TransUnion Consumer Interactive Privacy Notice 

This notice was last modified on and has an effective date of July 14, 2023.

We have recently updated our Privacy Notice. Be sure to review the notice carefully to understand our privacy practices.

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Neustar, Sontiq, Argus, and Commerce Signals are now TransUnion companies. To learn how these companies handle personal information about you and the rights you may have regarding that personal information, please visit the Neustar Privacy Notice, the Sontiq Privacy Center, the Argus Privacy Notice, and Commerce Signals Privacy Notice.

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This Privacy Notice (“Notice”) provides information about how TransUnion Interactive, Inc. (“TUI,” “we,” “us,” “our”) handles personal information and describes the rights you may have regarding your personal information. This Notice applies to TUI, its websites, applications, products (the “Products”), features, and application program interfaces, when you communicate or interact with us either directly or through the use of any of our online systems and applications, and its online and offline collection, use, sale, sharing, and disclosure of personal information (collectively, the “Online and Offline Services”). The Notice applies to TransUnion Credit Monitoring, TrueIdentity, and zendough. For transparency purposes only, this Notice provides limited information regarding certain consumer credit reporting and other regulatory activities, governed by the Fair Credit Reporting Act (“FCRA”), please navigate to the “TransUnion’s credit database” section below.

Use of our Online and Offline Services constitutes your agreement to the terms of this Notice. If you do not agree with the terms of this Notice, please do not use our Online or Offline Services.

Visit our Consumer Privacy Rights page to exercise your privacy choices and rights.

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Notice at Collection: We collect personal information as detailed in this Notice. The categories of personal information that we collect are listed below under “Collection and use of personal information,” which also describes the purposes for which we collect and use personal information. To learn more about your privacy rights, including your right to opt out of the sale or sharing of your personal information, please navigate to the “Consumer privacy rights” section below. Our retention practices are outlined below under “Retaining personal information.”

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View TransUnion's California Consumer Privacy Act (CCPA) Metrics.

1. Collection and use of personal information

Personal information we may collect, from whom or how we may collect, and why we may collect it, by category:

IDENTIFIERS, INCLUDING THOSE IN THE CALIFORNIA CUSTOMER RECORDS STATUTE

We may collect the following information:

• Name (first, last, and/or maiden name) (or that of a family member or child); home address, billing address, or other physical address; an email address (so we may communicate with you); a telephone number
• Device identification information which we may associate with a mobile telephone number you provide in order to access the Online Services
• Information collected passively via cookies and similar technology
• IP addresses, device identifiers, and application identifiers
• Debt, income and financial information
• Utility and income information
• Categories of Sensitive Personal Information:
  • Social security number; or certain other information, such as date of birth, employment information, and credit card account information
  • Account and password information related to financial services
  • Driver’s license number and passport number

From whom or how we may collect it:

• Consumers
• Information collected passively via cookies and similar technology
• Advertising Partners
• Credit reporting agency and its affiliates
• External data providers, vendors

Why we may collect it:

• To verify your identity
• To enroll you in the Product, finalize your application during the enrollment process and create your TUI Product membership program
• To provide you with products and their features
• To send emails and other alerts
• To process payment and complete the transaction
• To provide you with quality customer service
• For product development, product research, and product improvement by TUI and its affiliates, or the TransUnion family of companies
• To prevent fraud on your account, or to identify fraudulent activity towards TUI
• To enhance and optimize your experience on our Online and Offline Services and improve our Products, for example, to test new products, to determine if products that we are contemplating may be desirable to our customers, for analytics, marketing research, and business analysis
• To perform analytics, improve user experience, improve our product offerings
• To maintain the accuracy of your credit report and information
• To participate in our affiliate program, subscribe to our emails or newsletter, participate in one of our contests or surveys or transact other business with us
• To display, optimize and provide you with personalized advertisements
• To communicate with you
• For fulfillment of your requests and purchases, transactional and other communications about the Online Services, Offline Services and Product; promotional opportunities and generally for TUI’s and its affiliates’ internal business purposes such as, for example, internal analyses and audits
• For product development and research, and for any purpose subject to the limitations set forth in this Privacy Notice and applicable law
• For data utilization from third parties, such as your telecommunications provider, to help confirm your identity and prevent fraudulent access. It is likely you authorize your wireless operator to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, to our third party service provider, solely to verify your identity and prevent fraud for the duration of the business relationship. TUI limits the use of this information to prevent fraud and unauthorized access or disclosures of your personal information.

