Privacy Policy

Digital Media Connection’s Privacy Policy

Last Updated: 9/15/2021

 

Thank you for visiting the DMC website located at www.helpingamericasseniors.com (the “Site”). The Site is an Internet property of Digital Media Connection, LLC (“DMC,” “we,” “our” or “us”). This DMC Privacy Policy (“Privacy Policy”) covers our treatment of personal information and other information that we collect when an end-user visitor to the Site (“user,” “you” or “your”) accesses or uses: (a) the Site; (b) the Site’s viewable text, graphics and other material (collectively, “Content”); (c) a variety of printable, web-based coupons ("Printable Coupons") and online coupon codes ("Coupon Codes," and together with Printable Coupons, “Coupons”), as made available on or through the Site by DMC third-party coupon provider partners ("Coupon Providers"); (d) the sample program (“Sample Program”), that will enable you to register for the opportunity to receive free samples and other discounted merchandise (collectively, the “Samples”), as made available on the Site by DMC third-party sample providers (“Sample Providers,” and together with the Coupon Providers, the “Merchants”); (e) links to DMC social media pages/accounts (collectively, “Social Media Pages”) on third-party social media websites, such as Facebook® (“Social Media Websites”); and/or (f) certain promotions, contests and/or sweepstakes offered by DMC by and through the Site, and otherwise, from time to time (collectively, “Contests,” and together with the Site, Content, Coupons, Samples and Social Media Pages, the “DMC  Offerings”).

 

Users with disabilities who wish to access this Privacy Policy in an alternative format can contact us by e-mailing us at: [email protected]; sending us mail to: Two Union Plaza, Suite 104 New London, CT 06320

 

Capitalized terms not defined herein shall have the meanings set forth in the [email protected] Website Terms Of Use (“Terms and Conditions”). IF YOU DO NOT AGREE TO TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE UTILIZE THE SITE OFFERINGS.

 

This Policy also describes your choices about the collection and use of your information.

Please read the Privacy Policy carefully before you start to use our Services. By using the Services, you agree to be bound and abide by our posted Terms of Use (“Terms”), California Privacy Policy (if applicable), and this Privacy Policy. If you do not agree to both the Terms and our Privacy Policy, or if you violate them in any way, your right to access or use the Services may be terminated.

This policy does not apply to the practices of companies that we do not own or control, or to people that we do not employ or manage.

How We Collect Information. We may collect information about you by various means, including:

•     Directly from you, both online and offline;

•     Through our Services; and

•     From other third-party sources and social media platforms that you may use to engage with us, as well as from our affiliates, partners or third parties, including, but not limited to public databases, for the purposes provided below, and/or to supplement information we already possess.

Types of Information We Collect. The website collects personal information when you register with us, fill out surveys fill out other forms, or otherwise provide information via out Services or interact with our Services as defined in the Terms of Use. We may combine information about you that we have with information we obtain from business partners or other companies. In order to better provide you with our Services, we may collect the following categories of information:

•     Contact information, such as your name, mailing address, e-mail address, phone number, and business interests, which may include signing up to some of our communications;

•     Communications between you and us, such as via e-mail, web form, mail, phone, or other channels;

•     Offline activity you engage in with us (e.g., phone, conferences); and

•     Online User Activity described in the next section.

Once you register with us and sign in to our services, you are not anonymous to us


If you provide us with information regarding another individual, you represent that you have that person’s consent to give us his or her information and to permit us to use the information in accordance with this Policy.

Online User Activity, Cookies, and Information Collected by Other Automated Means. Cookies are a commonly-used web technology that allow websites to store and retrieve certain information on a user’s system, and track users’ online activities. We, our service providers, and our advertising partners may use such technology to collect information about your use of the Services by such automated means, including but not limited to cookies, pixels and other similar technologies. There are online tools available for clearing all cookies left behind by the websites you have visited, such as www.allaboutcookies.org.

These technologies may help us automatically identify you when you return to our Services. Cookies help us review website traffic patterns, improve the Services, and determine what Services are popular. We can also use such information to deliver customized content and advertising to users of the Services whose behavior indicates that they are interested in a particular subject area.

