1. Personal Information we collect
2. Purpose for the collection of Personal Information
3. Sharing your Personal Information
4. Advertising opt outs5. Securing your Personal Information
6. Personal Information of children
7. California privacy rights
8. Contact information
9. Notice changes and effective date
Introduction
This Privacy Notice (“Notice”) provides information about howTrans Union LLC (and its United States subsidiaries and affiliates) (“We”, “Us”,“Our”) collects, uses, and shares personal information in its TruAudience®Marketing Solutions, including TruAudience Platform, TruAudience Data Marketplace, and TruAudience Identity Solutions.
Summary
Purpose and Use. Through TransUnion’s TruAudience MarketingSolutions 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.
Data Collected. The information we collect (“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, protected classification characteristics under California or federal law, commercial information, internet or other similar network activity geolocation data, professional or employment information, and inferences drawn from other personal Information. We do not collect biometric data sensory data, or non-public education information (per theFamily Educational Rights and Privacy Act) categories of Personal Information, and we do not 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. In addition, as a part of enabling our TruAudience Marketing Solutions, we may use service providers.We collect your Personal Information for different purposes. We describe the purpose for collecting Personal Information, listed by category ofPersonal Information in the chart below. Please note that a specific piece of PersonalInformation may fall into one or more categories of Personal Information.
3. Sharing your Personal Information
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, we share your Personal Information as outlined below.
We disclose and/or share your Personal Information with different third parties. We describe the third parties to whom we share or sell yourPersonal 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.
We share Marketing Data, including Personal Information, with our customers and business partners (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 theDigital Advertising Alliance (DAA).
4. Advertising opt outs
We take our commitment to privacy seriously. If you prefer to optout of receiving marketing messages, we recommend that you visit the Association of National Advertisers (ANA) and register on their consumer website: 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:
Please note that if yourInternet 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). 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 all participating companies’ targeted advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintains cookies on your internet connected device
Please note that if you delete the cookies from your internet connected device, you will need to repeat the opt-out process outlined above.
5. Securing your Personal Information
We maintain a comprehensive Information Security Program with administrative (policies, standards, and processes), physical, and technical controls to ensure the security and confidentiality of your information.
6. Personal Information of children
In our TruAudience Marketing Solutions, we define children as individuals under age 18, and we do not knowingly use, sell or disclose for a business purpose information on children.
7.California privacy rights
If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA).
Right to know
You have the right to request a disclosure of the Personal Information collected, sold, and shared about you over the past 12 months and the purpose for doing so. Upon submission of a verifiable consumer request, we will provide you with the following information.
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.
To make a verifiable consumer request to know, visit
www.transunion.com/consumer-privacyIf 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 first and last name, postal address, date of birth, and the last four digits of your Social Security Number. We will use that information to verify your identity so we can respond to your request.
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.
To make a verifiable consumer request to know, visit
www.transunion.com/consumer-privacyIf 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 first and last name, postal address, date of birth, and the last four digits of your Social Security Number. We will use that information to verify your identity so we can respond to your request.
Right to deletion
If we collected Personal Information from you, you have the right to request the deletion of this Personal Information.
To make a verifiable consumer request to delete, visit https://www.transunion.com/
consumer-privacy 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 first and last name, postal address, date of birth, and the last four digits of your Social Security Number. We will use that information to verify your identity so we can respond to your request.
Right to be free from discrimination
You have the right to be free from discrimination for exercising any of the California consumer privacy rights. If you choose to exercise any of your CCPA rights, we will not:
Right to opt-out of the sale of Personal Information
You have the right, at any time, to direct a business that sells your personal information to third parties to not sell your Personal Information. If you would like to exercise this right, visit our “Do not sell my personal information" page.
Authorized agent
A consumer has the right to appoint another person to submit privacy requests on their behalf.
Using an authorized agent without power of attorney to submit a request to know or delete
In order to submit a request to know or delete Personal Information on behalf of another consumer, an authorized agent without power of attorney must provide one item from each of the three sections below.
1. Signed permission from the consumer authorizing the agent to submit the CCPA privacy request(s) on their behalf. Describe the type of privacy request(s) being requesting (know/disclosure report and/or deletion).
AND
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:
AND
3. Information or documentation that provides sufficient proof of identification to verify your identity, such as:
Using an authorized agent with power of attorney to submit a request to know or delete
In order to submit a request to know or delete Personal Information 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 sections below.
1. The valid power of attorney executed lawfully under CaliforniaProbate Code sections 4000 to 4465.
AND
2. Information or documentation that provides sufficient proof of identification to verify your identity, such as:
Using an authorized agent to submit an opt-out request
In order to submit a request to opt out of the sale of Personal Information, on behalf of another consumer, please provide the following:
· Written permission, signed by the consumer, authorizing the agent to submit the opt-out request.
Please send your letter and documentation to the following address:
TransUnion Data Privacy Request
P.O. Box 130
Woodlyn, PA 19094
Right to notice.
You have the right to receive timely notice, at or before the point of collection, about the categories of Personal Information we will collect from you and the purposes for which we will use the Personal Information.
8. 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:
All Locations
9. Notice changes and effective date
We may periodically make changes to this Notice and recommend that you check back to review this Notice so that you always know how we collect, use, and share your Personal Information. The effective date denotes the date that this Notice applies to our services.