CHARACTERISTICS OF PROTECTED CLASSIFICATIONS UNDER STATE OR FEDERAL LAW

We may collect the following information:

• Date of Birth
• Marital Status
• Categories of Sensitive Personal Information:
  • Ethnicity

From whom or how we may collect it:

• Consumers
• Advertising partners
• Credit reporting agency and its affiliates

Why we may collect it:

• To verify your identity
• To enhance and optimize your TUI Product membership program experience
• To provide you with advertisements that are more relevant to your demographic
• To finalize your application and create your TUI Product membership program
• To display, optimize and provide you with personalized advertisements
• For fulfillment of your requests and purchases, transactional and other communications about the Online Services, Offline Services and Product; promotional opportunities and generally for TUI’s and its affiliates’ internal business purposes such as, for example, internal analyses and audits
• For product development and research, and for any purpose subject to the limitations set forth in this Privacy Notice and applicable law
• For data utilization from third parties, such as your telecommunications provider, to help confirm your identity and prevent fraudulent access. It is likely you authorize your wireless operator to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, to our third party service provider, solely to verify your identity and prevent fraud for the duration of the business relationship.  TUI limits the use of this information to prevent fraud and unauthorized access or disclosures of your personal information.

COMMERCIAL INFORMATION

We may collect the following information:

• Purchase records of our Product

From whom or how we may collect it:

• Consumers
• Payment processor
• TUI

Why we may collect it:

• For fulfillment of your requests and purchases, transactional and other communications about the Online Services, Offline Services and Product, promotional opportunities and generally for TUI’s and its affiliates’ internal business purposes such as, for example, internal analyses and audits.
• To keep a record of your transaction history.

BIOMETRIC INFORMATION

• We do not collect this category of information

INTERNET OR OTHER SIMILAR ELECTRONIC NETWORK ACTIVITY

We may collect the following information:

• Information about your interactions with the website, for example, when you view or search content, we receive and track that information; web session; log file information; information such as the website(s) you visited, when you visited the website, how long you stayed, your behavior while you were on our website and from what device you accessed the website; device identification information which we may associate with a mobile telephone number you provide used to access the website; email address, first and last name, the IP address and information related to that IP address, the internet service provider or proxy used, operating system information, browser information (the pages you view, how long you stay on each page, how often you come back and your behavior while you are on our websites); and which advertisement, emails, SMS notifications or other push notifications related to the website and/or Product, offer or online content you view, access, or click on, including to get to the Online Services or while you are on the websites
• Information collected from advertising partners
• Information about your interactions with online forms; for example, the use of autofill, number of pauses, length of time to complete a field, number of errors, number of changed answers, typing fluency and number of repeat interactions
• Local Storage Objects such as HTML5 and Flash to store content information and preferences

From whom or how we may collect it:

• Directly from individuals
• Cookies and similar technology

Why we may collect it:

• To continually enhance and optimize the Product and the Online Services, based on up-to-date user experience and available technology
• To improve the delivery and development of the Product
• To customize your web site and/or customer service experience
• To develop new Products
• To display, optimize, and provide you with personalized advertisements
• To measure advertising effectiveness
• To perform site analysis
• To predict the risk of fraud
• For product development and research, and for any purpose subject to the limitations set forth in this Privacy Notice and applicable law
• For data utilization from third parties, such as your telecommunications provider, to help confirm your identity and prevent fraudulent access. It is likely you authorize your wireless operator to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, to our third party service provider, solely to verify your identity and prevent fraud for the duration of the business relationship.  TUI limits the use of this information to prevent fraud and unauthorized access or disclosures of your personal information.

GEOLOCATION DATA

We may collect the following information:

• We collect non-precise geolocation data by using various technologies to determine your location including, but not limited to IP address, Wi-Fi access points, and cell towers

From whom or how we may collect it:

• Consumers
• Cookies and similar technology
• Telecommunications providers

Why we may collect it:

• Fraud prevention
• Targeted advertisements
• For fulfillment of your requests and purchases, transactional and other communications about the Online Services, Offline Services and Product; promotional opportunities and generally for TUI’s and its affiliates’ internal business purposes such as, for example, internal analyses and audits
• For product development and research, and for any purpose subject to the limitations set forth in this Privacy Notice and applicable law
• For data utilization from third parties, such as your telecommunications provider, to help confirm your identity and prevent fraudulent access; it is likely you authorize your wireless operator to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, to our third party service provider, solely to verify your identity and prevent fraud for the duration of the business relationship; TUI limits the use of this information to prevent fraud and unauthorized access or disclosures of your personal information

SENSORY DATA

We may collect the following information:

• Audio and electronic recording, for example, when you call in with a question to customer service

From whom we may collect it:

• Consumers

Why we may collect it:

• To provide customer service and support consumers
• To train agents to ensure best customer service delivery
• To ensure legal and compliance obligations
• To help answer questions and resolve disputes