When you use the Services, the information that we may collect by automated means includes, for example:

•     Usage Details about your interaction with our Services (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, and referring website addresses);

•     Device Information including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, and mobile network information); and

•     Location information where you choose to provide the Services access to your device’s location information.

We may also ask advertisers or other partners to serve ads to you, which may use cookies or similar technologies placed by us or the third party. If a user does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies, but if you choose to decline cookies, you may not be able to fully experience the interactive features that our Services provide. We may share non-personal information obtained via cookies with our advertising partners. Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time.

You may see us advertising on various websites, web pages, social media, and other platforms. We may not always be made aware of the platforms or websites on which our advertising may appear, and if you believe that our advertising is being displayed through channels that promote inappropriate or offensive content, please contact us as directed below.

How We Use Information We Collect. We may use the information that we obtain about you for purposes allowed by applicable laws, including, but not limited to:

•     To contact you for marketing and promotional purposes by various means, including email, text and phone;

•     To pre-fill or pre-populate offer forms on the Site;

•     Provide our Services to you and respond to your inquiries and other communications;

•     Tailor the content that we display to you in our Services and communications, including advertising, and offer products and information that we believe may be of interest to you;

•     To enhance and validate the data we have in our database;

•     Operate, evaluate, and improve our Services, including to diagnose or fix technology problems;

•     Monitor the performance of our Services including metrics such as total number of visitors, traffic, and demographic patterns, as well as analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read);

•     Provide you with administrative notices, such as to inform you about changes to this Privacy Policy, the California Privacy Policy, and our Terms; and

•     Comply with and enforce as needed applicable legal requirements, industry standards, our policies, and our contractual rights.

We may also use or share information in an anonymized or aggregate manner for many purposes such as research, analysis, modeling, marketing and advertising, as well as improvement of our Services.

How We Share Your Information. We will not disclose your personal information to third parties without your consent, except in the following circumstances:

•     We may share your information as permitted by law, including, but not limited to, with our corporate affiliates, service providers that we believe need the information to perform a technology, business, or other professional function for us (examples include IT services, maintenance and hosting of our Services, payment processors, shipping and returns partners, marketing partners, and other service providers). We only provide such vendors with information so that they can perform their required functions on our behalf.

•     We may also disclose information about you: (i) if we are required to do so by law or legal process; (ii) when we believe disclosure is necessary to prevent harm or financial loss; (iii) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (iv) under exigent circumstances to protect the personal safety of our staff, users, or the public.

•     We reserve the right to transfer the information that we maintain in the event that we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Policy.

Where appropriate, we will limit sharing of your information in accordance with the choices that you have provided us and applicable law.

Your Privacy Choices. We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

•     Marketing Emails: From time to time, we may contact you via email or through other channels for the purpose of providing announcements, promotional information and/or other general communication. In order to improve our Services, we may be notified when you open an email from us or click on a link therein. You may choose not to receive marketing emails from us by clicking on the unsubscribe link in the marketing emails you receive from us. Even if you opt out of receiving such communications, we may continue sending you non-marketing email communications, such as administrative or transaction alerts, or information about changes to our terms of service.

•     Cookies: Web browsers may offer users the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our Services may not function correctly.

Links to Other Websites and Third-Party Content. Our Services may contain links to other websites or apps. This can include social media integrations. Please be aware that we are not responsible for the content or privacy practices of such other websites or apps, and we encourage you to be aware when you leave our Services and to read the privacy statements of any other website or app that collects personal information.

How We Protect Information. We endeavor to maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information that we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot ensure the security of any information that you transmit to us, or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures in the event of any compromise of personal information. To the extent the law allows us to provide such notification via e-mail or conspicuous posting on the Services, you agree to accept notice in that form.

How we Retain Your Personal Information. We retain personal information regarding you or your use of the Services for as long as your Account is active or for as long as needed to provide you or our Users with the Services. We also retain personal information for as long as necessary to achieve the purposes described in this Privacy Policy, for purposes that include, but are not limited, to comply with our legal obligations, to protect us in the event of disputes and to enforce our agreements, or to protect our and others’ interests.

