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FDIC-Insured - Backed by the full faith and credit of the U.S. Government

Online Privacy Policy

Effective as of July 22, 2025

INTRODUCTION

This Online Privacy Policy (the “Privacy Policy”) pertains to Old National Bancorp and its affiliates, including Old National Bank, but excluding 1834 Investment Advisors Co., which posts its own online privacy policy (“Old National,” “we,” “our,” or “us”). Old National respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the information you provide to us when accessing our website (“Site”), use the services provided through our Site, and any of the mobile applications we offer (collectively, “Services”),  and is intended for a U.S. audience only. By using our Site, or by using our Services, you are acknowledging that you have read, understood, and accept this Privacy Policy.

If you have a consumer financial product or service with us, we will use and share any information that we collect from or about you in accordance with our US Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.

This Privacy Policy does not extend to anyone whose personal information is not under our control or management, including data that is collected by other websites that you may visit before or after this Site, and which are not governed by this Privacy Policy. We are not responsible for the data protection or privacy policies of any other websites and accept no responsibility or liability for those policies. Please carefully check the policies of other websites and services you use before you visit or submit personal information.

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically.

COLLECTING AND USING INFORMATION

Personally Identifiable Information We Collect Online

We may collect Personally Identifiable Information from you through your use of the Site and Services. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. We collect the following types of Personally Identifiable Information:

Information You Provide

We may collect the following Personally Identifiable Information that you voluntarily provide to us:

  • Online Banking. If you open an online banking account, we will collect your first and last name, social security number, and email address. We will also collect the pin number associated with your banking account. Every time you log on to use our online banking features, we will request that you enter your User ID—personal online identifier.
  • Applications. If you apply for one of our financial products or services, such as a credit card, bank account, or loan, we will collect your first and last name, postal address, email address, telephone number, and social security number. We also will collect other information such as your date of birth, marital status, driver’s license number and expiration date, months and years you have resided at your current residence, current rent or mortgage monthly payment, employment information such as your occupation, employer name and address, your gross monthly income, and if you are applying for a loan, we will request your bank account number.
  • Mobile Apps. If you use our mobile applications, we, through our mobile application service providers, will collect your User ID and password information. We also will collect a device identifier and location to provide additional security to protect your account.  We may also collect information you grant access to on your mobile device through our mobile application, such as your contacts or camera.
  • Talk to an Expert. If you request communication with one of our experts, we will collect your first name and telephone number.
  • Business Express. If you enroll in our Business Express service, we will request the name of your business, your first and last name, postal address, telephone number, and email address. We will also collect your financial information such as your bank account and routing number.

Information as You Navigate Our Site

We automatically collect certain Personally Identifiable Information through your use of the Site and Services, such as the following:

  • Usage Information. We collect information automatically through your use of the Site and Services, such as which of the pages on the Site you access, the frequency of access, and what you click on while on the Site.
  • Device Information. We collect information about the device you are using, such as hardware model, operating system, application version number, and browser.
  • Mobile Device Information. In addition to the Device Information listed above, when you access our Site via a browser on your mobile device, we collect and aggregate information about whether you are accessing the Site via a mobile device or tablet, device type, and carrier.
  • Location Information. We collect location information from Site visitors on a city-regional basis.

Third Party Information

In some cases, we may receive certain Personally Identifiable Information from you about a third party. For example, as part of our application process, you may provide the information of a third party. If you submit any Personally Identifiable Information about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personally Identifiable Information in accordance with this Privacy Policy.

How We Use Your Personally Identifiable Information

We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Services and Site, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:

  • Process your account registration and application;
  • Provide customer service;
  • Review your job application;
  • Contact you regarding our products and services that we feel may be of interest to you;
  • Communicate with you about our Site or Services or to inform you of any changes to our Site or Services;
  • Provide support;
  • Maintain and improve our Site and Services;
  • Defend our legal rights and the rights of others;
  • Efficiently maintain our business;
  • Comply with applicable law; and
  • For any other purpose not otherwise prohibited by applicable law

How We Disclose Your Personally Identifiable Information

We may disclose the information that we collect about you in the following ways:

  • With service providers who perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.). Any such service providers will be under an obligation to us to maintain the confidentiality of your Personally Identifiable Information;
  • To service providers to prepare, deploy, and analyze advertising content;
  • To the extent that we are required to do so by law;
  • In connection with any legal proceedings or prospective legal proceedings;
  • To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
  • To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal Information;
  • To any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, or in preparation for any of these events; and
  • To any other person or entity where you consent to the disclosure.

