b. Opting out of SMS messages.
We may send you SMS messages to conduct your case review. To cancel the SMS service at any time, text “STOP” to any text message you receive or Contact Us. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have unsubscribed. After this, you will no longer receive SMS messages from us. If you are experiencing issues with the messaging program you can text “HELP” for more assistance, or you can Contact Us.
c. Additional rights available in certain states and jurisdictions.
Certain U.S. jurisdictions provide residents with certain rights with respect to their personal data. These rights are subject to the specific laws of that jurisdiction and that certain other rights might apply. Please review our California Privacy Notice; Nevada Privacy Notice; Privacy Notice for Residents of Other States; and Consumer Health Data Privacy Notice for more information on rights and terms specific to your location or place of residence.
d. Exercising your privacy rights.
Please use the following information to exercise your rights. Please note that any request you submit to us is subject to an identification and residency verification process as permitted under applicable law, as well as certain other procedural requirements that may be noted in the sections below. Additionally, all requests are subject to certain exceptions under applicable law, which may vary. If you are a visually-impaired customer, a customer who has another disability or a customer who seeks support in another language, you may access your privacy rights by emailing us at privacy@ndallc.com.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, manifestly unfounded, or in accordance with applicable law. 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.
Depending on applicable law, you may be limited in how many verifiable or authenticated consumer requests you may make within a twelve (12) month period. If we have inadvertently collected information on your minor child, you may exercise the above rights on behalf of your minor child. Additionally, in some jurisdictions, you may designate an authorized agent to submit a request on your behalf, and if so, we may require proof of the agent’s authorization by you and/or verification of the agent’s own identity. Generally, a rights request must include:
- Sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative, which must include, at a minimum, your first and last name and email address.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to the request.
We cannot respond to your request or provide you with personal data if we cannot verify or authenticate your identity or authority to make the request and confirm that the personal data relates to you. We will only use personal data provided in a verifiable or authenticated consumer request to verify your (or your authorized agent’s, as applicable) identity or authority to make the request.
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact privacy@ndallc.com. Except where otherwise noted, we will respond to your request within forty-five (45) days after receipt and 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. As described below, in some jurisdictions, an authorized agent may submit a request to exercise your rights on your behalf.
How to submit a request. To exercise any of the rights described in this Privacy Policy, please email us at privacy@ndallc.com.
10. California Privacy Notice
This California Privacy Notice applies to any California residents about whom we collect personal data. The provisions contained within this section are intended to provide notices in compliance with the California Consumer Privacy Act of 2018 and other relevant California laws and regulations.
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 resident or household. Personal information does not include publicly available information, information that has been de-identified or aggregated, or other information subject to certain federal and state regulations.
Please note that we are providing the following disclosures and rights regarding personal information in this section in the interest of transparency and our commitment to privacy; such disclosures and rights are not intended to waive any applicable exemptions under the CCPA.
If you are a visually-impaired individual, an individual who has another disability or an individual who seeks support in another language, you may access your privacy rights by emailing us at privacy@ndallc.com.
a. Personal Information We Collect
We may collect, or have collected, the following categories of personal information:
- Identifiers
- Commercial information
- Financial information
- Internet or other electronic activity information
- Geolocation data
- Professional or employment-related information
- Audio, electronic, visual, or similar information
- Characteristics of protected classifications under California or federal law
- Inferences drawn from any of the above
Certain of the personal information that we collect may constitute “sensitive personal information” as defined by California law. This may include:
- Social Security number
- Racial or ethnic origin, citizenship, or immigration status
- Personal data collected and analyzed concerning health
b. How We Use Your Personal Information
We use the personal information we collect about you for the following purposes:
- Contact you and provide information
- Assess your eligibility for/represent you in claim(s) for Social Security Disability Insurance (SSDI) and/or Supplemental Security Income (SSI) benefits before the Social Security Administration (SSA)
- Provide customer service
- Develop, provide, and maintain our Services, including including for training purposes related to our own artificial intelligence technology
- Facilitate interactive features
- Internal analytics
- Market our products and Services directly to you
- Internal business purposes, including general business administration
- Audit, compliance, legal, policy, procedure, and regulatory obligations
- Customer claims and fraud investigation and prevention
- Systems and data security
- Protecting the safety of our employees and others
- Targeted advertising
- Any other purpose consistent with your consent, expressed preferences, and/or applicable lawc. To Whom We Disclose Personal Data
We limit our disclosure of the categories of personal data above to our service providers for one or more business purposes. “Business purposes,” means the reasonably necessary and proportionate use of personal data for our operational purposes, other purposes described in this Privacy Policy, for the operational purposes of our service providers and contractors, as well as other purposes compatible with the context in which the personal data was collected.