The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. For example, the period for which we keep a support message is based on how long has passed since the last submission in the thread.

Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized or de-personalized information which we may retain indefinitely.

Children. We do not knowingly collect personal data from children under the age of 13 on our Services. If you have reason to believe that a child under the age of 13 has provided personal information to us through our Services, please contact us. We endeavor to delete personal information from our systems in the event that we learn that we collected it from a child under the age of 13.

International Data Transfers and Use. Our Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than those of the United States. Any information that you provide through use of the Services may be stored and processed, transferred between, and accessed from, the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Privacy Policy regardless of where your personal information is stored or accessed.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information, potentially including sensitive data, by us from your region to countries which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area, including the United States. By providing your personal information, you consent to any transfer and processing in accordance with this Privacy Policy.

State-Specific Notices. For California residents, the California Consumer Protection Act (the “CCPA”) provides various rights to individuals and households with respect to the collection and use of personal information that we have collected about you. Please see the California Privacy Policy found on our website.

Updates to Our Privacy Policy. We may revise or update this Privacy Policy at any time. We will post the updated version on our Services, and may notify you of any significant changes to our Privacy Policy. We will indicate on our Privacy Policy when it was most recently updated. Your continued use of our Services after such updates will constitute your: (i) acknowledgment of such updates; and (ii) agreement to abide and be bound by the updated Privacy Policy.

Contacting Us:

If you have any questions, concerns, or comments about this Privacy Policy, our privacy practices, or other related issues, please contact us via mail at:

Attention: Privacy Policy Department

DMC

Two Union Plaza, Suite 104

New London, CT 06320.

 

Or send any questions regarding Digital Media Connection, LLC's Privacy Policy email to the Privacy Policy Department: [email protected]

 

We will review your question, concern, or comments and will respond to your comment accordingly.

 

Your Nevada Privacy Rights

If you are a resident of the State of Nevada and would like to opt-out from the sale of your personal information to any third party data broker, please e-mail us at [email protected]; or sending us U.S. mail to: Two Union Plaza, Suite 104 New London, CT 06320

Personal Information Collected

[Please see our Privacy Provisions for California Residents for additional details regarding the categories of personal information collected] 

For the purposes of this Privacy Policy, “personal information” shall mean individually identifiable information from or about an individual. We collect personal information when you access certain of the DMC Offerings and complete the required information request form and/or otherwise provide such information to us. Where a user attempts to utilize the DMC Offerings, that user may be required to submit, and DMC may collect, some or all of the following information: (a) full name; (b) full mailing address; (c) telephone number; (d) e-mail address; (e) date of birth; (f) gender; and (g) any other information requested on the Form. In addition, where a user enters a Contest and, where applicable, is selected as a potential prize winner in connection therewith, DMC may collect some or all of the following: (i) Social Security Number (for prize winners); (ii) picture proof of identification, which may include a driver’s license, passport, voting card or similar government issued identification (for prize winners); and (iii) any other information requested in connection with the applicable Contest.

Use and Sharing of Personal Information

[Please see our Privacy Provisions for California Residents for additional details regarding our use and sharing of personal information]

By submitting your personal information by and through the DMC Offerings, you agree that: (a) we may share, sell, rent, lease or otherwise provide that personal information to any third-party for any purpose permitted by law; (b) the third parties that we share, sell, rent, lease or otherwise provide your personal information may also re-sell your personal information to additional third parties; and (c) we may work with other businesses to bring selected retail opportunities to our users. These businesses and third-parties may include, but are not limited to: (i) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (ii) e-mail marketers; (iii) telemarketers (where permitted by applicable law); and (iv) direct marketers. We may also use your personal information to send you promotional messages regarding various DMC products and/or services, as well as third-party products and/or services that we think may be of interest to you.

Where you submit personal information, we use the personal information that you make available to personalize your experience with the Site and to facilitate the delivery of the applicable DMC Offerings to you, including to respond to any inquiries made by you.

Your email will only be shared with our preferred mailing partner for the purpose of sending third party promotional email communications.

