In this Privacy Notice (“Notice”), we describe how Extend Insurance Services, LLC, d/b/a Via Benefits Insurance Services, a Delaware limited liability company, and our affiliates and/or subsidiary companies (collectively, “Via Benefits,” “we” or “us”) collect, use and otherwise process personal information about users of our websites and services which are offered through the website(s) listed in the section Scope of This Privacy Notice (“Website”)  The Services include providing you with information about insurance options, assisting with the selection of and enrollment in an insurance plan, providing you with an opportunity to interact with other users, and other products and services that may be available to you as are described and/or made available through the Website (“Services”).  Other Via Benefits websites may have different Privacy Policies.  You should check the specific privacy policy of other Via Benefits websites if you visit them.

1.             Scope of This Privacy Notice

Our use of the term “personal information” in this Privacy Notice includes other similar terms under applicable privacy laws, such as “personal data” and “personally identifiable information.”  In general, personal information includes any information that identifies, relates to, describes, or is reasonably capable of being associated, linked, or linkable with a particular individual. 

In this Privacy Notice we describe the collection, use, disclosure, and processing of personal information when we provide Services.  Separate Terms of Use may also apply, please see our website homepage for details.

Our collection, use, and disclosure and processing of personal information about individuals will vary depending upon the circumstances and Services we provide.  This Privacy Notice is intended to describe the overall privacy and data protection practices associated with the website found at https://optimizeretireebenefits.com/ and associated Services which it supports and describes.

This Privacy Notice also applies to personal information provided by users of our Services that we collect through your use of the Services, or at times, may be collected from other sources including from you directly as described below. 

This Privacy Policy does not apply to any third-party websites, services, products or mobile applications maintained by other companies, which are linked to or from our Services.  In addition, this Privacy Policy does not apply to any personal information that we collect and process that is subject to other privacy laws such as the Health Insurance Portability and Accountability Act (“HIPAA”) or the Gramm Leach-Bliley Act.

2.             Personal Information Collected

The information we collect about individuals varies depending upon the circumstances and the Services. Via Benefits collects personal information directly from individuals, automatically related to the use of the Services, and from third parties (such as current or former employers that provide us with information about individuals who may be interested in our Services).  It is not mandatory for you to provide any personal information, but a failure to do so might impact or restrict the type of service we are able to provide.

We collect the following categories of personal information:

• Name, Contact Information, and Other Identifiers: identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

• Usage Data: including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.

• Audio/Visual or other Sensory Data: including but not limited to photographs, CCTV, audio recordings and other audio, electronic, visual, thermal, olfactory, or similar information.

Below, we describe how we collect these different types of personal information.

3.             Sources of Personal Information

We collect information that you provide to us when you inquire about or use our Services.  We may also collect personal information

• From Website users or individuals, either directly (i.e., through information you submit to us, including via forms that you may complete and submit through our site) or indirectly (for example, by observing your actions on our websites).  This includes user-generated content.  If you post or communicate information through certain features of our Site or Services, such information may be publicly available to other users. For example, if you submit a comment to a blog post, your comment may be published on the Site and elsewhere, in which case separate Terms of Use may also apply, please see our Website homepage for details,

• From our clients in connection with us providing professional services to them,

• From our service providers (i.e., companies who are assisting us in fulfilling our contracts and carrying out our business, such as to perform mailings or to provide customer assistance),

• From third parties such as public databases, joint marketing partners, social media platforms (including individuals with whom you are friends or otherwise connected to on social media) and other third parties

• Social media sign-on: if you choose to log in to our community forum board through a social media service (e.g., Facebook, Twitter, Instagram, etc.), we collect your permission to access certain information from your profile with that social media service. If you post in or engage the community forum board through such a social media service, we may collect personal information about you related to those interactions.

Our Sites use cookies, pixels, tags, log-files, and other technologies, which may be provided by third parties, to collect information about a user’ from their browser or device, including, without limitation, your browser type, platform-dependent information, requested document, referrer URL, date and time of your visit, clickstream data (e.g., about the pages you view, links you click and date and time stamps for your activities on our Sites) and the IP address associated with your transactions in the system. This information that we collect automatically may be linked with other personal information we have collected. For more information, see the Cookies, Analytics and Personalization section below.

4.             Use of Personal Information

We may use the personal information that we collect about you for the following purposes:

• Providing our Services and related support: including in furtherance of our legitimate interests, performing our contracts, help fulfill your requests for products and Services; to communicate with you about you use of our Services; to respond to your inquiries; to facilitate your application for one or more Policies; to provide troubleshooting and other technical support; and for other customer service and support purposes.

