SUBCO PRIVACY POLICY

This privacy policy (“Policy”) covers www.subco.com, a marketing services website (the “Site”), created, owned and operated by Subco (“us” or “we”) and is applicable to all information about you (“you” or “your”) collected through the Site. All references in this Policy to the Site include Sites that we and our Affiliates (defined below) may create, own and/or operate.

This Policy describes the types of information that we gather from you and the other people who visit the Site (“Users”), how we may use that information and how you can contact us regarding this Policy and your personal information. This Policy also describes additional rights that California Users have under the California “Shine the Light” law.


1: Your Consent

Please read this entire Policy carefully before using the Site or providing us with any information that is personally identifiable to a User (PII) and information that is not personally identifiable to a User (non-PII)(together, “Information”). When you access or use the Site, you consent to the collection, use, processing, and disclosure of your Information in accordance with this Policy by us, our third party marketing partners, and our parent, subsidiaries and entities under common control with us (“Affiliates”). If you do not agree to the terms of this Policy, you are not authorized to use the Site.


2: How We Collection Information and the Types Collected

We and our marketing partners and Affiliates collect Information in a number of different ways. We collect Information when a User registers on our Site and provides us identifying PII such as their name, email, address, date of birth and gender. We also use technological means to collect Information about a User such as the type of device and browser they are using, where they were browsing before they arrived at our Site, their IP address and if a User is on a mobile device, which carrier they use. This Information may be supplemented or verified by third party services.

If you reached the Site by clicking on a link or an ad from another website or from an email sent from one of our marketing partners, then we may also capture that information to understand the interests of our Users and to keep track of third parties who direct Users to our Sites. Users may supply information through our dynamically determined survey questions which we then associate with the User’s PII to help us identify the products and services they may be interested in. We track and record a User’s behavior while on our Site and associate it with the User’s PII so that if a User returns to our Site, we can, for example, avoid showing the User the same offers or asking the same survey questions.

In order for a User to take full advantage of the Site, we ask Users to voluntarily provide their PII to us. If a User chooses not to provide us with their PII by simply not entering it on the Site or not otherwise providing it to us, the User will not be able to access or use certain of the services or features available through the Site.

Usage Information. Whenever you visit or interact with the Site, Subco, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Site is accessed and used (“Usage Information”). Usage Information may include, in part, browser type, operating system, the page served, the time, and the preceding page views. This statistical data provides us with information about the use of the Site, such as how many visitors visit a specific page on the Site, how long they stay on that page, and which hyperlinks, if any, they “click” on. This information helps us keep our website fresh and interesting to our visitors and tailor content to a visitor’s interests.

Device Identifiers. Subco may also automatically collect your IP address or other unique identifier (“Device Identifier”) for the computer, mobile device, technology or other device (collectively, “Device”) you use to access the Site. A Device Identifier is a number that is automatically assigned to your Device when you access a web site or its servers, and our computers identify your Device by its Device Identifier. We may use a Device Identifier to, among other things, administer the Site, help diagnose problems with our servers, analyze trends, track users’ web page movements, help identify, and gather broad demographic information for aggregate use.

We currently do not use technologies such as “cookies” (small text files placed/dropped on a User’s device), “web beacons” (single-pixel GIF files) or similar technologies to track the User’s online behavior and interaction with the Site. We may permit third parties to use these technologies to track your online behavior for their own purposes.


3: How We Use the Information We Collect

We may use the Information (whether PII or non-PII) that a User provides us to, among other things:


4: Behavioral Advertising

Behavioral advertising enables us and our marketing partners and Affiliates to deliver to users what is hoped to be more relevant information and offers for products or services. We track online behavior principally by a User’s email address while our third party marketing partners and Affiliates may use cookies, web beacons and other technological means to track users’ online behavior and to collect Information. In either case, identifying a User and their past online behavior enables the tailoring of targeted offers and advertisements. We may share this and other Information with our third party marketing partners and Affiliates and may be compensated for doing so.


5: Third Party Analytics

We may use Google Analytics and similar tools provided by our third-party partners to help analyze how Users interact with the Site and display customized ads and other content to our Users during a current browsing session or in the future when the User is online. These analytics are performed by using the technological means described above to monitor a User’s interactions with the Site and do not involve the collection of any additional PII.


6: Other Web Sites; Links

We and our Affiliates and marketing partners may advertise and promote the Site and we may permit our marketing partners to place ads and other content, including links to other websites, on the Site. While we try to post links only to third-party websites that share our respect for privacy, this Policy and our privacy practices do not extend to and may differ from those of third-party websites that can be accessed through links on this Site. You should review the applicable privacy policies of the third-party websites before registering with, providing Information to or navigating those websites.


7: Site Policy Regarding Children Under the Age of 18 and Non-US Residents

The Site is intended to comply with the Children’s Online Privacy Protection Act (COPPA). COPPA requires that web site operators never knowingly collect PII from anyone under the age of 13 without prior verifiable parental consent. The Site is not intended for children under the age of 18 and we do not knowingly collect or use PII from children under the age of 18. If we discover personal data from a child under the age of 18, we will eliminate that data.