COOKIES AND OTHER TRACKING TECHNOLOGIES

How We Use Cookies

Like many other companies, we use cookies and other tracking technologies (such as pixels and web beacons) (collectively “Cookies”). “Cookies” are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).

We use Cookies to:

  • Estimate audience size and usage patterns;
  • Understand and save your preferences for future visits, allowing us to customize the Site and Services to your individual needs;
  • Advertise new content and services that relate to your interests;
  • Keep track of advertisements and search engine results;
  • Compile aggregate data about Site traffic and Site interactions to resolve issues and offer better Site experiences and tools in the future;
  • Ensure browsing security; and
  • Recognize when you return to the Site.

We set some Cookies ourselves and others are set by other entities. We use Cookies set by other entities to provide us with useful information to help us improve our Site and Services, to conduct advertising, and to analyze the effectiveness of advertising. For example, we use Cookies from Google, Facebook and other similar companies.

We use technology supplied by certain service providers such as HotJar and WebTrax to better understand our users’ needs and to optimize our Services and your experience. The technology helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our Services with user feedback. The technology uses cookies and other tools to collect data on our users’ behavior and their devices. This may include a device’s IP address (processed during your session), device screen size, device type (unique device identifiers), browser information, and the preferred language used to display our Site.

How You Can Opt-Out of Cookies

Browser Settings

Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Site.

You can find out more about Cookies and how to manage them by visiting https://www.allaboutcookies.org/privacy-concerns/.

Platform Controls

You can opt out of Cookies set by specific entities by following the instructions found at these links:

Google: https://adssettings.google.com Facebook: https://www.facebook.com/about/ads

Advertising Industry Resources

You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

Please note that these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.

Global Privacy Control (GPC)

Global Privacy Control (GPC) is a service that lets you opt out of the sale or sharing of your personal information at the browser level. You can enable this service through specific browsers or browser extensions. The opt out associated with a GPC signal is applied on a browser and device basis. This means if you use a different browser or device, you will need to enable GPC on each one to ensure that your preference is consistently applied. For more information on which browsers are GPC-enabled and how to use that service please visit the Global Privacy Control website.

Third Party Processors

To ensure that your Personally Identifiable Information receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share it with to ensure that it is treated consistent with applicable data security and privacy laws. For example, we use service providers to allow us to accept applications and deliver our financial products and services.

This Privacy Policy does not extend to anyone whose personal information is not under our control or management, including data that is collected by other websites that you may visit before or after this Site, and which are not governed by this Privacy Policy. We are not responsible for the data protection or privacy policies of any other websites and accept no responsibility or liability for those policies. Please carefully check the policies of other websites and services you use before you visit or submit personal information.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Site and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.

In addition to Google Analytics, we have implemented reCAPTCHA v3 on our site. The use of reCAPTCHA v3 is subject to the Google Privacy Policy and Terms of Use. Our adoption of reCAPTCHA v3 may only be used to fight spam and abuse on our site. reCAPTCHA is not used for any other purposes such as determining credit worthiness, employment eligibility, financial status, or insurability of a user.

“Do Not Track” Signals

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site may not, respond to or alter its practices when it receives “Do Not Track” signals

CHOICES ABOUT YOUR PERSONALLY IDENTIFIABLE INFORMATION

Review and Request Changes to Your Personally Identifiable Information

You may use your account to access, correct, or view certain Personally Identifiable Information we have collected, and which is associated with your account. To review or request changes to any of your Personally Identifiable Information, please contact us at bancorp@oldnational.com.

Marketing Communications

To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us at bancorp@oldnational.com.

SECURITY

Old National safeguards client information by maintaining physical, electronic, and procedural safeguards that comply with federal standards to guard non-public personal information about you. This is accomplished by operating under a detailed information security policy and program designed to protect the security of your information. The information security program is subject to ongoing regulatory oversight and examination. Additionally, access to personal information will be restricted to our authorized personnel who require the information to perform their duties properly. Furthermore, access will be limited to only that information that is strictly necessary for the performance of those duties. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.