PROFESSIONAL OR EMPLOYMENT-RELATED INFORMATION

We may collect the following information:

• Employment

From whom we may collect it:

• Consumers

Why we may collect it:

• To enhance and optimize your experience and improve our Products and our affiliates’ Products, for example, to test new products, to determine if products that we are contemplating may be desirable to our customers, for analytics, marketing research, and business analysis
• To display, optimize and provide you with personalized advertisements

NON-PUBLIC EDUCATION INFORMATION (per the Family Educational Rights and Privacy Act)

• We do not collect this category of information

INFERENCES DRAWN FROM OTHER PERSONAL INFORMATION

We may collect the following information:

• Site preferences and characteristics, for example, your behavior on our sites

From whom or how we may collect it:

• Consumer
• Cookies and similar technology
• Advertising partners

Why we may collect it:

• To determine how users interact with our website and how we can improve the user experience
• To create a customer profile in order to better optimize your customer experience and offer personalized advertisements
• For fulfillment of your requests and purchases, transactional and other communications about the Online Services, Offline Services and Product; promotional opportunities and generally for TUI’s and its affiliates’ internal business purposes such as, for example, internal analyses and audits
• For product development and research, and for any purpose subject to the limitations set forth in this Privacy Notice and applicable law
• For data utilization from third parties, such as your telecommunications provider, to help confirm your identity and prevent fraudulent access. It is likely that you authorize your wireless operator to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, to our third party service provider, solely to verify your identity and prevent fraud for the duration of the business relationship. TUI limits the use of this information to prevent fraud and unauthorized access or disclosures of your personal information.

2. Selling/Sharing personal information

We sell and share personal information with different third parties. For the reasons listed, during the prior 12 months, we may have sold or shared for a commercial purpose the following categories of personal information, by category of third parties. Please note that a specific piece of personal information may fall into one or more categories of personal information.

IDENTIFIERS, PERSONAL INFORMATION CATEGORIES LISTED IN THE CALIFORNIA CUSTOMER RECORDS STATUTE, CHARACTERISTICS OF PROTECTED CLASSIFICATIONS UNDER STATE OR FEDERAL LAW

• Advertising networks, to provide personalized advertisements, reporting purposes, analytics, if applicable
• Advertising platform providers, in order to provide and deliver personalized offers to you
• Affiliates, or the TransUnion family of companies, to enable updates on TransUnion’s consumer credit database; deliver, enhance, or develop the Products and those of TransUnion companies, or for internal business purposes; and to provide you with products, to improve our product offerings, to facilitate and improve our targeted offers and advertising, improve our database accuracy, or to send you personalized offers
• Commercial partners, or non-affiliated third parties which TUI may employ or partner with in order to provide and continually enhance the Product and deliver personalized offers to you
• Consumer data resellers, with whom we form indirect partnerships
• Credit reporting agencies to obtain your requested credit report
• Data analytics providers, to enable TUI to understand and improve the delivery of advertisements, enhance or modify our Online Services, Product, and understand and optimize consumer experience
• Government entities and regulators, to respond to regulator request
• Internet service providers
• Law enforcement agencies, without your consent pursuant to a subpoena or when required by other legal process, government request, to protect TUI’s rights, to protect the rights, privacy, safety or property of TUI and its affiliates, you, or another individual, and otherwise as may be necessary or required by applicable law or regulation; this may include responding to legal requests from jurisdictions outside of the United States; to detect, prevent and address fraud and other illegal activity, including as part of internal investigations and remediation efforts, to protect TUI and its affiliates, you and others, and to prevent harm to you or any other individual
• Marketing companies, to provide personalized advertisements and enhance the your experience; measure advertising effectiveness; provide advertising services such as advertising placement, advertising performance, cookie management
• Operating systems and platforms, to share with a different system or database, for example, to process payments
• Parties to litigation, to provide required documentation for litigation
• To consultants, agents and advisors, such as attorneys and accountants, in the good faith belief that such disclosure is within the scope of their professional duties to TUI and with the understanding that such professionals will abide by our security and confidentiality policies

COMMERCIAL INFORMATION

• Affiliates, or the TransUnion family of companies, to enable updates on TransUnion’s consumer credit database; deliver, enhance or develop the Products and those of TransUnion companies, or for internal business purposes; and to provide you with products, to improve our product offerings, to facilitate and improve our advertising, or improve our database accuracy
• Data analytics providers, for testing purposes

INTERNET OR OTHER SIMILAR ELECTRONIC NETWORK ACTIVITY

• Advertising networks, to provide personalized advertisements
• Consumer data resellers, with whom we form indirect partnerships
• Data analytics providers, to enable TUI to understand and improve the delivery of advertisements, enhance or modify our Online Services, Product and understand and optimize consumer experience
• Marketing companies, to provide personalized advertisements and enhance your experience
• Internet service providers

