Privacy policy

UPDATE TO BECOME EFFECTIVE: January 1, 2025

Click here for our Privacy Policy in Spanish.

Click here for our Consumer Health Data Privacy Notice.

This Privacy Policy applies to K Health, Inc. and the personal information we collect, use, and disclose in connection with your use of our Services (as defined below) and other business interactions you have with us.  Once you create an account to become a patient, use the  K Pharmacy services or otherwise use the services of any other member of our Organized Health Care Arrangement (“OHCA”), all personal information you provide to us through your account while using the Services is subject to the OHCA’s joint HIPAA Notice of Privacy Practices.

If you are a United States resident, please click here for more information.

At K Health Inc. (“K,” the “Company,” “we,” “us,” or “our”), we want you to be familiar with how we collect, use, and disclose personal information.  This Privacy Policy describes our practices in connection with personal information that we collect through our “Services,” which, together, include:

• Websites (each, a “Site”) and mobile applications (each, an “App”) operated by us (together, the “Platform”);
• Email and text messages that we send to you or other communications with you; and
• Offline business interactions you have with us.

Contact Us:  If anything in our privacy policy is unclear or if you have any questions, please email us at [email protected].

Reproductive Health and Law Enforcement:

K Health supports access to reproductive health care services. K Health follows, to the extent applicable, the U.S. Department of Health and Human Services – Office for Civil Rights’ guidance applicable to disclosures of personal information relating to reproductive health care and will not disclose this information to state officials or law enforcement unless (i) we are compelled to do so by law, (ii) the request is enforceable under law, and (iii) we limit the disclosure to the minimum necessary to comply with law.

1) Types of Personal Information We Collect and How We Collect Personal Information

The categories of personal information we collect depends on how you interact with us and our Services.  For example, you may provide us your personal information directly when you visit our Site, register for an account, download our App, or otherwise contact us or interact with us.

We also collect personal information automatically when you interact with our Platform and other services and we may collect personal information from other sources and third parties.

Personal Information Provided by You

We may collect the following categories of personal information that you provide us:

• Personal identifiers, including contact Information, such as name, email address, phone number, physical address, signature, unique personal identifiers, date of birth, gender, physical characteristics, or description.
• Government Issued Identifiers, such as driver’s license number, and other government issued identifiers for identity verification purposes.
• Education or Employment Information, such as education information and employment information.
• Commercial Information, such as transaction information and purchases considered.
• Health or Insurance Information, such as information about your medical history, preferences, insurance, and goals before you create an account to become a patient. Please see our Consumer Health Data Privacy Notice for information about how we collect consumer health data.
• Financial or Payment Information, such as a financial account number, payment card information (collected by our third-party payment processor), and transaction details.

If you choose to contact us, we may need additional information to fulfill the request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the request we receive or personal information we require fall outside the scope of this Privacy Policy.  In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.

Personal Information Automatically Collected

We, and third parties, may use automatic data collection technologies to collect certain information about your device, browsing actions, and patterns.  We, and third parties, typically collect this information through the use of a variety of our own and our third-party partners’ automatic data collection technologies, including (i) cookies and (ii) other similar technologies, such as pixels, SDKs, APIs, location-identifying technologies, and logging technologies, in each case, for our or our third-party partners’ purposes.  Information collected automatically about you may be combined with other personal information collected directly from you or received from other sources.

The following types of information may be automatically collected by us and third parties:

• Device Data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser id, the URL entered, the referring page, date/time of visit, other user agent string data, the time spent on the Services, and any errors that may occur during the visit to the Services.  Device data may overlap with the other categories of data listed below.
• Analytics/Usage Data, including the path taken to the Services, through the Services, and when exiting the Services, usage and activity on or in connection with the Services (e.g., pages visited, links clicked, videos watched), metrics on how many emails we send are actually opened and which attachments or links are opened, clicked, or viewed (such as via pixels, as described further below).  We may also use third-party tools to collect information you provide to us or information about how you use the Services, including mouse movements, scrolling, clicks, and keystroke activity on the Services and other browsing, search, or purchasing behavior.  These tools may also record information you enter when you interact with the Services or engage in chat or other features through the Services.
• Location Data, including geographic location we or our third-party providers may collect, such as via IP address or permissions within the Platform operating system or browser functionality.
• Advertising/Advertising Measurement Data, including data associated with your view of, or your clicks on, advertisements served on our Services, cookie IDs or other digital or proprietary identifiers (e.g., iOS IDFA, Google AAID) assigned to such device, and the device data, analytics/usage data, and location data described above, in each case, for purposes of serving advertising (personalized or otherwise) or facilitating advertising measurement/attribution to better optimize or otherwise understand the effectiveness of ad campaigns.

