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PRIVACY NOTICE



This Privacy Notice was last revised on and has an effective date of December
23, 2022.

Sontiq, Inc., is now a TransUnion company. Please note that this Sontiq Privacy
Notice does not cover any products offered by another TransUnion company.

We have recently updated our Privacy Notice. Be sure to review the notice
carefully to understand our privacy practices.

To print our full Terms of Use, click here. To read or print our full Privacy
Notice, click here. To review the full Privacy Notice, please keep reading.

This Privacy Notice provides information about how we handle Personal
Information about you and describes the rights you may have regarding your
Personal Information. It applies to our online and offline collection, use,
sale, sharing, disclosure, and protection of the Personal Information you may
provide to us and we collect or maintain about you (our “Services”), to include
Personal Information you may supply when you use our websites, mobile apps, and
other online services we provide that link to this Privacy Notice (“Site”).

When we process your Personal Information, we will always apply the core
principles we have adopted from the European Union’s General Data Protection
Regulation, GDPR, to ensure the information is:

 * Used lawfully, fairly and in a transparent way.
 * Collected only for valid purposes that we have clearly explained to you and
   not used in any way that is incompatible with those purposes.
 * Relevant to the purposes we have told you about and limited only to those
   purposes.
 * Accurate as updated by you from time to time.
 * Kept only as long as necessary.
 * Kept securely.

Notice at Collection: We collect Personal Information from you and about you
from third parties, as detailed in this Privacy Notice. The categories of
Personal Information that we collect are listed below under “What information is
collected?” and the purposes for which we collect and use Personal Information
are listed below under “How do we use the information collected?” To learn more
about your privacy rights, including your right to opt out of the sale or
sharing of your Personal Information, please navigate to the U.S. Consumer
Privacy Addendum and the “Personal Information Requests” section below. This
Privacy Notice does not apply to data we receive from third parties unless it is
combined with Personal Information you have provided to us.

If you do not agree to the terms of this Privacy Notice, please do not provide
us with any Personal Information and do not use our Services or this Site. We
also recommend that you review the Site’s Terms of Use. This document governs
your use of the Site.

This notice will answer many of the questions you have about the use of your
information. These include:

 * What information is collected?
 * How do we use the information collected?
 * Where does processing of the information occur?
 * How is the information protected?
 * How do I change my information and communications preferences?
 * How and when do we sell/share or disclose information with third parties?
 * How is your information used for advertising?
 * Does third-party content, links to sites, and/or apps appear on the Site?
 * How is children’s information processed?
 * How do we make changes to the Privacy Notice?
 * Who do I contact with questions and concerns?
 * Is there any jurisdictional specific information?

 

1    WHAT INFORMATION is COLLECTed?

1.1  INFORMATION YOU PROVIDE US

In general, you can use our Services and the Site without revealing Personal
Information about yourself. However, we may ask you to provide to us certain
categories of information, such as:

Personal Information, such as your identifiers: first and last name, phone
number, email address, and categories of sensitive personal information, such as
username and password, credit card number, and Social Security number (“Personal
Information”); and

Demographic Information, such as information about your gender (characteristics
of protected classifications) and professional or employment-related information
(“Demographic Information”). If we combine Demographic Information with your
Personal Information, we will treat the combined data as Personal Information.

We may collect this information through various forms and in various places in
our Services and the Site. If you register for an account, subscribe to our
newsletter, through “contact us” forms, or when interacting with the Site, we
may collect Personal Information.

1.2  LOCATION-BASED INFORMATION

We may use location-based services to determine your location (geolocation
data). We do this to verify your location, deliver you relevant content based on
your location, and to enable the location-based services we offer. You may be
able to change the settings on your device to prevent it from providing your
location.

1.3  INFORMATION THIRD PARTIES PROVIDE ABOUT YOU

We may supplement the Personal Information we collect directly from you with
information from third parties. This allows us to:

 * enhance our ability to provide the services you have requested,
 * tailor our content to you, and
 * offer you opportunities that may be of interest to you.