• Protecting the integrity of the Services: including to verify your identity; to detect and prevent fraud and unauthorized activities; to facilitate software; to preserve the integrity of the Services and our systems, and prevent unauthorized access and activities; to enforce our applicable terms; and to protect the rights and safety of others

• Analyzing and improving the Services and our business: including to better understand how users access and use our Services; to evaluate and improve the Services and our business operations; to develop new features, offerings, and services; to conduct surveys and other evaluations; and for other research and analytical purposes.

• Personalizing the Services: including to personalize and/or tailor content we send or display on our Sites and Services (e.g., for your geographic area); to offer personalized help and instructions; and to otherwise personalize your experiences with the Services.

• Advertising, marketing and promotional purposes: including to send or display targeted marketing; to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to contact you about our Services, and those of our affiliates, as well as other information we think may interest you; to share participant testimonials; and to share your information with third parties so that they may contact you with information about products and services you may be interested in. Where required by applicable law, we will obtain your consent to use your personal information for marketing and related purposes. 

• Securing and protecting our business: including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct.

• Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with Users or third parties.

• Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; to maintain appropriate business records; to enforce company policies and procedures; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.

• Participation in telephone activities: including utilization of service providers to assist us in delivery of our products or Services. 

• Business transfers: We may disclose or transfer personal information as part of any actual or contemplated merger, sale, and transfer of our assets, acquisition, financing or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.

• Legally required: We may disclose personal information if we are required to do so by law (e.g., to law enforcement, courts or others, in response to a subpoena or court order).

• Protecting our rights: We may disclose personal information where we believe it necessary to respond to actual or potential disputes or claims asserted against us, including in the context of anticipated or actual litigation with Users or third parties, or to comply with legal processes (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation and to establish, defend, protect the rights, property or safety of Via Benefits, our clients and customers or others.

5.             Disclosure of Personal Information

We may share or disclose the personal information we collect with the following groups:

• Service Providers: We may disclose personal information with third-party service providers who use this information to perform services for us, such as hosting providers, auditors, advisors, consultants and customer service and support providers.

• Third parties: We may share personal information with third parties, including data analytics providers that provide advertising, campaign measurement, online and mobile analytics, and related services. These third parties may receive or access browsing and other data about your use of the Services, in order to help us better reach individuals with relevant ads and measure our ad campaigns, or to better understand how individuals interact with our Site and online services over time and across devices. 

Anonymized and Aggregated Data. We may share aggregate or de-identified information with third parties for research, marketing, advertising, analytics, and other purposes. When we de-identify personal information, we have implemented reasonable measures as required by law to ensure that the de-identified data cannot be associated with any individual or client.  We will only maintain and use such data in a de-identified manner and do not attempt to re-identify the data, except as permitted by law.

6.             Cookies, Analytics and Personalization

We use cookies, pixels, tags, and other technologies, which may be provided by third parties, on our Sites to enable certain functionality and for security and fraud detection and prevention, as well as to collect usage information about our Sites and the emails that we send and to personalize content and provide more relevant ads and information. We may combine the information we collect via these technologies with other information, including personal information, that we collect.  You can specify which cookies you access by using our cookie preference manager when first visiting our website.

Cookies: Cookies are alphanumeric identifiers that are transferred to your computer through your web browser for record-keeping purposes. Some cookies enable you to log-in to our Sites or save certain settings and preferences, while others allow us to track usage and activities on our Sites, personalize content on our Sites, or deliver more relevant ads on our Sites and third party sites. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The “Help” tab on the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies, however, certain features on our Sites may not be available or function properly.

Pixel tags and embedded script (aka clear GIFs and web beacons): Pixel tags are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, pixel tags are embedded invisibly on web pages. We may use these, in connection with our Sites to, among other things, track the activities of users of our Services, improve ads, personalize and manage content, and gather usage information about our Sites. We may also use these in HTML emails to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Opt-Out Preference Signals and “Do-Not-Track” Signals

If your browser enables the Global Privacy Control (GPC) when visiting our Website, our Website will automatically opt you out of any tracking cookies that constitute a “sale” where required by applicable privacy law.  For more information about the GPC and to learn how to implement it on your browser, please click here.   Please note, our Website does not recognize or respond to any signal which your browser might transmit through its so-called “Do Not Track” (DNT) feature.  If you wish to disable cookies on our Websites, you should not rely on DNT browser settings.  For more information about DNT signals, please click here.