Personal Information from Other Sources

We may receive from other sources the same categories of personal information as described above:

• Sponsor Organizations.  If an organization, such as your or your partner’s, spouse’s, or parent/guardian’s employer, university, or health plan, offers coverage for access to or usage of the Services on your behalf (each, a “Sponsor Organization”), in addition to the information described above, use of the Services through a Sponsor Organization may require you to provide additional registration information. This information is collected to confirm your eligibility with the Sponsor Organization.  Information collected under these circumstances may include, but not be limited to, name, email address, date of birth, phone number, and member or group number. The information is required to confirm program or benefit eligibility, your specific benefits, and to prevent insurance and benefit fraud.
• Personal information you direct us to receive, including personal information we receive from third parties and social media.  We may collaborate with third parties in connection with providing the Services, and these third parties may provide us with personal information about you.  Additionally, from time to time, we may receive personal information about you from other third parties (such as Apple’s HealthKit or Fitbit) if you have directed your personal information to be shared with us.
• Advertisers, Influencers, and Publishers.  We engage in advertising both on our services and through third-party services. Advertisers, influencers, and publishers may share personal information with us in connection with advertising (targeted or otherwise) and advertising measurement. For example, we may obtain information about whether an advertisement on our services led to a successful engagement between you and a third-party advertiser (e.g., measurement reports).
• Service Providers.  Our service providers that perform services on our behalf, such as analytics and certain marketing providers, collect personal information about use of the Services and report on activities and trends.  The service providers may also collect information regarding the use of other websites, apps, and online resources and often share some or all of this information with us.
• Business Partners.  We may receive your personal information from our business partners, such as companies that offer their products or services on our Services or on other properties (e.g., digital properties, offline locations) or marketing/advertising and analytics partners, including third-party brands/agencies or other partners that facilitate the buying and selling of advertising inventory on our Services, measure of the effectiveness of those related ad campaigns, or inform business analytics (e.g., view rates, bounce rates, audience composition).
• Other Sources.  We may also collect personal information about you from other sources, including publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.

2) How We Use the Personal Information We Collect

We and our service providers use your personal information for the following purposes

• To provide Services to you, including access to your account.  Certain of our Services may be provided using our artificial intelligence models and tools, such as our artificial intelligence-enabled Symptom Checker.
• To provide and coordinate your care.
• To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or other customer service requests, or when you request other information about our Services.
• To complete your transactions and verify your personal information.
• To send you changes to our terms, conditions, and policies.
• To allow you to communicate with us through the Services if you choose to do so.
• To provide you with information about new services, news about us, or other marketing materials, and to determine the effectiveness of our promotional campaigns so we can adapt campaigns to the needs of users, and to facilitate social sharing.
• To send you communications about new features, updates, sweepstakes, contests, products, and offers.  We may also use your personal information to serve you ads (targeted or otherwise) about our products or services or other products or services we (or our advertising partners, such as other third-party brands/agencies) think you might find interesting, such as on the Services or on third-party properties (e.g., uploads of email addresses to ad platforms or use of cookies or other tracking technologies).  We may also use individual or aggregate information about you to measure the effectiveness of, and inform, our and our third-party partners marketing and advertising campaigns (e.g., disclosure of your personal information to third-party ad partners for ad measurement/attribution purposes).
• To analyze your personal information to improve the Services and the recommendations and information we provide our users and other third parties, including through the use of our artificial intelligence models and tools.  Specifically, we may use your personal information in order to improve our artificial intelligence models and tools so that we are constantly improving our services, products, and the information we provide our users.  When you are using our Services, you are not only learning from our data, but our Services also learn from you and your experiences.  Over the long term, this growing repository of health experiences and clinical decision-making will accelerate medical research and improve our understanding of human disease. Generally, the information we use for machine learning is aggregated and/or deidentified and we take reasonable steps not to reidentify you individually unless permitted by law.
• To analyze personal information for business reporting, including, providing personalized services, improving the efficiency of the Services, and identifying usage trends.
• To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
• To aggregate and/or deidentify personal information so that it will no longer be considered personal information and use and disclose this aggregated and/or deidentified information for any purpose not prohibited by law, including training our artificial intelligence models.
• For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements.
• To prevent fraud and monitor fraud security, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
• To develop new products and services, operate, and expand our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
• To enhance, improve, repair, maintain, or modify our current products and services, as well as undertake quality and safety assurance measures.
• For other purposes about which we may notify you or to which you consent.