We gather personal data from consumers via Cookies as part of our targeted advertising initiatives, which is technically considered a “sale” and/or “share” of personal data under California law, even though we do not receive monetary payment for sharing or disclosing personal data to these third parties We may also “sell” and/or “share” personal data to Third-Party Business Partners. During last 12 months (from the last updated date listed at the top of this Privacy Policy), we have “sold” or “shared” the following categories of personal data as those terms are defined under the CCPA, in accordance with applicable law:
- Identifiers
- Commercial information
- Internet or other electronic network activity information
- Geolocation data
- Professional or employment-related information
- Characteristics of protected classifications under California or federal law
- Inferences drawn from any of the above
- Sensitive data
e. Your California Privacy Rights
If you are a California resident, you have the following rights under applicable California law:
- Right to know and access. You have the right to know what personal information we collect, use, disclose, and sell and/or share, as those terms are defined under applicable law. You may ask us to provide you with a portable copy of this information up to two times in a rolling twelve-month period.
- Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal information that we collect about you.
- Right to correct. You have the right to request the correction of inaccurate personal information.
- Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
- Right to opt out of sale and/or sharing. You have the right to opt out of the sale and/or sharing of your personal information.
- Right to limit use and disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide goods or services to you. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
- Sharing with third parties for their own direct marketing purposes. We do not disclose personal information to third parties for their own purposes without your consent. If you wish to request information regarding such practices under California’s “Shine the Light” Law, please 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.
How to exercise your rights. You may exercise any of the rights described in this section by following the instructions in Your Privacy Choices & Rights.
f. Notice of Right to Opt Out of Sale/Sharing
You have the right to opt out of the sale and/or sharing of your personal data by a business. As noted above, we may “sell” and/or “share” your personal data for purposes of cross-context behavioral advertising. You may optout by following the instructions in Your Privacy Choices & Rights.
We do not knowingly sell or share the personal data of minors under 16 years of age without legally-required affirmative authorization. If you believe that your child has provided us with information, please review Children’s Privacy and Contact Us.
g. Retention of Personal Information
We will retain your personal data only for as long as is necessary for the purposes set out in this Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain certain personal data for internal analysis purposes. This information is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.
Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable considering our legal position, including with regard to applicable statutes of limitations, litigation or regulatory investigations.
11. Nevada Privacy Notice
We may “sell” certain personal data as defined by Nevada Law. Nevada residents have the right to request to opt out of any “sale” of their personal data under Nevada SB 220. If you are a Nevada resident and would like to make such a request, please follow the instructions in Your Privacy Choices & Rights. You must include your full name, email address, and postal address in your email or mail request so that we can verify your Nevada residence and respond. In the event we sell your personal data after the receipt of your request, we will make reasonable efforts to comply with such request.
Additionally, SB 370 provides Nevada residents with rights to receive certain disclosures and access regarding the collection, use, sale, and sharing of consumer health data. For information regarding the Consumer Health Data that we collect, how we use it, what sources it is derived from, to whom we disclose it, as well as the rights of Nevada residents and our responsibilities under SB 370, please see our Consumer Health Data Privacy Notice.
12. Privacy Notice for Residents of Other States
This Privacy Notice contains additional information for residents of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia about personal data that we collect, how we use it, what sources it is derived from, and to whom we disclose it, and provides information regarding your rights, and our responsibilities, under applicable laws and regulations. For the purposes of this section, “personal data” means information that is linked or reasonably linkable to an identified or identifiable individual. Personal data does not include de-identified data or publicly available information. This section does not apply to certain personal data that is already subject to certain federal and state regulations, such as protected health information.
The provisions contained within this section are intended to provide notices in compliance with the Colorado Privacy Act, the Connecticut Data Privacy Act, the Delaware Personal Data Privacy Act, the Iowa Consumer Data Protection Act, the Maryland Online Data Privacy Act, the Minnesota Consumer Data Privacy Act, the Montana Consumer Data Privacy Act, the Nebraska Data Privacy Act, the New Hampshire Privacy Act, the New Jersey Privacy Act, the Oregon Consumer Data Privacy Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the “State Privacy Laws”).
The State Privacy Laws provide or will provide rights to residents of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia respectively, to receive certain disclosures and access regarding the collection, use, sale, and sharing of personal data.
a. Our Personal Data Practices
The State Privacy Laws provide rights to residents of those states, to receive certain disclosures and access regarding the collection, use, sale, and sharing of personal data. Detail about what kinds of personal data we may collect or have collected, how we collect it, why we collect it, and to whom we may disclose it is found in Personal Data We May Collect, Use, and Disclose; Sources of Personal Data; and Disclosure of Personal Data.