A critical part of protecting your information includes steps you should take to protect yourself when using computers to access online services, communicate and store information. If you'd like to know more about how Old National Bank protects information about you, or for details about our Website Security Practices click here

THIRD PARTY LINKS

The Site may contain links that will let you leave the Site and access another website. Linked websites are not under our control. Except as stated below, this Privacy Policy applies solely to Personally Identifiable Information that is acquired by us on this Site. We accept no responsibility or liability for these other websites.

CHILDREN’S PRIVACY

The Site and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13 years of age.

NOTICE TO NEVADA RESIDENTS

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. You may submit a request to opt-out of the sale of your personal information by calling us toll-free at 1-800-731-2265.

CALIFORNIA CONSUMER PRIVACY ACT NOTICE AT COLLECTION AND PRIVACY POLICY FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act (CCPA) requires that we provide California residents with a Notice at Collection and Privacy Policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale and sharing of personal information and of the rights of California residents regarding their personal information (“CCPA Notice at Collection and Privacy Policy”). This CCPA Notice at Collection and Privacy Policy section is intended solely for, and is applicable only as to, California residents. Any use of the words “you,” or “your” in this section refers to California residents.

This CCPA Notice at Collection and Privacy Policy applies to “personal information” defined under the CCPA to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). Personal information does not include certain information subject to exemptions, including information that is publicly available, deidentified or aggregate information and information subject to other federal privacy laws, such as the Gramm-Leach-Bliley Act or the Health Insurance Portability and Accountability Act. Any other terms defined in the CCPA have the same meaning given to them in the CCPA when used in this CCPA Notice at Collection and Privacy Policy.

Certain exemptions apply to your rights and our obligations pursuant to the CCPA. These rights may not apply in certain situations depending on the nature of the Personal Information we handle, your relationship with us and our other legal obligations under the CCPA. For example, if you are a California resident who has a financial product or service with us, much of the Personal Information that we collect is exempt from the CCPA. Your choices and rights with respect to our use and disclosure of that information are subject to our U.S. Consumer Privacy Notice. If you are not a California resident, this CCPA Notice at Collection and Privacy Policy does not apply to you and you should not rely on it.

The CCPA Notice at Collection and Privacy Policy does not address Personal Information collected for employment-related inquiries or transactions. For additional details about the use of Personal Information for employment matters, please refer to the Notice to California Employes and Prospective Employees

Categories of Personal Information Collected

The Personal Information that we collect about a specific California resident will depend upon our interaction or relationship with that individual. We currently collect and, in the 12 months prior to the “last updated” date of this Privacy Policy, have collected the following categories of Personal Information about California residents.

Personal Identifiers (e.g. name, alias, postal address, telephone number, online identifier, internet protocol address, email address, account name, signature, Social Security number, driver’s license number, passport number, and other types of state identification cards);

Personal Information categories listed in the California Customer Records Statute, Cal. Civ. Code (e.g. name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number and ATM card number, or any other financial information, medical information, or health information);

Unique Online personal identifiers (e.g. cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology);

Internet or other electronic network activity information (e.g. browsing history; search history; and information regarding consumers’ interactions with websites, applications or advertisements);

Geolocation data (e.g. the location of you or your device);

Commercial information (records of products or services purchased, obtained or considered);

Education information (e.g. degrees or certificates);

Professional or employment-related information (e.g., occupation, employer name, current and past job history);

Protected classifications (race, color, sex/gender, age (40 and older), national origin, disability, citizenship status, marital status, medical condition, military status;)

Audio, Electronic and Visual Information (e.g., voice, call and video recordings, and electronic communications);

Sensitive Personal Information (e.g. Social Security number, driver’s license, state identification card or passport number, account login; account login, financial account, debit card or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation (which means information that pinpoints your location within a radius of 1,850 feet or less); racial or ethnic origin, citizenship, immigration status or union membership; the contents of mail, email, and text messages, unless we are the intended recipient of the communication; biometric information processed to uniquely identify you; and health data); and

Inferences (e.g. Inferences drawn from any of the information identified above to create a profile about you reflecting preferences, characteristics, attitudes or similar trends).