The Site may allow access to third-party websites, online services, or
applications. In return, the third party may provide personal and other
information to us. For example, if you select a social media icon (such as for
Facebook, Twitter, or Instagram), we may have access to the information from
them.

We may also receive information about you from your friends and others that use
the Site. This will happen when they submit content to us or post on the Site.

When we receive information from those sources and combine it with Personal
Information, the new information will be treated as Personal Information under
this Notice.

1.4  INFORMATION WE COLLECT AUTOMATICALLY

In addition to any Personal Information you provide to us, we may use a variety
of technologies that automatically collect certain information whenever you
visit or interact with the Site (collectively, “Usage Information”). When we
associate Usage Information with your Personal Information, we will treat it as
Personal Information.

This Usage Information (internet or other electronic network activity) may
include:

 * Your IP address, UUID – universally unique identifier, or another unique
   identifier (“Device Identifier”). This is automatically assigned to your
   device.
 * Your device functionality (including browser, operating system, hardware,
   mobile network information, etc.).
 * The areas within our Site that you visit and your activities there, including
   remembering you and your preferences.
 * Your device location (geolocation data).
 * Other device data, such as the time of day.

We use various methods and technologies to store or collect Usage Information
(“Tracking Technologies”). The Tracking Technologies used on the Site include:

Cookies – A cookie is a small data file placed on a device when it is used to
visit the Site. We do not respond to browser Do Not Track requests. Most types
of cookies may be disabled or removed by tools that are available as part of
most commercial browsers. Each browser you use must be set separately. Please be
aware that if you disable or remove cookies on your device, some parts of our
Site may not function properly.

Web Beacons – Web beacons are small images that may be included in our Site and
in our messages. Web Beacons may be used for a number of purposes such as:

 * counting visitors to the Site,
 * monitoring how users navigate the Site,
 * counting how many sent emails were actually opened, or
 * counting how many particular links were actually viewed.

Embedded Scripts – An embedded script collects information about how you use the
Site. The code is temporarily downloaded onto your device while you are
connected to the Site and is deactivated or deleted when you leave.

Browser Fingerprinting – Browser fingerprinting is based on the analysis of
information from your device. Items such as your operating system, plug-ins,
system fonts and other data are used to create a unique ID to identify your
device.

Entity tags – An entity tag, or ETag, is an opaque identifier assigned by a web
server to a specific version of a resource found at a web server. If the
resource content ever changes, a new and different ETag is assigned. Used in
this manner ETags are a form of Device Identifier. ETag tracking may generate
unique tracking values even where you may block cookies.

Recognition Technologies – Recognition technologies make assumptions about users
and devices such as that a user of multiple devices is the same user.

1.5  IF YOU FAIL TO PROVIDE PERSONAL INFORMATION

If you fail to provide certain information when requested, we may not be able to
provide part of our Services to you (such as monitoring your credit card for
unlawful activity), or we may be prevented from complying with our legal
obligations.

 

2    HOW DO WE USE THE INFORMATION COLLECTED?

We may use your Personal Information, Demographic Information or Usage
Information that is subject to this Privacy Notice:

 * to provide you with and to improve our Services such as to protect your
   identity,
 * to process transactions or provide you with information such as to send you
   electronic newsletters,
 * to provide you with special offers or promotional and marketing materials
   (including sweepstakes and contests) on behalf of us or third parties,
   including to let you know about new products, services, or upcoming events,
 * to improve the Site including the user experience, marketing endeavors, and
   our Site offerings,
 * to customize your experience on the Site,
 * to serve you specific content or ads that are relevant to you,
 * to provide customer support,
 * to authenticate a credit card number and verify that the person requesting
   your credit report really is you,
 * to contact you with regard to your use of the Site and, in our discretion,
   changes to the Site and/or Site’s policies,
 * for internal business purposes, and
 * for purposes provided at the time you provide your information or as
   otherwise set forth in this Privacy Notice.

