TruAudience® Marketing Solutions Privacy Notice

Effective Date: 08/24/2021
Last Updated: 08/24/2021

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.

Category of Personal Information

Personal Information we collect, by source category

Identifiers andPersonal Information categories listed in the California Customer Records statute

Including, but not limited to,  real name, alias, postal address, unique personal identifier, online or mobile identifier, InternetProtocol (IP) address, email address, account name, Social Security Number, driver’s license number, passport number, or other similar identifiers




Note that personal information in this

category may overlap with other categories.

This Personal Information is collected from the following sources:

  • Advertising networks
  • Banks/credit unions
  • Collection agencies
  • Credit reporting agencies
  • Data brokers, including data aggregators, data compilers, and data originators
  • Financial technology(Fintech) companies
  • Government (information not in public records)
  • Insurance carriers
  • Marketing companies
  • Public records made lawfully available from government agencies
  • Operating systems and platforms
  • TransUnion Companies

Protected  classification characteristics under California or federal law

An individual’s age  (40 years or older), race, color, ancestry, national origin, citizenship,  religion or creed, marital status, medical condition, physical or mental  disability, sex (including gender, gender identity, gender expression,  pregnancy or childbirth and related medical conditions), sexual orientation,  veteran or military status, genetic information (including familial genetic  information)

This Personal Information is collected from the following sources:

  • Banks/credit unions
  • Collection agencies
  • Credit reporting agencies
  • Data brokers, including data aggregators, data compilers, and data originators
  • Financial technology (Fintech) companies
  • Insurance carriers

Commercial information
 
Including, but not limited to, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

This Personal Information is collected from the following sources:

  • Banks/credit unions
  • Collection agencies
  • Credit reporting agencies
  • Data brokers, including data aggregators, data compilers, and data originators
  • Financial technology (Fintech) companies
  • Insurance carriers

Biometric data

Including, but not limited to, information pertaining to bodily characteristics, facial information, fingerprints, or eye scans

We do not collect this category of Personal Information.

Internet or other similar network activity

Including, but not limited to, internet browsing and search history and information regarding a consumer’s interaction with an internet website, application, or advertisement while using an internet connected device

This Personal Information is collected from the following sources:

  • Advertising networks
  • Data brokers, including data aggregators, data compilers, and data originators
  • Marketing companies
  • Operating systems and platforms

Geolocation data

Various technologies to determine your location, including, but not limited to, IP address, Wi-Fi access points, and cell towers.

This Personal Information is collected from the following sources:

  • Data brokers, including data aggregators, data compilers, and data originators

Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

We do not collect this category of Personal Information.

Professional or employment information 

Including, but not limited to, professional licenses, employment dates, employer name, employer information

This Personal Information is collected from the following sources:

  • Banks/credit unions
  • Collection agencies
  • Credit reporting agencies
  • Data brokers, including data aggregators, data compilers, and data originators
  • Financial technology (Fintech) companies
  • Insurance carriers

Non-public education information (per the FamilyEducational Rights and Privacy Act)

We do not collect this category of Personal Information.

Inferences drawn from other Personal Information

Inferences drawn from any of the Personal Information identified in this category to create a profile about a consumer reflecting the consumer’s site preferences, characteristics, behavior, personal preferences

This Personal Information is collected from the following sources:

  • Advertising networks
  • Banks/credit unions
  • Collection agencies
  • Credit reporting agencies
  • Data brokers, including data aggregators, data compilers, and data originators
  • Financial technology (Fintech) companies
  • Government (information not in public records)
  • Insurance carriers
  • Marketing companies
  • Public records made lawfully available from government agencies
  • Operating systems and platforms
  • TransUnion Companies



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.

Category of Personal Information

Purpose of Collection

Identifiers and Personal Information categories listed in the California Customer Records Act

The purposes for collecting, disclosing and/or selling this Personal Information include:

  • To operate and administer 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.
  • To deliver relevant content.
  • For the development and sale of TruAudience Marketing Solutions.