3) When and With Whom We Share Your Personal Information

We may share your personal information with third parties, including electronically, as follows:

• Affiliates.  We may share your personal information with our affiliates for the purposes described in this Privacy Policy.
• Partners.  We may share your personal information with other companies, such as companies with whom we jointly offer products and services, including third party payers and Sponsor Organizations.
• Service Providers.  We may share personal information with certain of our service providers, processors, and others who perform functions on our behalf.  These may include, for example, hosting and server services, customer support, chatbot, analytics providers, and payment processors.
• Social Media, Advertising, Analytics, and Measurement Companies.  We may use advertising platforms and other adtech providers to serve advertisements regarding our Services (e.g., ads for our Services on social media networks) or regarding third-party products or services (e.g., ads for third-party products/services on our Services) to you or to others that we or our advertising partners determine are similar to you.  In order to provide these ads, we may use internally or share your personal information, such as email addresses or phone numbers, in hashed or non-hashed format, with the advertising partner, in order to match this information to a particular user.  To deliver ads that may be of interest to you, or measure the effectiveness of such ads, we may also share personal information with other companies, such as advertisers, publishers, analytics, measurement providers, and other adtech companies.  For example, we may share device-related data (such as unique identifier like IDFA/AAID or another proprietary identifier, type of device, IP address, cookies, and other information associated with your browsing and Platform usage), other user identifiers (e.g., email address or phone number), individual preferences and characteristics (such as insights and inferences related to patterns and behaviors), and actions taken on our Services (e.g., page views, purchases, clicks) to these adtech companies in order to better identify and understand our users or others, assist with such targeted advertising, or otherwise analyze, measure, and optimize advertising campaigns. 
• Session Replay Recording.  We may use session replay recording software in order to better understand our users’ needs and to optimize the Services and experience.
• Our Affiliated Clinicians and Pharmacy.  When you use our Services that connect you with a clinician, we will share your personal information with our affiliated clinicians, other providers, and/or pharmacy, in order for them to provide you care or coordinate your treatment.  More about the treatment of this information is within the Notice of Privacy Practices of those organizations.
• Third-Party Services.  We may provide options within the Services where you can receive additional services from a third party.  If you choose to receive services from such third parties, then your personal information will be treated in accordance with those third parties’ privacy policies, and we are not responsible for their practices.
• Information You Share Through Our Services.  Our Services may enable you to share your personal information with others, including healthcare providers, friends, and contacts via social media, via our Platform, or otherwise.  Please use caution when sharing your personal information with others.  The information you share will be shared according to your instructions and actions, and we have no control over what happens with your personal information once you share it with others.

We may also use and disclose your personal information as necessary or appropriate, in particular when we have a legal obligation to do so:

• Applicable Law.  We may share personal information to comply with applicable law and regulations, which may include laws outside your country of residence.
• Transactions, Liquidation.  We may share personal information with third parties in connection with a transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business, or in the event of a bankruptcy or related or similar proceedings.  As part of such transactions, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants; in each case, these parties will be required to agree to confidentiality and non-disclosure terms relating to such personal information before being provided with access.
• Public and Government Authorities, Law Enforcement.  Where permitted or required by applicable data protection laws, we may disclose your personal information pursuant to a legal request, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.
• Protecting Rights and Safety.  Where permitted or required by law, we may share your personal information with others if we believe in good faith that it will help protect the rights, property, or personal safety of us, any of our users, or any member of the general public, with or without notice to you.
• Aggregate and Deidentified Information.  We may share and/or use aggregated or deidentified information about users with third parties for marketing, advertising, our business purposes, research, or any other purposes.

4) Your Choices Regarding Personal Information

Your Communication Preferences

The following are your choices regarding our use and disclosure of your personal information:

• Notifications.  We may send you push or SMS notifications and similar forms of communication from us, which you can control within the Services. We will not provide your phone number to non-service provider third parties for marketing purposes without your explicit consent.
• Marketing-related emails from us.  If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by contacting us via the “Contact Us” information above or opting out using the link in the bottom of the email.  Opting out may prevent you from receiving notification including notices regarding updates, improvements, or offers.  Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages about the Services, from which you cannot opt out.

Your Targeted Advertising Preferences

• Targeted Advertising Self-Regulatory Opt-Outs.  We may work with third-party partners to deliver targeted advertisements based on your interests (also known as “interest-based advertising”).  To opt out of interest-based advertising, visit the Digital Advertising Alliance’s (DAA) opt-out page at www.aboutads.info/choices or the Network Advertising Initiative’s (NAI) opt-out page at www.networkadvertising.org/choices.  Please note that opting out of interest-based advertising will not stop you from seeing ads, but the ads will no longer be tailored to your interests.  You may also download the AppChoices app at www.aboutads.info/appchoices to opt out from participating companies in mobile apps.
  