By using the Site, you agree to provide us with accurate information concerning your age or identity if we request it. You also agree not to assist children under the age of 18 in accessing a Site or to attempt to contact children under 18 through the Site.

The Site is also not intended for persons not resident in the U.S. We use filters that are designed to prevent non-U.S. residents from accessing the Site.


8: Telephone Consumer Protection Act

We may seek your consent to receive telemarketing calls from us, our Affiliates and marketing partners in accordance with the rules under the Telephone Consumer Protection Act (“TCPA”). If you provide your express consent via your electronic signature for TCPA purposes, even if your mobile or landline telephone number is listed on the federal or a State’s Do-Not-Call Registry, you expressly consent to; (a) receive telemarketing calls, text (SMS) messages, and any other means of communication that your wireless device may be capable of receiving (e.g. mms, video etc. ) from the persons named in the consent (including through the use of automated dialing equipment); and (b) receive future information about products and services from us, our marketing partners, Affiliates and other third parties to whom we may provide your Information via other means such as email. You may revoke your consent to be contacted in this manner by any reasonable means at any time (see the Opting-Out section below).

Merely accessing our Site without providing your express written consent for TCPA purposes does not constitute your consent to receive telemarketing calls.


9: Opting-Out

Users may opt-out from receiving future offers from us including have their email address removed – unsubscribed – from email marketing lists by following the Opt-Out instructions contained in the marketing communication. If you receive offers or other communications from our third party marketing partners and would like to opt-out from future communications from them, you must contact them directly. In general, it takes up to 10 days for an Opt-Out request to take effect. A third party’s use of Information is subject to their privacy policy.

Users may opt out from the collection of online viewing data for behavioral advertising purposes by companies who have elected to participate in one of the behavioral advertising opt-out mechanisms such as the Digital Adverting Alliance’s opt-out program. As is the case with most websites, we have not elected to participate in any of these programs at this time.

Users may disable cookies, web beacons and other technological means placed by our Affiliates and third party partners by adjusting their browser or email client settings. Users may also opt out from the collection of online viewing data for analytics purposes performed by Google Analytics by going to Ad Settings under their Google account. As noted above, we do not place or use cookies or web beacons to track your online behavior but may identify you by your email address or other means and will use these methods to tailor your experience on our Site if you visit our Site or one of Affiliate’s sites in the future.

Users may revoke their consent to receive telemarketing calls from us and/or the persons named in the consent by indicating that do not want to receive any further telemarketing from us or the persons named in the consent.


10: Security of Your Information

We use commercially reasonable efforts to prevent unauthorized access or disclosure, or accidental loss or destruction of your Information. We currently do not encrypt Information that we store except for health-related information. Given the nature of the Internet, your Information passes through entities that we are unable to control. Therefore, we cannot guarantee that our security measures or those of our Affiliates or third parties who access or transmit your Information will prevent your Information from being illegally accessed, stolen or altered.


11: Access to Information

All users who provide their Information to us may modify and correct their Information by contacting us at 1-800-258-3350.


12: Your California Privacy Rights

The California “Shine the Light” law permits Users who are California residents to request information regarding our disclosure of their Information to third parties including the categories of Information shared and a list of the names and addresses of third parties with whom the Information was shared. If you are a California resident and would like a copy of this notice, please send a request and identify that it is a “Shine the Light Request.”

Most browsers contain a “do-not-track” setting. In general, when a “do-not-track” setting is active, the user’s browser notifies other websites that the user does not want their personal information and online behavior to be tracked and used, for example, for behavioral advertising. As required by recent Shine the Light law amendments, we are required to inform you that, if your browser is set to do not track, our Site will respond in accordance with that setting so that, for example, we will not be able to access any cookies stored in your browser. The impact a do not track setting has on a website’s operation varies from browser to browser. You should be aware that we use other means to identify Users who have previously visited our Site including their email address and we track a User’s online behavior while on our Site. We may use this information to tailor the User’s experience should they visit our Site or sites belonging to our Affiliate in the future. Setting your browser to “do not track” will have no impact on these practices.


13: Changes to this Privacy Policy

We reserve the right to revise and update this Policy at any time. If we make material changes to this Policy, we will post notice on our Site. Any such revisions will be effective 30 days after posting to the Site and will apply to all Information collected by us both before and following the effective date. Your use of the Site following any such revisions will be deemed your acceptance of such revisions. Users should periodically visit this page to review our current policies on our collection and use of Information.


14: Questions, Suggestions or to Contact Us

For additional Information or if you have any questions, comments, complaints, or suggestions regarding our Policy or one of our Sites, please contact us at 1-800-258-3350.


15: In Addition

By using this website, you acknowledge that you have read and agree to the specific Subco Terms of Use and Privacy Policy.


Last updated: October 24, 2019