GEOLOCATION DATA

• Data analytics providers, for analytics and testing purposes

SENSORY DATA

• Government entities and regulators, to respond to regulator request
• Law enforcement agencies, only as required by law
• Parties to litigation, to provide required documentation for litigation

PROFESSIONAL OR EMPLOYMENT-RELATED INFORMATION

• Advertising networks, to provide personalized advertisements
• Affiliates, or the TransUnion family of companies, in order to deliver, enhance or develop the Products and those of TransUnion companies, or for internal business purposes
• Consumer data resellers , with whom we form indirect partnerships
• Data analytics providers, to enable TUI to understand and improve the delivery of advertisements, enhance or modify our Online Services, Product, and understand and optimize consumer experience
• Marketing companies, to provide personalized advertisements and enhance your experience

INFERENCES DRAWN FROM OTHER PERSONAL INFORMATION

• Advertising networks, to provide personalized advertisements
• Affiliates in the TransUnion family of companies, in order to deliver, enhance or develop the Products and those of TransUnion companies, or for internal business purposes
• Consumer data resellers, with whom we form indirect partnerships
• Data analytics providers, to enable TUI to understand and improve the delivery of advertisements, enhance or modify our Online Services, Product and understand and optimize consumer experience
• Marketing companies, to provide personalized advertisements and enhance your experience

3. Disclosing personal information for a business purpose

We disclose personal information with different third parties. For the reasons listed below, during the prior 12 months, we may have disclosed for a business purpose the following categories of personal information, by category of third parties. Please note that TUI may share your personal information for a targeted advertising purpose.

Note that a specific piece of personal information may fall into one or more categories of personal information.

IDENTIFIERS AND PERSONAL INFORMATION CATEGORIES LISTED IN THE CALIFORNIA CUSTOMER RECORDS STATUTE

• Commercial partners, or non-affiliated third parties which TUI may employ or partner with in order to provide and continually enhance the Product and deliver personalized offers to you
• Consumer data resellers
• Data analytics providers, to enable TUI to understand and improve the delivery of advertisements, enhance, or modify our Online Services, Product and understand consumer experience
• Marketing companies, to provide personalized advertisements and enhance the your experience
• Service providers, third parties with whom we contract to enable certain services, such as, for example, email list and email management, marketing, customer support, Product fulfillment, consumer research, surveys, contests, promotions; and to enable personalization of offers based on your credit profile, and so that you can interact more easily with a third party through pre-filled forms or applications, or to enable a data pass when you redirect from the Online Services website to a third party site

CHARACTERISTICS OF PROTECTED CLASSIFICATIONS UNDER STATE OR FEDERAL LAW

• Commercial partners, or non-affiliated third parties which TUI may employ or partner with in order to provide and continually enhance the Product and deliver personalized offers to you
• Consumer data resellers
• Marketing companies, to provide personalized advertisements and enhance the your experience
• Data analytics providers, to enable TUI to understand and improve the delivery of advertisements, enhance, or modify our Online Services, Product and understand consumer experience
• Third parties with whom we contract to enable certain services, such as, marketing, consumer research, surveys, contests, promotions; and to enable personalization of offers based on your credit profile, and so that you can interact more easily with a third party through pre-filled forms or applications, or to enable a data pass when you redirect from the site to a third party site

COMMERCIAL INFORMATION

• Consumer data resellers
• Marketing companies, to provide personalized advertisements and enhance the your experience
• Data analytics providers, to enable TUI to understand and improve the delivery of advertisements, enhance, or modify our Online Services, Product and understand consumer experience
• Third parties with whom we contract to enable certain services, such as, marketing, consumer research, surveys, contests, promotions; and to enable personalization of offers based on your credit profile, and so that you can interact more easily with a third party through pre-filled forms or applications, or to enable a data pass when you redirect from the site to a third party site

BIOMETRIC INFORMATION

• We do not sell this category of information

INTERNET OR OTHER SIMILAR ELECTRONIC NETWORK ACTIVITY

• Commercial partners
• Consumer data resellers
• Marketing companies
• Data analytics providers, to enable TUI to understand and improve the delivery of advertisements, enhance, or modify our Online Services, Product and understand consumer experience
• Internet service providers
• Service providers, third parties with whom we contract to enable certain services, such as, for example, email list and email management, marketing, customer support, Product fulfillment, consumer research, surveys, contests, promotions; and to enable personalization of offers based on your credit profile, and to interact more easily with a third party through pre-filled forms or applications, or to enable a data pass when you redirect from the Online Services website to a third party site
• Third parties with whom we contract to enable certain services, such as, marketing, consumer research, surveys, contests, promotions; and to enable personalization of offers based on your credit profile, and so that you can interact more easily with a third party through pre-filled forms or applications, or to enable a data pass when you redirect from the site to a third party site