You also agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the DMC Offerings, and to keep you informed of our other products and services.

We may also employ other companies and individuals to perform certain functions on our behalf. Examples include sending direct and electronic mail, removing duplicate information from user lists, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to our users’ personal information as needed to perform these functions for us, but we do not permit them to use user personal information for other purposes.

We will also use your personal information for customer service, to provide you with information that you may request, to customize your experience with the DMC Offerings and/or to contact you when necessary in connection with your use of the DMC Offerings. We may also use your personal information for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the DMC Offerings. We may also combine the information we have gathered about you with information from other sources.

By submitting your personal information by and through the DMC Offerings, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.

Where you provide “prior express consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive telephone calls from DMC, including artificial voice calls, pre-recorded messages and/or calls (including SMS text messages) delivered via automated technology, to the telephone number(s) that you provided. Please note that you are not required to provide this consent in order to obtain access to the DMC Offerings, and your consent simply allows DMC to contact you via these means. Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes. Without limiting the foregoing, if you: (A) have your telephone number reassigned to another person or entity; (B) give up your telephone number so that it is no longer used by you; (C) port your telephone number to a landline or vice versa; or (D) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify DMC of the Phone Number Change via e-mail at: [email protected], or by using one of the methods set forth in the “Contact Us” section below.

We reserve the right to release current or past personal information: (I) in the event that we believe that the DMC Offerings are being or have been used in violation of the Terms and Conditions or to commit unlawful acts; (II) if the information is subpoenaed or requested pursuant to any court order or legal proceeding; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena/court order, prior to disclosure of any personal information pursuant to a subpoena; or (III) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if DMC is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.

We reserve the right to release current or past personal information: (A) in the event that we believe that the DMC Offerings are being or have been used in violation of the Terms and Conditions or to commit unlawful acts; (B) if the information is subpoenaed or requested pursuant to any court order or legal proceeding; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena/court order, prior to disclosure of any personal information pursuant to a subpoena; or (C) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if DMC is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.

You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with third-parties for suppression purposes in compliance with applicable law, including the CAN-SPAM Act of 2003, as amended from time-to-time. Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third-parties without permission.

Non-Personal Information Collection and Use

[Please see our Privacy Provisions for California Residents below for additional details regarding the categories and types of non-personal information collected] 

 

IP Addresses/Browser Type

We may collect certain non-personally identifiable information about you and your desktop computer and/or mobile device when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the DMC Offerings and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze usage of the DMC Offerings.

Cookies

When a user visits the Site, we send one (1) or more cookies and/or gif files (collectively, “Cookies”) to assign an anonymous, unique identifier to the applicable user’s computer. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. We use Cookies to improve the quality of the DMC Offerings, including for storing user preferences and tracking Site-user trends (such as pages opened and length of stay at the Site).

Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even in the case where a user rejects a Cookie, he or she may still use the DMC Offerings; provided, however, that certain functions of the DMC Offerings may be impaired or rendered inoperable if the use of Cookies is disabled. We reserve the right to retain Cookie data indefinitely.

Notwithstanding any other provision, we partner with third parties that collect information across various channels, including offline and online, for purposes of delivering more relevant advertising to you or your business Our partners may place or recognize a cookie on your computer, device, or directly in our emails/communications, and we may share personal information with them if you have submitted such information to us, such as your name, postal address, email address, or device ID. Our partners may link the hashed or obfuscated personal information we share with them to the cookie stored on your browser or device, and they may collect information such as your IP address, browser or operating system type and version, and demographic or inferred-interest information. Your data may be transferred outside of the country from which it was originally collected. To learn more about interest-based advertising in general and to opt out, please visit http://www.aboutads.info/choices. To opt-out of the use of your mobile device ID for targeted advertising, please see http://www.aboutads.info/appchoices.

Behavioral Tracking

DMC as well as third party entities such as Google®, Bing® and Facebook®, use Cookies, pixels and other tracking technology (collectively, “Tracking Technology”) in connection with the Site for purposes of tracking users’ activities (such as websites visited, advertisements selected and pages viewed) after they leave the Site. DMC and its third-party partners, use this Tracking Technology to target applicable users with advertisements featuring DMC products and/or services, as well as third-party products and/or services, that may be of interest to applicable users.

