Privacy Policy

Last Updated: January 1, 2023

Please review this Privacy Policy as part of our Advertising Checking Bureau ("ACB", "we", "us", or "our") service to this Client's program. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at privacyrequest@acbcoop.com.

When you visit this website and use related services, you may provide us with your personal information. We take your privacy very seriously and in this privacy policy, we outline what information we collect, how we use it and what rights you may have in relation to it. We recommend you take some time to read the entire policy. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites and our services.

This privacy policy applies to all information collected through

and any website hosted by ACB, and/or any related products and services or events (we refer to them collectively in this privacy policy as the "Services").

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information.

• Your interactions with third parties or their websites that are linked to or accessible from ACB’s websites or that are operated by unaffiliated parties, even though the website may contain references to ACB. The information collection, use and sharing practices are governed by the respective privacy notices at the bottom of the sites.

Links to Other Websites

• Our websites may link to other websites for your convenience and information. We are not responsible for the content or privacy practices of any website that we do not control and that does not point to this Privacy Statement.

1. Data We May Collect

We may collect a variety of personal information from you from the following categories:

• Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number, driver's license number, passport number, current or past job history, or other similar identifiers;
• Personal information categories protected by certain laws (including as an example, the California Consumer Records statute (Cal. Civ. Code § 1798.80(e)), such as your name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Note, some personal information included in this category may overlap with other categories;
• Protected classification characteristics under certain state or federal laws, such as 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);
• Commercial information, such as records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Internet or other electronic network activity information, possibly including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement; and Geolocation data, such as physical location or movements.

During the prior 12 months, we have collected the following categories of personal information for the purposes identified and may have provided personal information to the categories of third parties identified.

2. Do We use Cookies And Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

3. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). Clients may choose to retain or have us retain this data for varying time periods.

When we have no ongoing legitimate business need for your personal information and with our clients' consent, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

4. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.

5. Do We Collect Information From Minors?

In Short: We do not knowingly typically collect data from or market to children under 18 years of age.

Other than certain programs designed for the Educational market and schools and students, we do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at privacyrequest@acbcoop.com. In some cases, we handle client programs (such as school programs) that may allow children under 18 to access particular sites. These are done following the client/school's program requirements. Please contact your client/school for specific information.

6. What Are Your Privacy Rights?

In Short: For accounts that have a registration and User Name/Password protocol, you may review, change, or update your account at any time.

Account Information

Some of our sites require registration. For sites with registration, you may access your account at any time to review, update or change the information in your account by:

• Log into your account settings and update your user account

For accounts without registration, you will be asked to verify personal information in order to update any account information. Note: Account updates can be limited or stopped while a promotion is open, active, eligible for resubmission, or being finalized. Once the promotional offer and any resubmission period is closed, data will typically be closed for changes. In addition, any payment instrument such as a check, prepaid card, or other form of payment has been finalized (checks must be cashed and prepaid cards must be fully spent to a $0 amount before data can be removed). Note that some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and Similar Technologies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. Review specifics by following the instructions given by your specific web browser.

7. Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

8. Do Residents of Some States Have Specific Privacy Rights?

In Short: Yes, if you are a resident of some states, you are granted specific rights regarding access to your personal information.

Shine the Light Disclosures

Visitors to our site who are residents of some states have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to us at privacyrequest@acbcoop.com, or you may write to us at:

Advertising Checking Bureau
Data Privacy Officer
5775 Summer Trees Drive
Memphis, TN 38134
United States

Special State Requirements

The California Consumer Privacy Act (“CCPA”) and The California Privacy Rights Act (CPRA) as well as acts in certain other states require us to provide you with additional information regarding how we collect, use, and share your personal information.

Categories of Personal Information We Collect

For a list of the categories of personal information we have collected in the prior 12 months, see Data We May Collect above.

How We Use and Disclose Categories of Personal Information

Throughout this Policy, we describe the methods we use to collect personal information, how we use that personal information and who we disclose that personal information to. Please refer to the applicable sections above for more detailed information. References in this Policy to our use or disclosure of personal information for business purposes may include the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our Services, we will use that personal information to respond to your inquiry. If you provide your personal information to create an account, we will use that information to create and manage your account.
• To provide, support, personalize and develop our Services.
• To create, maintain, customize and secure your account with us.
• To process your requests, transactions and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your experience on our Services and to deliver content and service offerings relevant to your interests, including targeted offers and ads through our Services, third parties and via email or text message (with your consent, where required by law).
• To help maintain the safety, security and integrity of our Services, databases and other technology assets and our business. For testing, research, analysis and product development, including to develop and improve our Services.
• To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA/CPRA and similar Acts in other states.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about users of our Services and our customers is among the assets transferred.

Sales of Personal Information

In the past 12 months, we have not sold personal information.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Note: this right does not cover personal information that we may have about you where we are acting as a service provider to the business that provided personal information to us or engaged us to collect on their behalf. To submit a request to access such personal information, please contact the appropriate business(es).

For personal information that is subject to disclosure by us under the CCPA/CPRA and similar Acts in other states, once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you, based on what your request:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: Sales, identifying the personal information categories that each category of recipient purchased; and
• Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Note: in addition to the exceptions identified below, this right does not cover personal information that we may have about you where we are acting as a service provider to the business that provided personal information to us or engaged us to collect on their behalf. To submit a deletion request for such personal information, please contact the appropriate business(es).

For personal information that is subject to deletion by us under the CCPA/CPRA and similar Acts in other states, once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 1-800-540-1154

Sending a letter to us at:

The Advertising Checking Bureau, Inc.
C/O Privacy Request
5775 Summer Trees Drive
Memphis, TN 38134

Emailing us at privacyrequest@acbcoop.com

Only you, or a person registered with the California Secretary of State or other states with similar requirements that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of that person.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing our request.

In response to a verifiable consumer request, we will notate how data was deleted, anonymized or otherwise purged from being identifiable in our systems. A record of the request will be maintained pursuant to CCPA/CPRA and similar Acts in other states obligations.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us not to sell your personal information at any time. At this time, we do not sell any personal information. This includes information of consumers we actually know are less than 16 years of age. If, in the future, we elect to sell personal information, in addition to other obligations under applicable law, we will not sell personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization from either a consumer that is between 13 and 16 years of age, or the parent or guardian of a consumer who is under 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CCPA/CPRA and similar Acts in other states. Unless permitted by the CCPA/CPRA and similar Acts in other states, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA/CPRA and similar Acts in other states that can result in different prices, rates or quality levels. Any CCPA/CPRA and similar Acts in other states permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt- in consent, which you may revoke at any time.

9. Do We Make Updates To This Policy?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws and in accordance with our client requests.

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you by prominently posting a notice of such changes on the site or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information. Your continued use of the Services following the post of changes constitutes your acceptance of such changes.

10. How Can You Contact Us About This Policy?

If you have questions or comments about this policy, you may contact our Data Protection Officer by email at privacyrequest@acbcoop.com, by phone at 1-800-540-1154, or by post to:

Advertising Checking Bureau
Data Privacy Officer
5775 Summer Trees Drive
Memphis, TN 38134
United States