  Please note that when you opt out of receiving interest-based advertisements through one of these programs, this does not mean you will no longer see advertisements from us or on our services.  Instead, it means that the online ads you do see from relevant program participants should not be based on your interests.  We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs.  In addition, program participants may still use automatic data collection technologies to collect information about your use of our services, including for analytics and fraud prevention as well as any other purpose permitted under the applicable advertising industry program.
• Apple/Android.  You can control whether we can collect your mobile advertising identifier for advertising through settings on your Apple and Android devices.
• Cookies.  To manage cookies, an individual may have the ability to change their browser settings to (for example):  (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies (or certain types of cookies, such as cookies set by third parties).  Note that similar controls may or may not exist for other tracking technologies, such as pixels, SDKs, and localStorage.  Please check your device or browser settings and related documentation for more information.

Further, note that restricting the use of these technologies might negatively impact an individual’s experience using the Services, as some features or offerings may be less personalized or may not work as otherwise intended. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies or other tracking technologies described in this Privacy Policy. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser and device they use. You may also have options within your email client to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain actions with respect to such emails (e.g., URL clickthroughs).

5) Third-Party Services, Including Payment Service

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which our Services link.  The inclusion of a link on our Services does not imply our endorsement of the linked site or service.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any personal information you disclose to other organizations through or in connection with our Platform.

Our Services provide functionality allowing you to make payments using third-party payment services with which you have created your own account.  When you use such a service to make a payment to us, your personal information will be collected by such third party, not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy.  We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your personal information.

6. Retention

We will keep your personal information for as long as your user account is active, in order to allow you to have access to your personal information and to provide you with our services.

We may continue to retain your personal information even after you deactivate your user account or stop using the Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our users, enforce our agreements, or protect our legitimate interests, consistent with applicable law.

7) Security

We seek to use reasonable organizational, technical, and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section above.

8) Changes to This Privacy Policy

This Privacy Policy is current as of the “Last Updated” date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Policy on our Site and App.

U.S. State Privacy Notice

For residents covered under the State Privacy Laws, this U.S. State Privacy Notice supplements the information contained in our Privacy Policy by providing additional information under such laws.  The term “State Privacy Laws” means, as applicable, the U.S. state privacy laws that govern the processing of consumers’ personal information generally (e.g., the California Consumer Privacy Act (“CCPA”), Colorado Privacy Act, Oregon Consumer Privacy Act), as opposed to sector-specific laws (e.g., HIPAA).

For clarity, this U.S. State Privacy Notice also does not apply to protected health information covered by the Health Insurance Portability and Accountability Act (“HIPAA”).  Once you create an account to become a patient, use the  K Pharmacy services or otherwise use the services of any other member of our Organized Health Care Arrangement (“OHCA”), all personal information you provide to us through your account while using the Services is subject to the OHCA’s joint HIPAA Notice of Privacy Practices.

Your Privacy Rights

Depending on your state of residency, you may exercise the following rights under the State Privacy Laws in relation to the personal information about you that we have collected about you (subject to certain limitations under such laws, such as exceptions in the State Privacy Laws or the inability to verify your identity):

The Right to Access	Under the State Privacy Laws, you have the right to obtain confirmation regarding whether we are processing your personal information and to access that personal information and, in some cases, information about the third parties who may receive such personal information.  You also have the right to access that personal information in a portable, readily usable format, unless not technically feasible to provide in such a format. Specifically with respect to the CCPA’s right to access, you have the right to request the following: (a) the specific pieces of personal information the business has collected about you and (b) the categories of personal information collected, the sources of collection, the business/commercial purpose for collecting or “selling/sharing” personal information, and the categories of third party to whom the business discloses personal information.
The Right to Deletion	You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions under the State Privacy Laws.
The Right to Correction	You have the right to request that inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information.
Opt-Out Rights	Under State Privacy Laws, you have the right to opt-out of “sales” and “shares” of personal information and “targeted advertising”. A “sale” is defined broadly under State Privacy Laws and includes any disclosure of personal information to a “third party” for any benefit (whether or not the disclosure involves an exchange of money). We may “sell” your sensitive personal data.  Please read the disclosures below for more details. As further described in this Privacy Policy, we disclose the following personal information to our advertising/marketing and analytics partners (e.g., advertisers/agencies, publishers such as social media networks, customer analytics/intelligence platforms, adtech partners like exchanges, SSPs, and DSPs) for advertising and marketing purposes, including direct marketing:  identifiers, commercial information, geolocation data, sensitive personal information, and internet or other network information.  Please see our “Your Privacy Choices” link (found in the website footer) to exercise your opt-out rights for “sales”/“shares”/“targeted advertising” and processing of “sensitive personal information” accordingly. Further: We do not have actual knowledge of “selling” or “sharing” PI of consumers under sixteen (16) years of age. We do not engage in “profiling that results in legal or similarly significant effects,” as such is defined under State Privacy Laws.