We will only use your Personal Information for the purposes for which we
collected it and related purposes. You will be notified if we need to use your
Personal Information for an unrelated purpose. We may also process your Personal
Information where the processing is required or permitted by law.

2.1  USE OF INFORMATION FOR RECRUITMENT PURPOSES.

You may provide information to us as part of an application to become part of
the Sontiq team. This may include Personal, Demographic, or other information.
We use this information to make an informed decision about proceeding with your
application as a legitimate interest of our business. If you provide any
information that is considered to be sensitive, you may be asked to expressly
consent to our processing.

2.2  AUTOMATED DECISION MAKING

 “Automated decision making” is when choices are made by computers without the
involvement of a person. Sontiq does not make decisions using automated means.

 

3    WHERE DOES PROCESSING OF THE INFORMATION OCCUR?

Our Services and Site operate in the United States. Information we collect,
including Personal Information, will be transferred, processed, stored, and used
in the United States.

The data protection laws in the United States may differ from those of the
country in which you are located. Your information may be subject to access
requests from governments, courts, or law enforcement according to the laws of
the United States.

3.1  HOW LONG IS PERSONAL INFORMATION RETAINED?

We only retain your Personal Information for as long as necessary to fulfill the
purposes for which it was collected. This includes satisfying any legal,
accounting, or reporting requirements.

When you give up your membership, your Personal Information is retained for a
short period of time in the event you decide to rejoin. After this period, your
Personal Information will be securely destroyed or obfuscated.

 

4    HOW is the INFORMATION PROTECTED

The security of your Personal Information is of critical importance to us.
Sontiq’s security controls are independently audited, annually to help ensure
compliance with the following standards:

 * the Payment Card Industry Data Security Standards (PCI DSS) Level 1 controls,
   including a Report on Compliance (RoC) issued by a Qualified Security
   Assessor (QSA),
 * the American Institute of Certified Public Accountants (AICPA) SOC 2, Type 2,
   (Report on Controls at a Service Organization) based on the Trust Services
   Criteria relevant to Security, Availability, Processing Integrity,
   Confidentiality, and Privacy, and
 * the US National Institute of Standards and Technology (NIST) 800-53 Risk
   Management Framework.

Sontiq maintains a comprehensive Information Security Program that utilizes
administrative (policies and procedures), physical, and technical controls to
provide comprehensive protection for all Sontiq systems and applications.
Security, integrity, and confidentiality of data is of the highest importance.

We use industry-standard safeguards to protect your information.  While we make
reasonable efforts to safeguard Personal Information once we receive it, the
protection of your information cannot be guaranteed.

You are responsible for maintaining the confidentiality of any password(s) and
all activities that occur using your password(s).  You should notify us
immediately of any unauthorized use of your password(s) or accounts.  Please
contact us (see below) if you believe your Personal Information has been
exposed.

 

5    HOW DO I CHANGE MY INFORMATION AND COMMUNICATIONS PREFERENCES?

You are responsible for the accuracy of the information you share with us. This
information may be reviewed and updated through the:

 * Site’s registration forms or
 * “Manage Account” tab on your account dashboard.

You also may write to us directly to update or delete your contact information
or to request that we stop sending you any form of communication. These requests
should be sent to us by postal mail to:

Sontiq
Attn: Privacy Team
9920 Franklin Square Drive
Suite 250
Nottingham, MD, 21236
USA

We may ask you to provide additional information before making these changes.
This may be done to verify your identity.

When you update your information, we will make good faith efforts to make the
requested changes in our systems as soon as reasonably possible. We may need to
retain prior information as business records in some situations.

For information regarding U.S. consumer privacy rights, as applicable by law for
residents of California, Colorado, Connecticut, Utah, and Virginia, please visit
our U.S. Consumer Privacy Addendum for your specific disclosures and rights.