GEOLOCATION DATA

We disclose personal information that may allow a third party to determine location, such as IP addresses, to the following parties:

• Commercial partners
• Consumer data resellers
• Internet service providers
• Marketing companies
• Data analytics providers, to enable TUI to understand and improve the delivery of advertisements, enhance, or modify our Online Services, Product and understand consumer experience
• Third parties with whom we contract to enable certain services, such as, marketing, consumer research, surveys, contests, promotions; and to enable personalization of offers based on your credit profile, and so that you can interact more easily with a third party through pre-filled forms or applications, or to enable a data pass when you redirect from the site to a third party site

SENSORY DATA

• We do not disclose this category of information

PROFESSIONAL OR EMPLOYMENT-RELATED INFORMATION

• Commercial partners
• Consumer data resellers
• Marketing companies
• Data analytics providers, to enable TUI to understand and improve the delivery of advertisements, enhance, or modify our Online Services, Product and understand consumer experience
• Service providers, third parties with whom we contract to enable certain services, such as, for example, email list and email management, marketing, customer support, Product fulfillment, consumer research, surveys, contests, promotions; and to enable personalization of offers based on your credit profile, to interact more easily with a third party through pre-filled forms or applications, or to enable a data pass when you redirect from the Online Services to a third party site
• Third parties with whom we contract to enable certain services, such as, marketing, consumer research, surveys, contests, promotions; and to enable personalization of offers based on your credit profile, and so that you can interact more easily with a third party through pre-filled forms or applications, or to enable a data pass when you redirect from the site to a third party site

NON-PUBLIC EDUCATION INFORMATION (PER THE FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT)

• We do not disclose this category of information

INFERENCES DRAWN FROM OTHER PERSONAL INFORMATION

• Commercial partners, or non-affiliated third parties which TUI may employ or partner with in order to provide and continually enhance the Product and deliver personalized offers to you
• Consumer data resellers, with whom we form indirect partnerships
• Marketing companies
• Data analytics providers, to enable TUI to understand and improve the delivery of advertisements, enhance, or modify our Online Services, Product and understand consumer experience
• Service providers, third parties with whom we contract to enable certain services, such as, email list and email management, marketing, customer support, Product fulfillment, consumer research, surveys, contests, promotions; and to enable personalization of offers based on your credit profile, and so that you can interact more easily with a third party through pre-filled forms or applications, or to enable a data pass when you redirect from the Online Services to a third party site
• Third parties with whom we contract to enable certain services, such as, marketing, consumer research, surveys, contests, promotions; and to enable personalization of offers based on your credit profile, and so that you can interact more easily with a third party through pre-filled forms or applications, or to enable a data pass when you redirect from the site to a third party site

4. Your authorization to TUI

When you enrolled, you provided written instruction and authorization for TUI to obtain your credit information from TransUnion, Experian, and Equifax (depending on the Product) to display it to you, as well as to use and share the information provided by you, along with your credit information, to obtain personalized offers from third parties and display personalized offers to you.

5. Corporate reorganization

In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, we may share your personal information. We may also share your personal information if we undergo bankruptcy or liquidation, in the course of such proceedings.

6. Cookies, pixels, and similar technology

Information collected passively via cookies and similar technology: A cookie is a small text file that a web server places on your computer or device when your browser accesses a website. Cookies store data specific to a client or website and are designed to create a record of or “remember” online activity. We use cookies for a number of different purposes. Some cookies are necessary to ensure the site functions properly and some enable us to deliver an individualized Online Services experience.

When you use the site, TUI, commercial partners, and service providers may use cookies and similar technologies like pixel tags and web beacons to facilitate your access to and use of our Online Services, and to improve, enhance and personalize your experience for advertising purposes on the site. For example, we use this technology to recognize you each time you return to the site using the same computer or device so that you do not have to re-enter all of your personal information on each visit. Like many websites, we also use this technology to collect and store information to customize user experience, track activity on the site, as well as to deliver and measure online advertising, including personalized offers and retarget advertisements. TUI advertising commercial partners and service providers may also use cookies or similar technologies for the management and delivery of email communications so that, for example, TUI knows when an email communication to you has been delivered or opened.

You generally have the ability to accept or decline most types of cookies. We do not respond to browser Do Not Track requests. Most web browsers give you a choice to modify your browser settings to decline some or all non-necessary cookies. We provide you choices to manage your privacy and sharing in the Cookies Settings section, also located in the footer of our website. Not accepting cookies may make certain features of the site unavailable to you. If you would like more information about cookies, you can visit http://www.cookiecentral.com/n_cookie_faq.htm.