In general, users may be able to disable some, but not all, of this tracking activity by utilizing the “Do Not Track” setting or similar options within most major Internet browsers. In addition, users may be able to opt-out of this form of tracking utilizing the options made available by the Network Advertising Initiative or Digital Advertising Alliance.

Further, users can opt-out of certain Google®-related tracking technology, and customize the Google® Display Network ads that they receive, by visiting the Google® Ads Settings at: http://www.google.com/settings/ads Google® also recommends installing the Google® Analytics Opt-out Browser Add-on for your web browser, which is available here: https://tools.google.com/dlpage/gaoptout. To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third-parties in connection with the Site.

Bing® is a registered trademark of Microsoft Corporation (“Bing”). Facebook® is a registered trademark of Facebook, Inc. (“Facebook”). Google+® is a registered trademark of Google, Inc. (“Google”). Please be advised that DMC is not in any way affiliated with Bing, Facebook or Google, nor are the DMC Offerings endorsed, administered or sponsored by any of the foregoing entities.

Cross Device Tracking

DMC may track users’ use of the DMC Offerings across various devices, including users’ personal computers and mobile devices, in order to optimize and personalize use of the DMC Offerings. DMC may collect certain user personal information across various devices.

Aggregate Data

DMC reserves the right to transfer and/or sell aggregate or group data about users of the DMC Offerings for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of DMC Offerings users as a group, without disclosing personally identifiable information.

Third-Party Websites

This Site may contain links to third-party owned and/or operated websites including, without limitation, the websites owned and operated by Merchants, Third-Party Providers and/or Social Media Websites. DMC is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of these third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and DMC has no responsibility or liability relating to them.

Security of Your Personal Information

We endeavor to safeguard and protect our users’ personal information. When users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). Where our registration/application process prompts users to enter sensitive information (such as financial information), and when we store and transmit such sensitive information, that information is encrypted with industry standard encryption technology.

Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. All of our users’ personal information is restricted in our offices. Only employees or third-party agents who need user personal information to perform a specific job are granted access to user personal information. Our employees are dedicated to ensuring the security and privacy of all user personal information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store user personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control.

Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site, other DMC Offerings or otherwise via the Internet or wireless networks, is done at your own risk.

In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

Children’s Privacy

[Please see our Privacy Provisions for California Residents below for additional details regarding the personal information of minors] 

Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information at the Site. DMC does not knowingly solicit or collect information from visitors under eighteen (18) years of age. DMC encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Opt-Out/Unsubscribe

[Please see our Privacy Provisions for California Residents below for instructions on how California Residents can opt-out of the sale of their personal information to third parties]

  • To opt-out of receiving e-mail and other forms of communication from us, you can: (a) follow the instructions included in the applicable e-mail message or other communication; or (b) e-mail us at: DMC
  • To opt-out from telemarketing calls, please follow the prompts on the call or contact customer service;
  • To opt-out from SMS/text messaging, reply STOP to the text/SMS message received;
  • To opt-out of browser-based push notifications, please disable the notifications at the time you receive the notification or disable notifications through your browser’s settings; and
  • To-opt out of cookies, interest-based advertising and/or third-party analytics, please see the section above.

Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for DMC Offerings, your participation in the Contests, as well as to respond to any inquiry or request made by you. To opt-out of receiving DMC Offerings-related and/or inquiry response-related messages from DMC you must cease requesting and/or utilizing the DMC Offerings, cease participating in the Contests and/or cease submitting inquiries to DMC as applicable.

Deleting, Modifying and Updating Your Information

[Please see our Privacy Provisions for California Residents below for instructions on how California Residents can access and/or delete personal information that we have collected] 

At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected. You may do so by e-mailing us at: [email protected]. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Please be advised that deleting your personal information may terminate your access to certain of the DMC Offerings. If you wish to continue using the full complement of DMC Offerings, you may not be able to delete all of the personal information that we have on file for you.

Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

Transfer of Personal Information Internationally

If you are visiting the Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of information across international boundaries. By visiting the Site and/or otherwise communicating electronically with us, you consent to such transfers. Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Privacy Policy.

Changes to this Privacy Policy

DMC reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site that we are changing our Privacy Policy. If the manner in which we use personal information changes, DMC will notify users by: (a) sending the modified policy to our users via email; and/or (b) by any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use your information in this different manner and we will only use your information in this different manner where you opt-in to such use.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices in general, please e-mail us at: [email protected]; sending us mail to: Two Union Plaza, Suite 104 New London, CT 06320

 

Privacy Provisions for California Residents

These Provisions for California Residents (“Provisions”) supplement, and do not limit in any way, the Privacy Policy set forth above. These Provisions apply solely to residents of the State of California (“CA Users”). We adopt these Provisions in compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in these Provisions. CA

Categories of Information We Collect

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 CA User or device (“personal information”). In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers. (Category)

EXAMPLE:

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, or other similar identifiers.

Collected: YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). (Category)

EXAMPLE:

A name, signature, Social Security number, physical characteristics or description, postal address, telephone number, passport number, driver's license or State identification card number, insurance policy 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. Some personal information included in this category may overlap with other categories.

Collected: YES

C. Protected classification characteristics under California or federal law. (Category)

EXAMPLE:

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).

Collected: YES

D. Internet or other similar network activity.

EXAMPLE:

Browsing history, search history, information on a CA User's interaction with a website, application or advertisement.

Collected: YES

E. Inferences drawn from other personal information.

EXAMPLE:

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: YES

 

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated CA User information.
  • Information excluded from the CCPA's scope, such as:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources (with the specific categories of personal information indicated in parenthesis):

  • Directly from our CA Users. For example, from online registration forms that our CA Users submit to us in connection with our membership services, our coupons-related products and/or services, our sweepstakes and promotions, and the other products and/or services that we offer by and through the Site. (Category A, B, C and E)
  • Indirectly from our CA Users. For example, through information we collect from our CA Users in the course of providing our products and/or services to them. (Category A, B, C, D and E)
  • Directly and indirectly from activity on the Site. This includes the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet Service Provider. In addition, we obtain certain Site usage details and analytics as same are collected automatically by us and our third party partners. (Category E)
  • When our CA Users interact with us on our social media accounts, including commenting on and/or liking our posts. (Category F)
  • From third-parties that interact with us in connection with the products and/or services that we offer to our CA Users. For example, third party entities that assist us in sending direct and electronic mail, removing duplicate information from CA User lists, analyzing data and providing marketing analysis. (Category A, B, C, D and E)

Use of Personal Information

We may use or disclose the personal information that we collect for one or more of the following business purposes (with the specific categories of personal information indicated in parenthesis):

  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with your registration for our coupons-related products and/or services, sweepstakes and promotions, and/or our other products and/or services, we will use that information to process your registration. (Category A, B, D and E)
  • To provide you with information, products or services that you request from us. (Category A, B, C, D and E)
  • To create, maintain, customize and secure your account with us. (Category A, B, C, D and E)
  • To provide you with e-mail, direct mail and telemarketing messages concerning certain DMC products and/or services, as well as third-party products and/or services, that we believe may be of interest to you. (Category A, B, C, D and E)
  • To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (Category A, B, C, D and E)
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Site’s Terms and Conditions. (Category A, B, C, D and E)
  • To improve the Site and better present its contents to you. (Category A, B, C, D and E)
  • For customer service purposes and to respond to inquiries from you. (Category A and B)
  • For testing, research, analysis and product development. (Category A, B, C, D and E)
  • As necessary or appropriate to protect our rights, property or safety, and that of our clients or others. (Category A, B, C, E and E)
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Category A, B, C, D and E)
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA. (Category A, B, C, D and E)
  • 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 is among the assets transferred. (Category A, B, C, D and E)

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 with notice.

Sharing Personal Information

Subject to your right to opt-out of such sharing/sale, we may share, rent and/or sell your personal information: (a) with/to third parties for marketing purposes; and (b) for each of the other business purposes set forth above. The third parties that we share/sell your personal information with/to may also re-sell your personal information to additional third parties.

