TruAudience® Marketing Solutions Privacy Notice

This notice was last modified on and has an effective date of December 16, 2022.

This Privacy Notice (“Notice”) provides information about how TransUnion LLC (and its United States subsidiaries and affiliates) (“we,” “us,” “our”) handles personal information about you and describes the rights you may have regarding your personal information. This Notice applies to the online and offline collection, use, sale, sharing, and disclosure of personal information in Our TruAudience^® Marketing Solutions, including TruAudience Platform, TruAudience Data Marketplace, and TruAudience Identity Solutions.

Notice at Collection: We collect personal information as detailed in this Privacy Notice. The categories of personal information that we collect are listed below under “Personal information we collect,” and the purposes for which we collect and use personal information are listed below under “Purpose for the collection of 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.

Click here for TransUnion’s California Consumer Privacy Act (CCPA) Metrics.

Summary

Through TransUnion’s TruAudience Marketing Solutions services, we enable our business partners to provide marketing solutions. In an effort to provide relevant products and services to consumers, these businesses use our data and technology to create, deploy, and measure targeted advertising programs across marketing and digital advertising technology ecosystems. In addition, we may aggregate and depersonalize data for analytical purposes, to provide reporting to our business partners, and for measuring advertising performance. And as a part of enabling TruAudience Marketing Solutions services, we may use service providers.

The information we collect and maintain (“Marketing Data”) for our TruAudience Marketing Solutions services is separate from traditional consumer reporting agency information. Marketing Data may include information on consumers, households, internet connected devices, properties and businesses as well as advertising program performance data. Marketing Data includes information about consumers such as demographics, life events, household composition, public records, or firmographics. Demographic data includes information such as age, gender, income, occupation, education, and marital status. Life events data includes information such as a recent move or home purchase. Household composition data includes information such as number of people in a household. Public records data includes information such as summarized U.S. Census data, geographic data, and property data from local tax assessor and recorded deed information. Firmographic data includes information such as type of business, years in business, size of business, and job titles.

1. Personal information we collect

We collect the following categories of personal information: identifiers, personal information categories listed in the California Customer Records Act, characteristics of protected classifications under California or federal law, commercial information, internet or other similar electronic network activity, geolocation data, professional or employment-related information, and inferences drawn from other personal Information. We do not collect biometric information, sensory data, non-public education information (per the Family Educational Rights and Privacy Act), nor do we collect information directly from consumers.

2. Purpose for the collection of personal information

Through TransUnion’s TruAudience Marketing Solutions, we enable our business partners to communicate with consumers across marketing and digital advertising technology ecosystems. In an effort to provide relevant products and services to consumers, these businesses may use our data and technology to create, deploy, and measure targeted advertising programs. We collect information as outlined below and use it for permitted marketing uses. We may also use the information we collect for analytical purposes, to provide reporting to our business partners, and for measuring marketing performance.

We describe the purpose for collecting personal information, listed by category of personal information in the chart below. Please note that a specific piece of personal information may fall into one or more categories of personal information.

3. Disclosing for a business purpose and selling/sharing personal information

We sell/share Marketing Data, including personal information, with our customers and business partners, such as marketing and digital advertising technology companies like platform providers, content publishers, and other entities that provide marketing solutions, to facilitate the creation and deployment of digital advertising. For example, when we segment our data into groups of consumers (“Audiences”), we share them using unique identifiers (“Unique IDs”). We may also share aggregated and depersonalized data with our customers and business partners for analytical purposes, including measuring advertising performance and reporting. Many of our customers and business partners follow the guidelines provided by the Network Advertising Initiative (“NAI”) members and/or the Digital Advertising Alliance (“DAA”).

In order to enable our business partners to communicate with consumers across marketing and digital advertising technology ecosystems and to provide relevant products and services to consumers, during the prior 12 months, we may have sold or shared for a commercial purpose or disclosed for a business purpose your personal information to different third parties, as detailed below.