Partners and service providers may separately permit you to opt-out of some or all of their information collection activities.

7. Analytics technologies

TUI uses a number of additional third-party tools for analytical and advertising purposes. These tools provide internet or similar electronic network activity, geolocation information, and inferences drawn from other electronic network activity, collected over time, and from other websites on which TUI displays advertisements and enables TUI to understand and improve the delivery of advertisements, enhance, or modify our Online Services and Product, as well as understand consumer experience. We may also use this information to segment, enhance or modify our advertisements and to personalize your experience.

Analytics Disclosure: TUI uses Google Analytics 360, including Google Tag Manager and Google Ads. If you would like to learn more about Google Analytics, or opt-out of this data collection and sharing activity, please use this link: https://www.google.com/policies/privacy/partners/.

8. Personalized (third-party) offers

In order to provide you with an optimal consumer experience, TUI strives to continually personalize the Product, including the offers displayed on the Product dashboard and delivered to you by email for some of the Online Services. TUI wants users to have access to personalized offers based on individual user credit experience, and not generic offers that may or may not be suited to an individual user’s needs.

Personalized offers, including prescreen offers, are third-party offers displayed automatically on the Product dashboard, via email, and in addition to other display locations as part of the Product. Permission to use your credit information to show you personalized offers on the Product dashboard was provided by you during the enrollment process.

TUI may share personal information with affiliates and commercial partners or service providers so that the personalized offers can be generated by the third party and then displayed to you. For example, in order to enable the delivery of a personalized offer from a lender (itself or through an aggregator of loan offers), the lender must have access to your personal information to extend an appropriate offer for which you may be eligible. The lender may separately access your credit information if it has a lawful purpose to do so.

In addition to seeing personalized offers on the Product dashboard, you may receive personalized offers via email or other forms of communication from TUI. For TransUnion Credit Monitoring, you may elect to opt-out of receiving personalized offers via certain methods (email) by using the controls in the Your Profile settings tab in the Product. The Your Profile settings tab also allows you to opt-out of receiving certain other categories of commercial email from TUI. Each commercial email from TUI also includes an unsubscribe link.

For zendough and TrueIdentity, if you prefer not to receive such personalized offer information, you may indicate your preference by marking the appropriate box when you register, place an order, or update your account information, and TUI will not send you any promotional materials.

You have the choice to opt out of our marketing email communications at any time by using the opt-out provision at the bottom of every email.

9. Links to other sites or services

This Notice does not apply to other third-party sites or services. Please remember that personalized offers and other opportunities presented on Online Services will include a link or linking ability to a third-party site or application. If you click on a link or browse to a third-party site from our site/service, your activity and interaction is subject to that third party's rules and policies.

These third-party sites are not controlled by TUI and TUI is not responsible for the privacy practices or the content of any such third-party site. Personalized offers are provided to you as a convenience and the display of a third party offer through our Online Services is not an endorsement by TUI. If you provide any information to a third party, then the third party’s respective privacy policies will apply with regard to any information you provide or which may be collected by the third party. If, however, the third-party site provides that TUI’s Privacy Notice applies to the information provided by you on that site, then TUI’s policies will apply to the information collected for the purpose of enrolling in the Product once we receive the information from you or the third party.

We recommend that you review the online privacy statements on these other sites to understand their privacy practices and treatment of personal information so that you can make an informed decision regarding your use or interaction with their site/service.

10. TransUnion’s credit database

We limit access to TransUnion’s consumer credit database and make it available to only the following:

• entities with a permissible purpose to receive it, as defined in the Fair Credit Reporting Act (FCRA);
• entities with a permitted use under Title V of the Gramm-Leach-Bliley Act;
• companies who resell TransUnion data as permitted under law; and
• companies who process data on behalf of TUI or TransUnion.

Access to information in this database not subject to the FCRA may be provided to companies and other entities for research and other purposes.

Under the FCRA, our parent company, TransUnion, may provide information to companies that provide you with pre-approved offers of credit or insurance. If you prefer not to receive such offers, you may opt-out by calling 1-888-5OPTOUT or visiting https://www.optoutprescreen.com.

11. Market research

From time-to-time, you may be presented with a survey or other questions to solicit feedback about your use of the Product and the Online Services. Your participation in these types of market research activities is optional. Should you choose to participate, we may use information you provide to improve and/or develop our Product and Services.

12. Securing personal information

We maintain a comprehensive Information Security Program with administrative (policies, standards, and processes), physical, and technical controls designed to protect the confidentiality, integrity, and accessibility of your personal information.