Interest-based Advertising: We work with third party ad networks, channel partners, measurement services and others (“third-party ad companies”) to display advertising on our Services, and to manage our advertising on third party sites, mobile apps and online services. We and these third party ad companies may use cookies, pixels tags, and other tools to collect activity information on our Services (as well as on third party sites and services), as well as IP addresses, device IDs, cookies and advertising IDs, and other identifiers, general location information, and, with your consent, your device’s geolocation information; we and these third party ad companies use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.

You may control how participating third party ad companies use the information that they collect about your visits to our Sites, and those of third parties, in order to display more relevant targeted advertising to you; for more information and to opt-out go to:

• www.networkadvertising.org/optout_nonppii.asp (Network Advertising Initiative)

• www.aboutads.info/choices (Digital Advertising Alliance)

Opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.

7.             Your Choices

If you need to update your contact details or other personal information provided to us, please contact us as set forth in the Contact Us section below. 

California, Virginia, and Connecticut residents have certain rights, under state privacy laws, regarding their personal information which are set forth below in the Additional Privacy Information for California, Virginia, and Connecticut Residents sections below.

Opt-Out/Unsubscribe: To stop receiving future e-mail marketing communications from us, please send an e-mail to support@viabenefits.com or write to us at the following address requesting that we stop sending future e-mail marketing communications from us.

Sales Support
Via Benefits Insurance Services
10975 S. Sterling View Drive, Suite A1
South Jordan, UT 84095

To unsubscribe from the applicable insurer’s communications, you must contact such insurer directly. To opt-out of certain targeted advertising, follow the instructions set forth in the Cookies, Analytics and Personalization section above.

8.             Third Party Links and Websites

Our Sites may contain links to other third-party owned and/or operated websites. We are not responsible for the privacy practices or the content of such third-party websites. In some cases, you may be able to make a purchase through one of their third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices, and we have no responsibility or liability relating to such policies or practices.

9.             Security

We have taken certain physical, electronic, contractual, and managerial steps to safeguard and secure the personal information we collect. Despite this, the security of the transmission of information via the Internet cannot always be guaranteed and you acknowledge this in your access and use of our Site. Please note that it is your responsibility to maintain the confidentiality of your password associated with this Site, if any.

To fight spam and abuse on our websites, we use Google reCAPTCHA Enterprise which collects hardware and software information, such as device and application data, and sends this data to Google for analysis.  The information collected is used solely for providing, maintaining, and improving reCAPTCHA Enterprise and for general security purposes.  It will not be used for personalized advertising by Google.  Our use of reCAPTCHA Enterprise is subject to Google’s Privacy Policy and Terms of Use. 

10.          Retention Period

Via Benefits stores personal information as needed to accomplish the purposes identified in this Notice and to meet legal requirements, including legal and compliance requirements regarding records retention, resolving disputes, and enforcing our agreements.  This means that we may be required to maintain your information, for example, to: (1) comply with our legal or regulatory compliance needs (e.g., maintaining records of transactions you have made with us); (2) to exercise, establish or defend legal claims; and/or (3) to protect against fraudulent or abusive activity on our services and systems.  For these and possibly other reasons, we may be unable to delete personal information upon request of an individual in certain cases.

We may retain different categories of information for different periods of time for the instances stated above.  However, it our policy as an organization that when personal information is no longer needed or after legal authority to retain it has expired, personal information will be destroyed in accordance with applicable law and pursuant to procedures established in relation to the relevant Via Benefits services, systems, or processes.  Retention periods for records maintained by Via Benefits, including those containing personal data are established based upon business need, statutory and regulatory record keeping requirements in the geographies where we do business, and legal obligations.  If you have any further questions about our handling of personal information, please contact us at privacy@viabenefits.com.

11.          Minors

Our Services are not designed for individuals under 18, and we do not knowingly solicit information from individuals under the age of 18. We encourage parents and guardians to spend time online with their children and to participate in and monitor the interactive activities of their children. We will not be liable for any content or advertisements viewed by minor children in violation of the terms of this Privacy Policy.

12.          Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. When we do, we will post the change on this Website. If we change the Privacy Policy in any material way, we will provide appropriate online notice to you.

13.          Contact Us

If you have any questions or suggestions regarding this Privacy Policy, you should feel free to contact us at privacy@viabenefits.com or at

Privacy Policy
Via Benefits Insurance Services
10975 S. Sterling View Drive, Suite A1
South Jordan, UT 84095

14.          IMPORTANT ADDITIONAL PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS

In this section, we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”), which requires that we provide California residents certain specific information about how to handle their personal information, whether collected online or offline.