Please note that Sontiq is now a TransUnion company. To learn how TransUnion
handles Personal Information that TransUnion maintains about you and the rights
you may have regarding your Personal Information, please visit the TransUnion
Privacy Center at www.transunion.com/privacy/transunion.

5.1  PERSONAL INFORMATION REQUESTS

With some restrictions, you may make requests of us with regard to your Personal
Information. Please use our self-service options or contact our Privacy Office
in the following ways:

 * Visit your Sontiq Member Dashboard
 * Call us:
   * Within the U.S. (toll-free) at 888-6-SONTIQ or (888) 676-6847
   * Outside the U.S. at 01 (508) 644-8726
 * Email us at privacy@sontiq.com
 * Complete our Consumer Privacy Rights request forms available as follows:
   * Click here for “Do Not Sell/Share My Personal Information”
   * Click here to submit an Access Request
   * Click here to submit a Deletion Request
   * Click here to submit a Correction Request

For more information, visit our Sontiq Trust Center.

For information regarding U.S. consumer privacy rights, as applicable by law for
residents of California, Colorado, Connecticut, Utah, and Virginia, please visit
our U.S. Consumer Privacy Addendum for your specific disclosures and rights.

Access – You may request a copy of the Personal Information we hold about you.
To see the information we hold, log in to your account and review the
information from the Sontiq Member Dashboard. You will not have to pay a fee to
access your Personal Information in Sontiq-owned Member Dashboard(s) while your
account is current (or to exercise any of the other rights). Please note that,
for security, we cannot provide your full Social Security number or your full
credit card numbers.

Transfer – You may request we provide an electronic copy of the information you
have provided to us to be shared in a format that may be sent to another entity.

Correction – You may request that we modify any incomplete or inaccurate
information we hold about you.

Erasure/Deletion – You may request that we delete elements of your information
that we collect or maintain. Please note that it is not always possible to
completely remove all of your information from our systems. This is often due to
legal or regulatory requirements.

Restrict Processing – You may request that we suspend the processing of your
Personal Information. You may want to do this, for example, if you want us to
verify the accuracy of the information. Another example may be to ask us to
confirm the reason the processing is occurring. You may do this by logging in to
your account and removing your Personal Information from the Sontiq Member
Dashboard.

You may change or cancel the marketing emails you currently receive from us by
following the instructions found in our promotional emails. Please note that we
will continue to send you communications about your account or use of our
Services and Site. This includes administrative and Site announcements.

5.2  WITHDRAWING CONSENT

In some very limited cases we process your Personal Information based upon your
consent. You have the right to withdraw your consent for processing in these
situations at any time.

To withdraw your consent, please log in to your account and delete the
information from the Sontiq Member Dashboard, or call us within the U.S.
(toll-free) at 888-6-SONTIQ or (888) 676-6847, or outside the U.S. at 01 (508)
644-8726.

 

6    HOW AND WHEN DO WE Sell/sHARE or disclose INFORMATION WITH THIRD PARTIES?

We may disclose Personal Information and other information with third parties
for business purposes. This is done:

 * based on your requests,
 * to provide our Services to you,
 * to protect the interests of Sontiq and others, and
 * in the event of a transfer of the business.

We may also disclose your information with related companies. These include our
parent company, our subsidiaries, and affiliates.

There are times when we disclose information in an anonymized or aggregated form
with our partners. In these cases, the identity of the individual(s) whose
information is shared cannot be directly discerned from the information we
provide.

All of our third-party service providers and other entities in the group are
required to take appropriate security measures to protect your Personal
Information. We do not allow our third parties to use your Personal Information
for their own purposes.

We may transfer Personal Information (identifiers) to credit reporting agencies
in a manner that may be considered a sale or sharing of Personal Information
under state privacy laws and regulations.