We may “sell” and/or “share” personal data with third party advertising networks and platforms for purposes of providing targeted behavioral advertising on those platforms and to Third-Party Business Partners.
b. Your Privacy Rights
If you are a resident of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia, you have or will have the following rights under applicable law in relation to your personal data, subject to certain exceptions:
- Right to know and access. You have the right to know what personal data we collect, use, disclose, and/or sell or share as those terms are defined under applicable law. You may ask us to provide you with a portable copy of this information up to two times in a rolling twelve-month period.
- Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal data that we collect about you.
- Right to correct inaccurate personal data. You have the right to request the correction of inaccurate personal data.
- Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
- Right to opt out. You have the right to opt out of targeted advertising, the sale of your personal data, and profiling decisions that could produce legal or similarly significant effects concerning the consumer.
- Rights concerning sensitive personal data. If you are a Connecticut, Colorado, Delaware, Maryland, Minnesota, Montana, Nebraska, New Jersey, Oregon, Tennessee, Texas, or Virginia resident, we cannot and will not process your sensitive data (as defined by applicable law) or your sensitive data inferences, or use your personal data for certain purposes without your affirmative consent. If you are an Iowa or Utah resident, you have the right to opt-out of having your sensitive personal data processed and/or used.
The CTDPA provides Connecticut residents with additional rights to receive certain disclosures and access regarding the collection, use, sale, and sharing of consumer health data. For information regarding the consumer health data that we collect, how we use it, what sources it is derived from, to whom we disclose it, as well as the rights of Connecticut residents and our responsibilities under the CTDPA, please see our Consumer Health Data Privacy Notice.
How to exercise your rights. You may exercise any of the rights described in this section by following the instructions in Your Privacy Rights.
How to appeal decisions about your rights. Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, and Virginia residents can appeal our decisions concerning privacy rights requests, as follows:
- Colorado residents. If you are a Colorado resident and want to appeal our decision about a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Colorado’s Office of the Attorney General by phone at (720) 508-6000 or by submitting a form here.
- Connecticut residents. If you are a Connecticut resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Connecticut’s Office of the Attorney General by phone at (860) 808-5420 or by submitting a form here.
- Delaware residents. If you are a Delaware resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Delaware’s Department of Justice by phone at (302) 683-8800 or by submitting a form here.
- Iowa residents. If you are an Iowa resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Iowa’s Office of the Attorney General by phone at (888) 777-4590 or by submitting a form here.
- Maryland residents. If you are a Maryland resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Maryland’s Office of the Attorney General by phone at (888) 743-0023 or by submitting a form here.
- Minnesota residents. If you are a Minnesota resident and want to appeal our decision about a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Minnesota’s Office of the Attorney General by phone at (800) 657-3787 or by submitting a form here.
- Montana residents. If you are a Montana resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Montana’s Office of the Attorney General by phone at (406) 444-4500 or by submitting a form here.
- Nebraska residents. If you are a Nebraska resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Nebraska’s Office of the Attorney General by phone at (402) 471-2683 or by submitting a form here.
- New Hampshire residents. If you are a New Hampshire resident and want to appeal our decision about a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact New Hampshire’s Office of the Attorney General by phone at (603) 271-3658 or by submitting a form here.
- New Jersey residents. If you are a New Jersey resident and want to appeal our decision about a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact New Jersey’s Office of the Attorney General by phone at (800) 242-5846 or by submitting a form here.
- Oregon residents. If you are an Oregon resident and want to appeal our decision with regard to a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Oregon’s Office of the Attorney General by phone at (877) 877-9392 or by submitting a form here.
- Texas residents. If you are a Texas resident and want to appeal our decision with regard to a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Texas’s Office of the Attorney General by phone at (800) 621-0508 or by submitting a form here.
- Virginia residents. If you are a Virginia resident and want to appeal our decision with regard to a request that you have previously made, please Contact Us or notify the Office of the Attorney General of Virginia online here. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Virginia’s Office of the Attorney General by phone at (804) 786-2071, written correspondence to 202 North 9th Street, Richmond, Virginia 23219, or online here.
13. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Sites, prior to the change becoming effective and update the “Effective Date” at the top of this Privacy Policy. We recommend reviewing this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
14. Contact Us
If you have any questions about this Privacy Policy, please email us at privacy@ndallc.com. You can also call us at (323) 379-2733 or write to us at 8 The Green #14451, Dover, Delaware 19901.
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