4. Advertising (cookie-based) opt-out requests

If you prefer to opt out of receiving marketing messages, we recommend that you visit the Association of National Advertisers (ANA) and register on their consumer web site: https://dmachoice.thedma.org/. TransUnion applies DMAChoice opt-outs to our Marketing Data to implement your preferences and comply with ANA guidelines.

You may also opt out of digital advertising through the TruAudience Data Marketplace. By clicking below, this will opt-out the household Internet Protocol (IP) address from which you are currently accessing this site: Opt Out.

Please note that if your Internet Protocol (IP) address changes (for example, if your router “reboots” or resets itself), you will need to repeat the opt-out process outlined above.

In addition, you may choose to opt out of other digital advertising through the NAI’s Consumer Opt-Out Program, DAA’s Consumer Choice Page, or the European Union/European Economic Area (“EU/EEA”) Opt-Out. By clicking on the “Opt-Out” links below, you will be directed to the respective opt out website(s) where your computer will be scanned to determine who maintains cookies on your internet connected device. At that time, you can either choose to opt out of the participating companies’ cookie-based targeted advertising or you can choose to opt out of cookie-based targeted advertising by selecting individual companies who maintains cookies on your internet connected device.

• Association of National Advertisers opt-out registration
• Network Advertising Initiative (NAI) Opt-Out
• Digital Advertising Alliance (DAA) Opt-Out
• European Union (EU) /European Economic Area (EEA) Opt-Out

Please note that if you delete your cookies or you visit this site using a different device or browser, you will need to repeat the opt-out process outlined above.

5. Securing Personal Information

We maintain a comprehensive Information Security Program with administrative (policies, standards, and processes), physical, and technical controls to help ensure the security and confidentiality of your information.

6. Personal Information of Children

Our TruAudience Marketing Solutions businesses are not intended for use by individuals under the age of eighteen (18). 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. If you believe we have collected personal information from individuals under the age of eighteen (18), a parent or guardian may call us for more information about making a data privacy inquiry or request, as described in the “Contact information” section below.

We do not knowingly sell personal information of minors under the age of eighteen (18) years.

7. Consumer 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. 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 the 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. You have the right to appeal a denial of your privacy rights.

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.

To make a verifiable consumer request or appeal (subject to limitations and exceptions under applicable law), visit our Consumer Privacy 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’ll need your first and last name, address, date of birth, and the last four digits of your Social Security number. We’ll use that information to verify your identity so we can respond to your request.

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.
• The specific pieces of personal information we collected about you.

To make a verifiable consumer request to know, visit our Consumer Privacy 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 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 page.

Right to be free from discrimination

You have the right to be free from discrimination for exercising any of the 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 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. Sensitive personal information includes, but is not limited to, Social Security number, driver’s license number, biometric information, precise geolocation, 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, you have the right to appeal by visiting our Consumer Privacy page.

8. Authorized agent

If a consumer is using an authorized agent to submit a consumer privacy request, the following is required.

Using an authorized agent without power of attorney to submit a consumer privacy request.  In order to submit a request 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 consumer authorizing the agent to submit the privacy request(s) on their behalf. Describe the type of privacy request(s).
2. The 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, an identification card issued by the motor vehicle administration or any other government issued identification.

Using an authorized agent with power of attorney to submit a consumer privacy request.  In order to submit a request on behalf of another consumer, an authorized agent with power of attorney pursuant to California Probate Code sections 4000 to 4465, must provide one item from each of the two sections below.

1. The valid power of attorney executed lawfully under California Probate Code sections 4000 to 4465.
2. Information or documentation that provides sufficient proof of identification to verify your identity, 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, an identification card issued by the motor vehicle administration or any other government issued identification.

Using an authorized agent to submit an opt-out request.  In order to submit an opt-out request on behalf of another consumer, please provide written permission, signed by the consumer, authorizing the agent to submit the opt-out request. Please send your letter and documentation to the postal address in the “Contact information” section below.

9. 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.

10. 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:

11. 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.