Protected  classification characteristics under California or federal law

The purposes for collecting, disclosing and/or selling this Personal Information include:

  • To operate and administer 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.
  • To deliver relevant content.
  • For the development and sale of TruAudience Marketing Solutions.

Commercial information

The purposes for collecting, disclosing and/or selling this Personal Information include:

  • To operate and administer 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.
  • To deliver relevant content.
  • For the development and sale of TruAudience Marketing Solutions.

Biometric data

We do not collect this category of Personal Information.

Internet or other similar network activity

The purposes for collecting, disclosing and/or selling this Personal Information include:

  • To operate and administer 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 may businesses use our data and technology to create, deploy, and measure targeted advertising programs.
  • To deliver relevant content.
  • For the development and sale of TruAudience Marketing Solutions.

Geolocation data

The purposes for collecting, disclosing and/or selling this Personal Information include:

  • For the development of TruAudienceMarketing Solutions.

Sensory data

We do not collect this category of Personal Information.

Professional or employment information 

The purposes for collecting, disclosing and/or selling this Personal Information include:

  • To operate and administer 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.
  • To deliver relevant content.
  • For the development and sale of TruAudience Marketing Solutions.

Non-public education information (per the FamilyEducational Rights and Privacy Act)

We do not collect this category of Personal Information.

Inferences drawn from other Personal Information

This Personal Information is collected from the following sources:

  • To operate and administer 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
  • To deliver relevant content.
  • For the development and sale of TruAudience Marketing Solutions.



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.

Category of Personal Information

Sold during the prior 12 months, by third party category

Disclosed for a business purpose during the prior 12 months, by third party category

Identifiers and Personal Information categories listed in the California Customer Records Act

  • Advertising networks
  • Marketing companies
  • Operating systems and platforms
  • Social networks
  • TransUnion Companies
  • Advertising networks
  • Marketing companies
  • Parties to litigation
  • Service providers
  • Social networks
  • TransUnion companies

Protected classification characteristics under California or federal law

  • Marketing companies
  • Operating systems and platforms
  • TransUnion Companies
  • Marketing companies
  • Operating systems and platforms
  • Parties to litigation
  • Service providers
  • TransUnion companies

Commercial information

  • Marketing companies
  • Operating systems and platforms
  • TransUnion Companies
  • Marketing companies
  • Operating systems and platforms
  • Parties to litigation
  • Service providers
  • TransUnion companies

Biometric data

We do not collect this category of Personal Information.

We do not disclose this  category of Personal Information.

Internet or other similar network activity

  • Advertising networks
  • Marketing companies
  • Operating systems and platforms
  • TransUnion Companies
  • Advertising networks
  • Marketing companies
  • Operating systems and platforms
  • Parties to litigation
  • Service providers
  • TransUnion companies

Geolocation data

We do not sell this category of Personal Information.

  • Parties to litigation

Sensory data

We do not sell this category of Personal Information

We do not disclose this category of Personal Information.

Professional or employment information

  • Marketing companies
  • Operating systems and platforms
  • TransUnion Companies
  • Marketing companies
  • Operating systems and platforms
  • Parties to litigation
  • Service providers
  • TransUnion companies

Non-public education information (per the Family Educational Rights and Privacy Act)

We do not sell this category of Personal Information

We do not disclose this category of Personal Information.

Inferences drawn from other Personal Information

  • Advertising networks
  • Marketing companies
  • Operating systems and platforms
  • TransUnion Companies
  • Advertising networks
  • Marketing companies
  • Operating systems and platforms
  • Parties to litigation
  • Service providers
  • TransUnion companies


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

Phone                                              1-866-310-8783
Post Mail
Please send your letter and documentation to the following address:
TransUnion Data Privacy Request
P.O. Box 130
Woodlyn, PA 19094

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.