Sources of Personal Information

We may collect the Personal Information described above from one or more of the following sources depending upon our relationship and interactions with you:

  • Directly from you
  • Businesses with which we have interacted, such as on behalf of a business we provide products and services to, or otherwise in the business-to-business context
  • Individuals authorized to act on your behalf
  • Our affiliates
  • Service providers
  • Government agencies and other publicly available sources
  • Operating systems and platforms Data analytics providers
  • Credit bureaus
  • Consumer lead generators

Use of Personal Information

In addition to the purposes stated above in the section “COLLECTING AND USING INFORMATION,” we currently collect and have collected, disclosed, or sold the above categories of Personal Information for one or more of the following business or commercial purposes:

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, and providing analytic services;
  • Auditing related to a current interaction with a consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Undertaking internal research for technological development and demonstration;
  • Undertaking activities to verify or maintain the quality or safety of our Services, and to improve, upgrade, or enhance the Services;
  • Advancing our commercial or economic interests, such as by inducing another person to buy, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction;
  • For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us;
  • Complying with legal and regulatory obligations;
  • Detecting, investigating and preventing activities that may violate our policies or be illegal; and
  • Enforcing our terms and conditions and otherwise protecting our rights and operations.

Selling and Sharing of Personal Information

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

The CCPA defines “share” to mean sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged.

We do not “share” your information as defined under the CCPA.

We do not sell your Personal Information to third parties for monetary consideration but do transfer information to third parties for the purposes described in the chart below that could be considered a “sale” of information under the CCPA. 

You may opt out of the sale of your Personal Information by following the process described below under Right to Opt-Out of Sale of Personal Information.

We do not knowingly collect, sell or share the Personal Information of minors under 16 years of age.

Purpose for Disclosing and Selling Information with Categories of Third Parties

    The following table identifies the categories of Personal Information that we may have disclosed or sold for a business or commercial purpose to service providers, contractors or third parties in the 12 months preceding the Last Update date of this Privacy Policy and, for each category, the category of service providers, contractors or third parties to whom the Personal Information may have been disclosed or sold:

    Category of Personal Information Collected

    Collection Sources

    Business or Commercial Purpose for Collection

    Categories of Third Parties with Whom Personal Information is Disclosed or Sold
    Personal Identifiers
    • Directly from you
    • Individuals authorized to act on your behalf
    • Our affiliates
    • Service providers
    • Government agencies and other publicly available sources
    • Operating systems and platforms
    • Data analytics providers

     

    • To open, maintain and service accounts, provide customer service, process or fulfill orders and transactions, verify customer information, process payments, provide financing, provide analytic services, or similar services.
    • Advancing our commercial or economic interests, such as by inducing another person to buy, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
    • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
    • Debugging to identify and repair errors that impair intended functionality
    • Short-term transient use meeting the conditions of the CCPA
    • Providing advertising and marketing services, not including cross-context behavioral advertising
    • Undertaking internal research for technological development and demonstration
    • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
    • Complying with legal and regulatory obligations
    • Detecting, investigating and preventing activities that may violate our policies or be illegal
    • Enforcing our terms and conditions and otherwise protecting our rights and operations
    • Evaluating, preparing for or engaging in a business or asset sale, equity transaction, merger, or acquisition.
    • Service providers
    • Our affiliates
    • Government agencies
    • Third parties to whom you authorize us, directly or indirectly, to disclose your Personal Information
    • Data analytics Providers
    • Operating systems and platforms
    Personal Information categories listed in the California Customer Records Statute, Cal. Civ. Code listed in the Collection of Personal Information section above
    • Directly from you
    • Service providers
    • Operating systems and platforms
    • Government agencies and other publicly available sources
    • To open, maintain and service accounts, provide customer service, process or fulfill orders and transactions, verify customer information, process payments, provide financing, provide analytic services, or similar services.
    • Advancing our commercial or economic interests, such as by inducing another person to buy, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
    • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
    • Debugging to identify and repair errors that impair intended functionality
    • Short-term transient use meeting the conditions of the CCPA
    • Providing advertising and marketing services not including cross-context behavioral advertising
    • Evaluating, preparing for or engaging in a business or asset sale, equity transaction, merger, or acquisition
    • Undertaking internal research for technological development and demonstration
    • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
    • Complying with legal and regulatory obligations
    • Detecting, investigating and preventing activities that may violate our policies or be illegal
    • Enforcing our terms and conditions and otherwise protect our rights and operations
    • Service providers
    • Our affiliates
    • Government agencies
    • Third parties to whom you authorize us, directly or indirectly, to disclose your Personal Information
    • Data analytics providers
    • Operating systems and platforms