This section does not address or apply to our handling of:

• publicly available information made lawfully available by state or federal governments

• personal information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA (such as protected health information that is subject to HIPAA or the California Medical Information Act, and non-public information subject to the Gramm-Leach Bliley Act or the California Financial Information Privacy Act)

• personal information we collect about job applicants, independent contractors, or current or former full-time, part-time and temporary employees and staff, officers, directors or owners of Via Benefits or its affiliates.

• personal information about individuals acting for or on behalf of another company, to the extent the information relates to our transactions with such company, products or services that we receive from or provide to such company, or associated communications or transactions (except that such individuals have the right to opt-out of any sale of their personal information and to not be subject to any discrimination for exercising such right)

Sale and Sharing of Personal Information Under the CCPA

The CCPA defines a “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration, and it defines “share” in pertinent part as disclosing personal information to a third party for cross-context behavioral advertising. 

In the past 12 months, we have “sold” and/or “shared” usage data (including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement) about California residents with our clients, data analytics providers and service providers for the purpose of gaining insights into online activities through analytics and lead generation, business prospecting and similar activities.

Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. We do not process personal data belonging to individuals 16 years or younger.

California Resident Rights

California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.

Do-Not-Sell/Do Not Share: California residents have the right to opt-out of the “sale” and the “sharing” of their personal information. The CCPA defines a “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration, and it defines “share” in pertinent part as disclosing personal information to a third party for cross-context behavioral advertising.  We do not “sell” or “share” personal information about California residents.  If you have reached this Privacy Notice from a website other than our Website Homepage, please go back and use the cookie preference manager on that website to exercise your opt-out rights, to the extent they may apply, on that website.

Limit the Use of Sensitive Personal Information: California residents have the right in certain instances to request that we limit the use and sharing of their sensitive personal information. The CCPA defines “sensitive personal information” to include, among other things, your: social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card numbers in combination with any required security or access code, password, or credentials allowing access to an account; racial or ethnic origin, religious or philosophical beliefs, or union membership; genetic data; and biometric information (including physiological, biological, or behavioral characteristics). Optimize Via Benefits does not collect Sensitive Personal Information and we therefore are not required to provide you with a mechanism to limit our use of your sensitive personal information.

Initial Notice: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.

Request to Delete: California residents have the right to request the deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies.  The instructions for submitting a verifiable Request to Delete are described in the “Submitting Requests” section below.

Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected, used, and disclosed about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them with certain information about how we have handled their personal information in the prior 12 months, including the:

• categories of personal information collected;

• categories of sources of personal information;

• business and/or commercial purposes for collecting their personal information;

• categories of third parties with whom we have shared their personal information;

• categories of personal information that we have disclosed for a business purpose in the preceding 12 months, and for each category identified, the categories of third parties to which we disclosed that particular category of personal information.

California residents may make Requests to Know up to twice every 12 months.  We will respond to verifiable requests received from California residents as required by law.  The instructions for submitting a verifiable Request to Know are described in the “Submitting Requests” section below.

Request to Correct: California residents have the right to request that we correct inaccurate personal information that we maintain.

Right to Non-Discrimination: The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

Financial Incentives: A business may offer financial incentives for the collection, sale or deletion of California residents’ personal information, where the incentive is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time and may not be included in such incentives without their prior informed opt-in consent. We do not offer any such incentives at this time.

Submitting Requests. Do-Not-Sell (Opt-out) Requests, Requests to Know, Requests to Delete, and Requests to Correct may be submitted:

• By contacting us at 1-800-889-9288 (toll free)

• By submitting a Consumer Request through this link

We will use the following process to verify Requests to Know and Requests to Delete:  We will acknowledge receipt of your Consumer Request, verify it using processes required by law, then process and respond to your request as required by law.  To verify such requests, we may ask you to provide the following information: 

• For a Request to Know categories of personal information which we collect, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you against information in our systems which are considered reasonably reliable for the purposes of verifying a consumer’s identity. 

• For a Request to Know specific pieces of personal information or for Requests to Delete, we will verify your identity to a high degree of certainty by matching at least three pieces of personal information provided by you to personal information maintained in our systems and also by obtaining a signed declaration under penalty of perjury that the requestor is the consumer whose personal information is the subject of the request.