For more information about our security practices, please review our Security Policy for TransUnion Credit Monitoring, zendough, and TrueIdentity.

13. Retaining personal information

We retain your personal information for as long as reasonably necessary to fulfill the purposes for which it was collected or processed, as described in this Notice. For instance, we retain your personal information, collected through our services and websites, for as long as your account is active or as needed to provide services to you and our customers. When determining retention periods, we consider our relationship with you and your information, the nature and sensitivity of the information, and what is reasonably necessary and proportionate to provide and improve our services. We also adjust retention periods to comply with our legal, reporting, or accounting obligations, to resolve disputes, and to enforce our agreements. We regularly review our retention periods and assess our data minimization practices, retaining the least amount of information for the shortest retention period, while still upholding all our obligations.

14. Managing your account

You are responsible for maintaining the accuracy of the information that you provide to TUI and for your own password management and online safety when accessing this Product. Please always consider best practices like changing your password routinely, using a strong password that is not the same as you use for other websites, and not accessing the Product with unsecure devices or unsecure networks.

You may make changes to your account settings on the Your Profile settings tab, including your email address, phone number, mailing address, payment card information and password details. You may also cancel your account online, if applicable, and manage communications preferences related to certain types of communications (email and SMS/MMS) from TUI to you.

Please note that although you may manage communication preferences so that you do not receive commercial communications from TUI outside of the Product dashboard, you may not decline to receive transactional communications from TUI, which contain information about your account and the Product. Please also note that important information about your account, including the alerts that are a part of the Product, will be sent to the email address and/or phone number that you have provided, if applicable. It therefore is important that you update your account information when necessary and actively check email communications from TUI.

15. Consumer privacy rights

In some instances, TUI offers its services to customers as a service provider/processor or subject to other exceptions under the applicable state privacy laws. Where TransUnion is acting as a service provider/processor, we are processing data on behalf of others who will provide you applicable privacy rights.

If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you may take advantage of certain privacy rights, such as to request access, correction, or deletion of your personal information. You also have the right to appeal a denial of your privacy rights.

To make a verifiable consumer request for access, correction, or deletion (subject to limitations and exceptions under applicable law), visit our Consumer Privacy Rights page. If you have a TransUnion account, you can use it to make your request. You can also make your request without setting up an account. To do so, we will need your name, address, email, phone number, date of birth, and either your full Social Security number or the last four digits. Depending on the type of request, we may also need you to answer knowledgebase questions regarding data associated with you and/or provide a passcode sent to your phone number. We will use that information to verify your identity so we can respond to your request.

Because we may “sell” or “share” personal information or engage in “profiling,” “targeted advertising,” “cross-context behavioral advertising,” or use sensitive personal information, consistent with the defined terms in applicable state laws, you may also exercise your right to opt out of such sales, sharing, profiling/automated decision making, targeted advertising, or cross-context behavioral advertising, and limit our use of your sensitive personal information.

To make an opt-out request or to limit our use of your sensitive personal information (subject to limitations and exceptions under applicable law), visit our Opt-Out Request page or visit the following links: Do Not Sell or Share My Personal Information and Limit the Use of My Sensitive Personal Information.

Right to know 

You have the right to request a disclosure of the personal information collected, sold, and shared about you and the purpose for doing so, unless such request proves impossible or would involve disproportionate effort. Upon submission of a verifiable consumer request, we will provide you with the following information.

• The categories of personal information we collected about you;
• The categories of sources from which we collected your personal information;
• Our business or commercial purpose for collecting or selling/sharing the personal Information;
• The categories of third parties to whom we sold or disclosed personal Information; and
• The specific pieces of personal information we collected about you.

To make a verifiable consumer request to know, visit our Consumer Privacy Rights page. If we provide this information to you electronically, the information will be in a portable format. To the extent that it is technically feasible, we will provide you the information in a readily useable format that you can easily transfer to another entity.

Right to correct

You have the right to correct inaccurate personal information that we collect or maintain about you, subject to verification. To make a verifiable consumer request to correct, visit our Consumer Privacy Rights page.

Right to delete

If we collected or maintain personal information about you, you have the right to request the deletion of this personal information, unless an exception applies under applicable law. To make a verifiable consumer request to delete, visit our Consumer Privacy Rights page.

Right to be free from discrimination

You have the right to be free from discrimination for exercising any of your consumer privacy rights. If you choose to exercise any of your rights, we will not:

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

Right to opt-out of the sale/sharing of personal information

You have the right to opt out of the sale/sharing of your personal information to third parties. To exercise your right to opt out of the sale or sharing of your personal information, through trackers or cookies please visit the Cookies Settings section, also located in the footer of our website. To opt out of the sale or sharing of your personal information, visit our Do Not Sell or Share My Personal Information page.