    Unique Online personal identifiers (e.g. cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology);

    • Directly from you
    • Service Providers
    • Data Analytics providers
    • Providing advertising and marketing services,not including cross-context behavioral advertising
    • Evaluating, preparing for or engaging in a business or asset sale, equity transaction, merger, or acquisition
    • Data Analytics Providers
    • Advertising Networks
    • Entities involved with us in a proposed or actual merger, sale or acquisition

    Characteristics of protected classification under California or Federal law

    • Directly from you
    • To open, maintain and service accounts, provide customer service, process or fulfill orders and transactions, verify customer information, process payments, provide financing, provide analytic services, or similar services.
    • Complying with legal and regulatory obligations
    • Detecting, investigating and preventing activities that may violate our policies or be illegal
    • Enforcing our terms and conditions and otherwise protecting our rights and operations
    • Evaluating, preparing for or engaging in a business or asset sale, equity transaction, merger, or acquisition
    • Service providers
    • Our affiliates
    • Government agencies
    • Third parties to whom you authorize us, directly or indirectly, to disclose your Personal Information
    • Operating systems and platforms

    Commercial information such as products or services purchased, obtained, or considered

    • Directly from you
    • Individuals authorized to act on your behalf
    • Our affiliates
    • Service providers
    • Government agencies and other publicly available sources
    • Operating systems and platforms
    • Data analytics providers
    • To open, maintain and service accounts, provide customer service, process or fulfill orders and transactions, verify customer information, process payments, provide financing, provide analytic services, or similar services.
    • Advancing our commercial or economic interests, such as by inducing another person to buy, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
    • For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us;
    • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
    • Debugging to identify and repair errors that impair intended functionality Short-term transient use meeting the conditions of the CCPA
    • Providing advertising and marketing services, not including cross-context behavioral advertising
    • Undertaking internal research for technological development and demonstration
    • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
    • Complying with legal and regulatory obligations
    • Detecting, investigating and preventing activities that may violate our policies or be illegal
    • Enforcing our terms and conditions and otherwise protecting our rights and operations
    • Evaluating, preparing for or engaging in any business or asset sale, equity transaction, merger, or acquisition
    • Service providers
    • Our affiliates
    • Government agencies
    • Third parties to whom you authorize us, directly or indirectly, to disclose your Personal Information
    • Operating systems and platforms
    • Data analytics providers

    Internet or other electronic network activity information

    • Directly from you
    • Service providers
    • Operating systems and platforms
    • Our affiliates
    • To open, maintain and service accounts, provide customer service, process or fulfill orders and transactions, verify customer information, process payments, provide financing, provide analytic services, or similar services.
    • Advancing our commercial or economic interests, such as by inducing another person to buy, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
    • For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us;
    • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
    • Debugging to identify and repair errors that impair intended functionality
    • Short-term transient use meeting the conditions of the CCPA
    • Providing advertising and marketing services, not including cross-context behavioral advertising
    • Undertaking internal research for technological development and demonstration Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
    • Detecting, investigating and preventing activities that may violate our policies or be illegal
    • Enforcing our terms and conditions and otherwise protecting our rights and operations
    • Complying with legal and regulatory obligations
    • Service providers
    • Our affiliates
    • Government agencies
    • Third parties to whom you authorize us, directly or indirectly, to disclose your Personal Information
    • Operating systems and platforms
    • Data analytics providers

    Geolocation

    • Directly from you
    • Service providers
    • Operating systems and platforms
    • To open, maintain and service accounts, provide customer service, process or fulfill orders and transactions, verify customer information, process payments, provide financing, provide analytic services, or similar services.
    • For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us;
    • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
    • Debugging to identify and repair errors that impair intended functionality
    • Short-term transient use meeting the conditions of the CCPA
    • Providing advertising and marketing services, not including cross-context behavioral advertising
    • Undertaking internal research for technological development and demonstration Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
    • Complying with legal and regulatory obligations
    • Detecting, investigating and preventing activities that may violate our policies or be illegal
    • Enforcing our terms and conditions and otherwise protecting our rights and operations
    • Evaluating, preparing for or engaging in any business or asset sale, equity transaction, merger, or acquisition
    • Service providers
    • Our affiliates
    • Third parties to whom you authorize us, directly or indirectly, to disclose your Personal Information
    • Operating systems and platforms
    • Data analytics providers