6.1  Disclosure BASED ON YOUR REQUESTS

You may have an opportunity to receive information or marketing offers from
third parties while on our Site. When this occurs, your Personal Information and
other information may be disclosed to the third parties.

The following data may be processed by third-party service providers:

 * Name, address, date of birth, telephone number, email address monitoring
 * Social security number monitoring
 * Credit and credit score monitoring
 * Driver’s license number monitoring
 * Passport number monitoring
 * Medical account number monitoring
 * Credit card monitoring
 * Bank account monitoring
 * Monitoring bank and credit card transactions
 * Social media account monitoring
 * Court records monitoring
 * Payday loan monitoring
 * IT services

Third parties may also store, collect, or have access to your information when
you interact with them. This includes when you use third-party tools such as
Facebook, Twitter, Pinterest, or other posting or content sharing tools.

In addition, we may provide interfaces or links to third-party sites to help you
send a message from the Site. For example, we may use third parties to send
emails, tweets, or make Facebook postings. These third parties may retain any
information used or provided in any such communications.

When you send someone else a message from the Site, the information you provide,
such as recipient names and email addresses, is used by Sontiq to send the
communication and is not used by us for any other marketing purpose unless we
obtain consent from that recipient or we explicitly say otherwise.

By using these tools, you are subject to the third-party’s privacy practices. We
are not responsible for the privacy policies and practices of third parties. You
should review each third-party’s privacy policies and practices prior to using
their services.

6.2  Disclosure TO PROVIDE our SERVICEs TO YOU

We may use third-party vendors to perform certain services on our behalf. These
services include:

 * assisting in the operation, design, and hosting of the Site,
 * tracking activity on the Site by collecting analytic information,
 * managing a database of customer information,
 * sending you special offers,
 * performing administrative services,
 * providing credit report information, and
 * providing other services designed to assist us in maximizing our business
   potential.

These vendors may have access to user information to carry out the services they
are performing. This may include Device Identifiers and Personal Information
which we provide to the vendors.

Third-party analytics and other service providers use their own Tracking
Technologies on your Device. These third parties may collect or have access to
information about you. This may include Personal Information which we do not
provide. We are not responsible for the technologies or activities of these
third parties. Some may offer you certain choices regarding their practices, and
information of which we have been informed regarding such choices is
available here.

6.3  Disclosure TO PROTECT THE INTERESTS OF SONTIQ AND OTHERS

We may disclose your information including Device Identifiers and Personal
Information to third parties to:

 * satisfy any applicable law, regulation, subpoena, governmental request, or
   legal process if, in our good faith opinion, such is required or permitted by
   law,
 * protect and/or defend the Site’s Terms of Use or other policies applicable to
   the Site, including investigation of potential violations,
 * protect the safety, rights, property, or security of the Site or any third
   party,
 * to detect, prevent or otherwise address fraud, security, or technical issues,
   or
 * identify users to third parties to protect their interests subject to
   applicable law. By extension, this may include disclosure to law enforcement
   agencies.

The previous disclosures may be made without our providing notice to you.

6.4  Disclosure for TRANSFER OF THE BUSINESS

Sontiq may disclose and transfer your Personal Information and other
information:

 * to a subsequent owner, co-owner, or operator of the Site or applicable
   database, or
 * in connection with a merger, consolidation, or restructuring of our business,
 * in connection with the sale of substantially all our interests or assets, or
 * in connection with other corporate change.

The above disclosure may occur during the course of any due diligence process.

6.5  Disclosure FOR A SWEEPSTAKES, CONTEST, OR PROMOTION

We may offer sweepstakes, contests, and other promotions (any, a “Promotion”)
through the Site that may require registration. When you participate in a
Promotion you are agreeing to its official rules. The rules may include
requiring you to allow the Promotion’s sponsor to use your name, voice, or
likeness in marketing efforts.

Personal Information may be disclosed with third parties and the public to
manage a Promotion. This may occur during winner selection or prize fulfillment.
Personal Information may also be made known as required by law or as permitted
by the Promotion’s official rules.