Right to opt out of profiling/automated decision making, targeted or cross-context behavioral advertising

You have the right to opt out of our use of your personal information for purposes of profiling, automated decision making, targeted or cross-context behavioral advertising. To opt out of these uses, visit our Opt-Out Request page.

Right to limit the use of sensitive personal information

You have the right to limit how we use your sensitive personal information. Depending on the applicable law, sensitive personal information may include: Social Security number, driver’s license number, biometric information, precise geolocation data, and racial and ethnic origin. To limit the use of your sensitive personal information, visit our Limit the Use of My Sensitive Personal Information page.

Right to appeal

If you believe we have denied any of your consumer privacy rights in error, you have the right to appeal by replying to our denial message or any communication from us.

16. Authorized agent

Using an authorized agent (with or without power of attorney) to submit an opt-out request or a request to limit the use of a consumer’s sensitive personal information:  In order to submit an opt-out request or a request to limit on behalf of another consumer, please provide written permission, signed by the applicable consumer, authorizing the agent to submit the opt-out request. The name of the agent submitting the request must match the name on the authorization.

In order for us to locate the consumer’s record, please also include the consumer’s first and last name (middle name optional) and their address (including unit number, city, state, and zip code). You may also provide the consumer’s Social Security number and date of birth. While those fields are optional, this information makes it easier for TransUnion to locate the consumer’s information and complete the request.

Documentation may be sent to the addresses listed below.

Using an authorized agent without power of attorney to submit a verifiable privacy request for access, correction, or deletion of a consumer’s personal information:  In order to submit a verifiable request for access, correction, or deletion on behalf of another consumer, an authorized agent without power of attorney must provide one item from each of the two sections below.

1. Signed permission from the applicable consumer authorizing the agent to submit the verifiable privacy request on their behalf, including a description of the type of privacy request(s). The name of the agent submitting the request must match the name of the authorization.
2. The applicable consumer must verify their own identity directly with the business by submitting information or documentation that provides sufficient proof of identification, such as:
   1. a Social Security number or a copy of a Social Security card issued by the Social Security Administration,
   2. a certified or official copy of a birth certificate issued by the entity authorized to issue the birth certificate, or
   3. a copy of a driver's license or an identification card issued by the motor vehicle administration or any other government issued identification.

This secondary identification must include or reference the same name as stated in the signed permission form. The submission must also include sufficient information for TransUnion to locate the consumer’s file. More information can be found on TransUnion’s Consumer Privacy Rights page by selecting the appropriate consumer request option. 

Documentation may be sent to the addresses listed below.

Using an authorized agent with power of attorney to submit a verifiable privacy request for access, correction, or deletion of a consumer’s personal information:  In order to submit a verifiable request for access, correction, or deletion on behalf of another consumer, an authorized agent with power of attorney must provide the valid power of attorney executed under applicable law.

The submission must also include sufficient information for TransUnion to locate the consumer’s file. More information can be found on TransUnion’s Consumer Privacy Rights page by selecting the appropriate consumer request option.

Documentation may be sent to: 

TransUnion LLC
PO Box 130
Woodlyn, PA 19094

You can also email the information to privacy@transunion.com

To protect the confidentiality of your data, you and/or your authorized agent may choose to submit your data using confidentiality features offered by your email provider.

All personal information provided as part of this process will be deleted after verification has been completed.

17. Personal information of children

Our services are not intended for use by individuals under the age of eighteen (18). You must be at least eighteen (18) to access our Online and Offline Services and Products or become a member of any membership program entitled to membership benefits. If we learn that we have collected or received personal information from individuals under the age of eighteen (18), we will delete the personal information. We do not knowingly sell personal information of children under the age of eighteen (18) years.

Parent or Guardian Privacy Opt-Out Request (child under 18 years)

If you believe we have collected personal information from individuals under the age of eighteen (18), a parent or guardian may make a data privacy opt-out request or limit our use of sensitive personal information (subject to limitations and exceptions under applicable law) by visiting our Opt-Out Request page or by visiting the following links: Do Not Sell or Share My Personal Information and Limit the Use of My Sensitive Personal Information.

18. Contact information

If you have questions or concerns regarding this Notice or the protection of your personal information and privacy rights, you may contact us in the following ways:

Email	privacy@transunion.com
Phone	1-866-310-8783
Postal Mail	TransUnion Data Privacy Request P.O. Box 130 Woodlyn, PA 19094

19. Notice changes and effective date

This Notice is subject to change at any time. If we make any changes to this Notice, we will post the revised Notice on this page with its effective date. Use of the Product following any change constitutes your acceptance of the Notice then in effect. We encourage you to check the website periodically for updates to our Notice.