To Exercise Your Privacy Rights

To submit a request to exercise your right to access, deletion, or correction please email [email protected].  You may also call us at 888-564-5250 for assistance on exercising rights requests (where State Privacy Laws require that we provide another means for such assistance).

To exercise your right to opt-out of “sales,” “shares,” and “targeted advertising,” please click our Your Privacy Choices link (found in the Site footer) and follow the instructions therein.  You may also visit our Site with the Global Privacy Control (GPC) signal enabled to opt-out of “sales/shares/targeted advertising” (learn more about GPC at www.globalprivacycontrol.org).  The “sale/share/targeted advertising” opt-out is on a per-website basis and applies at the browser level for the device you use to opt out.

Unless otherwise prohibited by the State Privacy Laws, we may need to verify your identity and confirm your residency before processing your request.  In order to verify your identity, we will generally either require the successful authentication of your account or the matching of sufficient information you provide us to the information we maintain about you in our systems.  This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, or date of last transaction on our Services.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your personal information in our systems.  If we cannot comply with a request, we will explain the reasons in our response.

Non-Discrimination and Appeals

You have the right to not receive “discriminatory” treatment for exercising the rights discussed in the table above.  However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

Further, under certain State Privacy Laws, you may appeal our decision to not take action on your rights request.  All appeals should be submitted by emailing [email protected] along with a copy of the decision that you are appealing.

Authorized Agents

In certain circumstances under the State Privacy Laws, you are permitted to use an authorized agent to submit requests on your behalf (using the mechanisms for submitting requests above), to the extent we can verify the authorized agent’s authority to act on your behalf.

For requests to access, delete, or correct personal information, we may require the following for verification purposes:

1. a power of attorney from you or your authorized agent that is valid under the laws of the applicable state where you reside; or
2. sufficient evidence to show that you have:
   1. provided the authorized agent signed permission to act on your behalf; and
   2. verified your own identity directly with us or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

For requests to opt-out of “sales,” “shares,” or the processing of your personal information for “targeted advertising” under the State Privacy Laws, we may require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

Deidentified Information

Where we process “deidentified information” (as such term is defined under the State Privacy Laws) and are required to keep such information deidentified, we commit to maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process we used satisfies the requirements under applicable law.

Notice at Collection for California Residents

The following additional disclosures are part of the U.S. State Privacy Notice but apply only to residents covered under the CCPA.

CCPA Categories of Personal Data

Please see the list below for the categories of personal information we have collected in the last 12 months.  Further, please see “How We Use the Personal Information We Collect” for the purposes for which such personal information is used.

• Identifiers, such as name, email address, phone number, physical address, signature, unique personal identifiers, date of birth, physical characteristics or description, driver’s license number, Social Security number, and other government issued identifiers for identity verification purposes.
• Customer records, such as information about your medical history, preferences, and goals before you create an account to become a patient.  We may also collect information about your insurance policy number or insurance information.  Please see our Consumer Health Data Privacy Notice for information about how we collect consumer health data.
• Protected classification characteristics, such as gender and age.
• Commercial information, such as, financial account number, payment card information (collected by our third-party payment processor), transaction information and purchase history, including purchases considered.
• Internet or other network information, such as Device Data, Analytics/Usage Data, and Advertising/Advertising Measurement Data.
• Geolocation data, including geographic location we or our third-party providers may collect, such as via IP address or permissions within the Platform operating system or browser functionality.
• Professional or employment information, such as education information and employment information.
• Sensitive personal data, such as government ID numbers; consumer health data; account log-in, financial account, debit card, or credit card number in combination with any required security code, access code, password, or credentials allowing access to an account; and race, ethnicity, or national origin.

“Sales” and “Shares”

In the previous 12 months, we may have “sold” and “shared” the following categories of personal information to our advertising/marketing and analytics partners for the purposes of advertising/marketing and analytics services, subject to your right to opt-out via our Your Privacy Choices link (found in the Site footer):  identifiers, commercial information, geolocation data, sensitive personal information, and internet or other network information.

Data Retention

We retain the categories of personal information above as reasonably necessary to fulfill the purposes outlined in this notice unless a longer retention period is required or permitted by law.  In many situations, we must obtain all, or a portion, of your personal information to comply with legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.