 

7    HOW IS YOUR INFORMATION USED FOR ADVERTISING?

Many companies serve advertisements across Internet sites. These companies
include Sontiq as well as third parties such as network advertisers and ad
exchanges. Third-party analytics service providers may be used to gauge the use
of these ads on third-party sites, the viewing of ads, and the viewing of our
content. The advertisements presented may be based on your activities across the
Internet and mobile media. These are called “Behavioral Ads.”

Our third-party network advertisers and ad exchanges may set and access their
own technologies on your device. This may include use of an identifier on your
device, which may be a unique cookie or another form of unique identifier. These
third-party technologies, combined with Personal Information we may provide,
may:

 * help deliver advertisements to you that might interest you,
 * prevent you from seeing the same advertisements repetitively,
 * recognize you across the devices you use, and
 * understand the usefulness of the advertisements that have been delivered to
   you.

This Privacy Notice does not apply to the collection or use of the information
by these third parties. We have provided information about these third parties
in the chart at the end of this Privacy Notice. You should review their
information processing practice policies.

7.1  ADVERTISING CHOICES

Some third parties may offer you certain choices regarding their Behavioral Ad
practices.

You may wish to visit a site provided by the Network Advertising Initiative
(NAI) https://optout.networkadvertising.org/?c=1, which shares information on
the choices provided by NAI members. This includes how to “opt-out” of members’
advertising.

You may wish to visit a site provided by the Digital Advertising Alliance
(DAA) https://optout.aboutads.info/?c=2&lang=EN, which shares information on
the choices provided by DAA participants. This includes how to “opt-out” of
their advertising.

By clicking on the “Opt-Out” links above, you will be directed to the respective
third-party website where your computer will be scanned to determine who
maintains cookies on you. At that time, you can either choose to opt out of the
cookie-based targeted advertising or you can choose to opt out of cookie-based
targeted advertising by selecting individual companies who maintain a cookie on
your machine.

We are not responsible for effectiveness of or compliance with any third
parties’ opt-out options or programs. Please note that if you delete your
cookies or you visit this site using a different device or browser, you will
need to repeat the opt-out processes outlined above.

 

8    DOES THIRD-PARTY CONTENT, LINKS TO SITES, AND/OR APPS APPEAR ON THE SITE?

The Site may contain content, links, or applications that are supplied by a
third party. These third parties may collect Usage Information and your Device
Identifier for their own commercial purposes. In some cases, you may be directed
to other sites and applications that are operated by third parties that we do
not control. These third parties may have their own terms of service, privacy
policies, or other policies. We are not responsible for the practices employed
by these third parties.

For example, if you “click” on a link you may be taken off the Site onto a
different Internet location. These other online services may track your
activities, collect information about you, and may or may not have their own
published privacy policies. We are not responsible for practices of these third
parties.

We encourage you to review any available policies before using third party
applications. Exercise caution in connection with these applications

 

9    HOW IS CHILDREN’S INFORMATION PROCESSED?

We understand the importance of protecting the privacy of children. The Site is
not intended for use by children under the age of eighteen (18). We do not
enroll children in our services although they can be a part of the services we
provide to families and for which their parent/guardian must enroll them
directly.

Sontiq does not knowingly collect Personal Information from children. If you
believe your child has provided Personal Information without your consent, we
will dispose of it as per applicable law. Simply contact us
at privacy@sontiq.com to let us know of the situation.

 

10 how do we make CHANGES TO THE PRIVACY NOTICE?

This Privacy Notice may change at any time. A new revision of this Privacy
Notice will be posted on this page and reflected by a change in the effective
date. Any changes will be effective as of that effective date.

We will not use your previously collected Personal Information in a way that is
significantly different than stated in the Privacy Notice which was effective on
the date the information was collected. However, we may request your consent for
any new uses.