An authorized agent can make a request on a California residents’ behalf by providing a power of attorney valid under California law, or providing: (1) proof that the consumer authorized the agent to do so; (2) verification of their own identity with respect to a Right to Know categories, Right to Know specific pieces of personal information, or Requests to Delete which are outlined above; and (3) direct confirmation that the consumer provided the authorized agent permission to submit the request.

We will respond to verifiable requests received from California residents as required by law.  For more information about our privacy practices, you may contact us as set forth in the Contact Us section above.

Consumer Requests Received in 2022.   In calendar year 2022, we received and responded to consumer requests under the CCPA as set forth in the table below:

*This includes requests that were denied because we were unable to verify the identity of the requestor.

Your California Privacy Rights Under the Shine the Light Law
California law allows individuals that reside in California to know the third parties with whom we shared their personal information for those parties’ own marketing purposes. The type of information and instances in which we share such information is detailed in this Privacy Policy. However, if you are a resident of California and you would like to know the specific companies with whom we shared your personal information and the categories of the information we shared, you should please feel free to call us at 1-800-275-9849 (toll free). Alternatively, you may send us a written request by clicking here.

15.          IMPORTANT ADDITIONAL PRIVACY INFORMATION FOR VIRGINIA RESIDENTS

Virginia law grants Virginia residents certain rights and imposes restrictions on particular business practices as set forth below.

• Right to Access:  Virginia residents have the right to confirm whether or not we are processing their personal information and to access such personal information.

• Right to Correction:  Virginia residents have a right to correct inaccuracies in their personal information, taking into account the nature of the personal information and our purpose for processing their personal information.

• Right to Delete:  Virginia residents have the right to request the deletion of their personal information that we have collected about them and to have such personal information deleted.

• Right to Data Portability:  Virginia residents have a right to obtain a copy of their personal information previously provided to us in a portable and, if feasible, readily usable format.

• Right to Opt-Out:  Virginia residents have a right to opt-out of the processing of their personal information for purposes of (i) targeted advertising; (ii) the sale of personal information; or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects.  Under Virginia law, “sale” means only if we exchange personal information for monetary consideration with a third party. 

• Right to Non-Discrimination: Under Virginia law, we are prohibited from discriminating against Virginia residents for exercising their rights listed above. 

Submitting Requests:  Right to Access Requests, Right to Correction Requests, Right to Delete Requests, Right to Data Portability Requests, and Right to Opt-Out Requests may be submitted:

• By contacting us at 1-800-889-9288 (toll free)

We will use the following process to verify Right to Access Requests, Right to Correction Requests, Right to Delete Requests, Right to Data Portability Requests, and Right to Opt-Out Requests:  We will acknowledge receipt of your request, authenticate it using processes required by law, then process and respond to your request as required by law.  To authenticate such requests, we may ask you to provide additional information as reasonably necessary.

16.          IMPORTANT ADDITIONAL PRIVACY INFORMATION FOR CONNECTICUT RESIDENTS

Beginning on July 1, 2023, Connecticut law grants Connecticut residents certain rights and imposes restrictions on particular business practices as set forth below.

• Right to Access:  Connecticut residents have a right to confirm whether we are processing their personal information and access the personal information we are processing. 

• Right to Correction:  Connecticut residents have a right to correct inaccuracies in their personal information previously provided to us.

• Right to Deletion:  Connecticut residents have a right to request the deletion of their personal information that we have collected about them.

• Right to Data Portability:  Connecticut residents have the right to obtain a copy of their personal information that we have collected in a portable format, if technically feasible.

• Right to Opt-Out:  Connecticut residents have a right to opt-out of the processing of their personal information for the purposes of (i) targeted advertising, (ii) the sale of their personal information, or (iii) profiling in connection with certain automated decisions that produce legal or similarly significant effects.  Under Connecticut law, the sale of personal information is the exchange of personal information for monetary or other valuable consideration by the controller to a third party.

• Right to Non-Discrimination:   We are not permitted to discriminate against a Connecticut resident for exercising one of the above rights.

Submitting Requests:  Right to Access Requests, Right to Correction Requests, Right to Deletion Requests, Right to Data Portability Requests, and Right to Opt-Out Requests may be submitted:

• By contacting us at 1-800-889-9288 (toll free)

We will use the following process to verify Right to Access Requests, Right to Correction Requests, Right to Deletion Requests, Right to Data Portability Requests, and Right to Opt-Out Requests:  We will acknowledge receipt of your request, authenticate it using processes required by law, then process and respond to your request as required by law.  To authenticate such requests, we may ask you to provide additional information as reasonably necessary.