    Audio, electronic, visual, or similar information

    • Directly from you
    • Our affiliates
    • Service providers
    • Operating systems and platforms
    • To open, maintain and service accounts, provide customer service, process or fulfill orders and transactions, verify customer information, process payments, provide financing, provide analytic services, or similar services.
    • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
    • Debugging to identify and repair errors that impair intended functionality
    • Short-term transient use meeting the conditions of the CCPA
    • Providing advertising and marketing services, not including cross-context behavioral advertising
    • Undertaking internal research for technological development and demonstration
    • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
    • Complying with legal and regulatory obligations
    • Detecting, investigating and preventing activities that may violate our policies or be illegal
    • Enforcing our terms and conditions and otherwise protecting our rights and operations
    • Service providers
    • Our affiliates
    • Government agencies
    • Third parties to whom you authorize us, directly or indirectly, to disclose your Personal Information

    Professional or employment-related information

    • Directly from you
    • Individuals authorized to act on your behalf
    • Our affiliates
    • Service providers
    • Government agencies and other publicly available sources
    • To open, maintain and service accounts, provide customer service, process or fulfill orders and transactions, verify customer information, process payments, provide financing, provide analytic services, or similar services.
    • Short-term transient use meeting the conditions of the CCPA
    • Providing advertising and marketing services not including cross-context behavioral advertising
    • Complying with legal and regulatory obligations Detecting, investigating and preventing activities that may violate our policies or be illegal
    • Enforcing our terms and conditions and otherwise protecting our rights and operations
    • Evaluating, preparing for or engaging in any business or asset sale, equity transaction, merger, or acquisition
    • Service providers
    • Our affiliates
    • Government agencies
    • Third parties to whom you authorize us, directly or indirectly, to disclose your Personal Information

    Education information

    • Directly from you
    • Individuals authorized to act on your behalf
    • Our affiliates
    • Service providers
    • To open, maintain and service accounts, provide customer service, process or fulfill orders and transactions, verify customer information, process payments, provide financing, provide analytic services, or similar services.
    • Short term transient use meeting the conditions of the CCPA
    • Complying with legal and regulatory obligations
    • Detecting, investigating and preventing activities that may violate our policies or be illegal
    • Enforcing our terms and conditions and otherwise protecting our rights and operations
    • Providing advertising and marketing services not including cross-context behavioral advertising
    • Evaluating, preparing for or engaging in any business or asset sale, equity transaction, merger, or acquisition
    • Service providers
    • Our affiliates
    • Government agencies
    • Third parties to whom you authorize us, directly or indirectly, to disclose your Personal Information

    Sensitive personal information

    • Directly from you
    • Individuals authorized to act on your behalf
    • Our affiliates Service providers
    • Government agencies and other publicly available sources
    • Operating systems and platforms
    • Data analytics providers
    • To perform services, including maintaining or servicing accounts, customer service, processing orders and transactions, verifying customer information, processing payments, providing financing, analytic service, storage or similar services
    • To provide requested goods and services 
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
    • Short term, transient use meeting the conditions of the CCPA
    • To verify or maintain quality or safety of service or device or improve upgrade or enhance service or device
    • Evaluating, preparing for or engage in a business or asset sale, equity transaction, merger, or acquisition
    • Service providers
    • Our affiliates
    • Government agencies
    • Third parties to whom you authorize us, directly or indirectly, to disclose your Sensitive Personal Information

    Inferences drawn to create a profile about a consumer

    • Directly from you
    • Our affiliates
    • Service Providers
    • Data Analytics Providers
    • To open, maintain and service accounts, provide customer service, process or fulfill orders and transactions, verify customer information, process payments, provide financing, provide analytic services, or similar services.
    • Advancing our commercial or economic interests, such as by inducing another person to buy, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
    • For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us;
    • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
    • Short-term transient use meeting the conditions of the CCPA
    • Providing advertising and marketing services
    • Undertaking internal research for technological development and demonstration
    • Complying with legal and regulatory obligations
    • Detecting, investigating and preventing activities that may violate our policies or be illegal
    • Enforcing our terms and conditions and otherwise protecting our rights and operations
    • Evaluating, preparing for or engaging in a business or asset sale, equity transaction, merger, or acquisition
    • Service providers
    • Our affiliate
    • Third parties to whom you authorize us, directly or indirectly, to disclose your Personal Information

     

    Data Retention

    We will retain Personal Information, including Sensitive Personal Information, no longer than reasonably necessary to fulfill the purposes for which we originally collected it or as legally required or necessary for our legitimate business purposes.

