Any campaigns that require collection of personally identifiable information conforms to the following privacy policies:
- Sensis will never sell data that we collect from client campaigns
- Sensis will always collect and store data in a secure manner (e.g., encryption and private keys)
- Data access is limited to staff based required role on the client campaign
- Any contact information that is gathered will be used solely as disclosed to the end-user
- Sensis will always provide options to opt-out of communications that are addressed to contact lists we create and manage
- We retain data for as long as necessary to provide our Services, afterwards purging the data.
- We employ administrative, physical, and technical measures designed to protect the confidentiality and integrity of personal information that we hold. These measures may include encryption and employment of information storage security technologies to restrict access to our network. Please be aware that no method of transmitting information over the Internet or storing information is completely secure. We have procedures and security features in place to help keep your data secure once we receive it.
- Data access is limited to staff based on the required role in the client campaign.
- Employees that are voluntarily or involuntarily terminated have access to all client data immediately revoked.
- We are insured by OneBeacon Professional Insurance with a Network Security & Privacy Supplement. This insurance requires that we establish, maintain and routinely update our security and privacy policies.
Sensis partners with advertising partners (e.g., Google, Facebook) to deliver ads. These ads are optimized throughout the campaign by tracking user click-throughs and ultimate conversion (acquisition of lead) using tracking pixels. The landing pages also capture user behavior using Google Analytics. This data is stored on the ad network infrastructure, not by Sensis.
All these tracking mechanisms are anonymous and do not capture any personally identifiable information.
When Sensis partners with vendors to deliver direct mail. Sensis provides targeting parameters (e.g., 5-mile radius from station-list). The actual names and addresses are never received, nor stored by Sensis.
Our campaigns sometimes require capturing of personally identifiable information via website forms. These forms are secured and the data we collect is encrypted on secure servers that are protected with private keys.
Sensis will use Secure Socket Layer over HTTP, which authenticates server authenticity and encrypts data during transition. Additionally, any system files (O/S, user files and database) will be stored on an encrypted file system. Should an image of the storage device, or the physical storage device itself become compromised, no one other than the original system admin will be able to retrieve content. As a last layer of protection against staff exposure to sensitive information (e.g., personally identifiable information, passwords), Sensis will use column level encryption to conceal sensitive data from engineers. When looking at the database, those records will look like strings of random text, not the actual value that is being stored.
We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
- Category A – Identifiers
Examples: Name, postal address, Internet Protocol address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers.
- Category B – Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Examples: Name, signature, Social Security number, address, telephone number, fax number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, bank account number, credit card number, debit card number, or any other financial information, physical illness, mental illness or disabilities.
- Category C – Protected classification characteristics under California or federal law
Examples: Age, ethnicity, citizenship, religion or creed, marital status, physical illness, mental illness or disabilities, gender, veteran status.
- Category F – Internet or other similar network activity
Examples: Access history and information on your interaction with our application.
- Category I – Professional or employment-related information
Examples: Occupation, employer information.
- Category J – Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
Examples: Education level, school attended.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our clients or their agents. For example, from information our clients provide to us related to the Services for which they engage us.
- Directly from you. For example, through information we ask from you when our clients or their agents subscribe and engage our Services.
- Directly and indirectly from you when using our Services or visiting our website. For example, usage details collected automatically in the course of your interaction with our platform or website.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, to submit this information to our clients or their agents in the form of insurance application forms or request for information.
- To provide you with email alerts and other notices concerning our Services, or updates to your insurance application process.
- For testing, research, analysis and product development.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category C: Protected classification characteristics under California or federal law.
- Category F: Internet or other similar network activity.
- Category I: Professional or employment-related information.
- Category J: Non-public education information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Our clients or their agents for which you have engaged in a business contract.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with our Services.
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
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. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- Our business or commercial purpose for collecting 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).
Deletion Request Rights
You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, 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 providers 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 email at firstname.lastname@example.org. Only you or a person registered with the California Secretary of State 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.
- 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. 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 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the registered email associated with the 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 your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you use of our Services.
- Provide you a different level or quality of Services.
Changes to Our Privacy Notice
We reserve the right to amend this Privacy Notice at our discretion and at any time. The date this Privacy Notice was last updated on October 1, 2020. You are responsible for periodically visiting Sensis’ website and this Privacy Notice to check for any changes.