 

11 WHO DO I CONTACT WITH QUESTIONS AND CONCERNS?

If you have any questions about this Privacy Notice or our practices, please
contact us.

Postal Mail:

Sontiq
Attn: Privacy Team

9920 Franklin Square Drive
Suite 250
Nottingham, MD, 21236
USA

Email: privacy@sontiq.com

Telephone:
From within the U.S. (toll-free): 888-6-SONTIQ or (888) 676-6847

From outside the U.S.: 01 (508) 644-8726

We may need to request specific information from you to help us confirm your
identity. We do this to ensure that your Personal Information is not disclosed
inappropriately.

Sontiq is now a TransUnion company. To learn how TransUnion handles Personal
Information about you and the rights you may have regarding your Personal
Information, please visit the TransUnion Privacy Center
at www.transunion.com/privacy/transunion.

If you want to submit a request to know, delete, correct, or opt-out for data
held by TransUnion, you can do so on TransUnion’s website
at: www.transunion.com/consumer-privacy, or by calling toll-free at:
866-310-8783 between 8 am and 9 pm eastern time Monday through Friday or between
8 am and 5 pm eastern time Saturday or Sunday.

If you have an unresolved privacy or data use concern that we have not addressed
satisfactorily, please contact our U.S.-based third-party dispute resolution
provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

 

12 IS THERE ANY JURISDICTIONAL SPECIFIC INFORMATION?

12.1              EUROPEAN UNION

Our privacy practices as required under the European Union General Data
Protection Regulation (“GDPR”) have been incorporated into this notice.

12.1.1   LEGAL BASIS FOR PROCESSING

A legal basis for processing Personal Information is required under GDPR.

 * We are fulfilling a contract when

 * * Sontiq monitors your Personal Information and sends alerts, or
   * we process payments, or
   * preventing fraudulent access to your accounts.

 * We are meeting the legitimate interests of our business when

 * * we contact you regarding new products and services, or
   * we capture analytic information to improve or personalize our products,
     services, and website, or
   * preventing fraudulent use of our services.

 * We are addressing our legal obligations when reporting income and related
   information to tax authorities.

12.1.2   OBJECTION TO PROCESSING

You may object to the processing of your Personal Information. This may be done
if you feel it is inappropriate for Sontiq to rely on legitimate interest as a
legal basis for processing. When you object, we will limit the processing of
your information. Once the objection is resolved, we will either resume
processing or delete the Personal Information as appropriate. Please
email privacy@sontiq.com to object to processing.

12.1.3   TRANSFER OF PERSONAL INFORMATION OUTSIDE OF THE EU

Sontiq utilizes Standard Contractual Clauses for the transfer of information
outside of the EU. This participation applies to all personal data that is
received from EU residents. This personal data is also subject to this Privacy
Notice.

12.1.4   REGISTERING A COMPLAINT

There may be times when you have a concern about the processing of your Personal
Information. We ask that you please contact the Sontiq Privacy Officer at these
times as detailed above.

If you remain dissatisfied, then you have the right to apply directly to the UK
Data Protection Authority:

Postal Mail:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
England

Website: https://ico.org.uk/global/contact-us/

Telephone: +440303 123 1113

12.2    U.S. State Privacy

12.2.1   comprehensive state privacy laws

For information on the comprehensive state privacy laws, please see our U.S.
Consumer Privacy Addendum.

Please also note that Sontiq is now a TransUnion company. To exercise your
consumer privacy rights for data processed by TransUnion, please click here.

In calendar year 2021, we received and responded to consumer requests as set
forth in the table below.

Request TypeRequests ReceivedRequests CompletedRequests Unverified/Denied*Mean
Days to ResolutionDeletion142766643Opt-Out (Do Not Sell…)436436028Data Privacy
Disclosure / Access2517828

* Requests may have been denied if the consumer’s information was not in, or
could not be matched to a unique identity in our systems, we were unable to
verify the consumer’s identity, or if an exception to compliance was applicable.

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