    Your Rights

    Right to Know and Access Personal Information Collected, Disclosed or Sold

    If you are a California resident, you have the right, subject to certain exceptions under the CCPA and other applicable laws and regulations, to request that we disclose what Personal Information we have collected about you. You also have the right to receive your Personal Information in a structured and commonly used format so that it can be transferred to another entity (also known as “data portability”). This includes the right to request any or all of the following:

    • Specific pieces of Personal Information that we have collected about you;
    • Categories of Personal Information that we have collected about you;
    • Categories of sources from which the Personal Information was collected;
    • Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
    • Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose, and the categories of Personal Information disclosed; and
    • The business or commercial purpose for collecting or, if applicable, selling Personal Information about you.

    Right to Request Deletion of Personal Information

    If you are a California resident, you have the right, subject to certain exceptions under the CCPA and other applicable laws and regulations, to request that we delete the Personal Information about you that we have collected. Under the CCPA, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

    Right to Correct Personal Information

    In certain circumstances, you have the right to request that we correct any inaccurate Personal Information held by us.

    Rights Regarding Sensitive Personal Information Processing

    The CCPA provides rights to limit how your Sensitive Personal Information is disclosed or shared with third parties, as defined in the CCPA. We only collect and use Sensitive Personal Information for certain limited purposes, such as providing services and products, maintaining and servicing accounts, detecting and investigating security incidents and verifying customer information. Because we only use Sensitive Personal Information for legally permissible limited purposes, there is no right to limit our use for these purposes.

    Right to Non-Discrimination

    You have the right to be free from discrimination for exercising any of your rights under the CCPA as described in this CCPA Notice at Collection and Privacy Policy. This means you cannot be denied goods or services, charged different prices or rates, provided with a different level or quality of goods or services or retaliated against in any other way for exercising your privacy rights.

    Right to Opt-Out of Sale of Personal Information

    If you are a California resident, you have the right to direct us to stop selling your Personal Information.

    The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

    You may submit a request to opt-out of the sale of your Personal Information via web form by clicking on this link: “Do Not Sell My Personal Information”. You also may submit a request by calling us toll-free at 1-800-731-2265.

    We also honor the Global Privacy Control (GPC) opt out preference signal as a valid request to opt out of the sale of your Personal Information. This is a service that allows you to set your opt out preferences at your browser level. For more information on how to use this service please see the section “ Global Privacy Control” above.

    To opt-out of our use of third-party advertising Cookies, please see the section “How You Can Opt-Out of Cookies” above.

    How to Submit a Request to Know, Access or Delete

    You may submit a request to know, access or delete via a web form available here or by calling us toll-free at 1-800-731-2265.

    If you submit a request to delete online, you may be asked to confirm separately that you want your Personal Information deleted.

    Our Process for Verifying a Request to Know or Delete

    If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable.

    For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

    For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

    We will generally respond to your request(s) within 45 days, unless, for reasons beyond our control, a longer response time is necessary, in which case, you will be advised accordingly. Please note that we may retain certain information about such requests as required by law or as necessary for our legitimate business purposes.

    Authorized Agents

    A California resident may designate an authorized agent to make a request on behalf of the California resident by contacting us at the toll-free number or email address listed above. If you designate an authorized agent to make an access, correction, or deletion request on your behalf, we may require you to provide the authorized agent written permission to do so and require you to verify your own identity directly with us (as described above).

    An authorized agent submitting a request on behalf of a California resident, must submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify the authority to act on behalf of the California resident.

    ACCESSIBILITY

    We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below. Please also see our Accessibility Statement available here.

    HOW TO CONTACT US

    To contact us for questions or concerns about our privacy policies or practices please call us toll-free at 1-800-731-2265.