When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from CA Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of CA Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of CA Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months.

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 D      Internet or other similar network activity.

Category E     Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties (with the specific categories of personal information indicated in parenthesis):

  • Our affiliates. Our affiliates may also re-sell your personal information to additional third parties. (Category A, B, C, D and E)
  • Service providers. (Category A, B, C, D and E)
  • Third parties who provide the products and/or services featured on the Site. These third parties may also re-sell your personal information to additional third parties (Category A, B, C, D and E)
  • Third parties who purchase and/or license your personal information for marketing purposes, including: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers. If a third party purchaser of your personal information wants to resell it, that purchaser is required by law to provide you with explicit notice and an opportunity to opt-out of further sales, unless the right to resell it was secured by us at the point of collection. These third parties may also re-sell your personal information to additional third parties. (Category A, B and E)
  • Third parties to whom you authorize us to disclose your personal information in connection with the products and/or services that we provide to you. These third parties may also re-sell your personal information to additional third parties. (Category A, B, C, D and E)

In the preceding twelve (12) months, we have sold the following categories of personal information to third parties:

Category A     Identifiers.

Category B     California Customer Records personal information categories.

Category C     Protected classification characteristics under California or federal law.

Category D      Internet or other similar network activity.

Category E     Inferences drawn from other personal information.

In the preceding twelve (12) months, we have sold the above referenced categories of personal information to the third parties who purchase and/or license your personal information for marketing purposes, as well as the third parties who provide the products and/or services featured on the Site. These third parties may also re-sell your personal information to additional third parties.

Your Rights and Choices

The CCPA provides CA Users (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Opt-Out from the Sale of Your Personal Information

You have the right to opt-out of our sale of your personal information to third parties. To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable CA User request to us by either:

·      Emailing us at: [email protected]

·      Sending us mail to: Two Union Plaza, Suite 104 New London, CT 06320

  • We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) days of the receipt of your request.

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 twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you:

  • 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 have shared 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. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you. 

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. 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 obligations in connection with our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech rights, ensure the right of another CA User to exercise her/his free speech rights or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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, but only if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with CA User expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. 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 your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by either:

·      Emailing us at: [email protected]

·      Sending us mail to: Two Union Plaza, Suite 104 New London, CT 06320

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information.

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

  • Provide sufficient information that allows us to reasonably verify that you are: (1) the person about whom we collected personal information; or (2) 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 that the personal information relates to you. Making a verifiable CA User request does not require you to create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. 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 CA User 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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; and/or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to these Provisions

We reserve the right to amend these Provisions in our discretion and at any time. When we make changes to these Provisions, we will notify you by email or through a notice on the Site’s homepage.

Contact Information

If you have any questions or comments about these Provisions, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either:

·      Emailing us at: [email protected]

·      Sending us mail to: Two Union Plaza, Suite 104 New London, CT 06320

 

 

 

 

 

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Your California Privacy Rights

 

Shine the Light. If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third-parties, what categories of personal information that we have shared with third-parties in the preceding year, as well as the names and addresses of those third-parties, please e-mail us at: [email protected]; sending us mail to: Two Union Plaza, Suite 104 New London, CT 06320

 

Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please e-mail us at: [email protected]; sending us mail to: Two Union Plaza, Suite 104 New London, CT 06320

 




Your California Privacy Rights


Shine the Light. If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third-parties, what categories of personal information that we have shared with third-parties in the preceding year, as well as the names and addresses of those third-parties, please e-mail us at: [email protected]; sending us mail to: Two Union Plaza, Suite 104 New London, CT 06320


Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please e-mail us at: [email protected]; sending us mail to: Two Union Plaza, Suite 104 New London, CT 06320


California Consumer Privacy Act of 2018 (“CCPA”). In addition to the foregoing, if you are a resident of the State of California certain other privacy-related rights may apply to you in accordance with the CCPA. These other rights include the right to opt-out of our sale of your Personal Information, as well as the right to know what Personal Information about you we have collected, whether your Personal Information was shared with third-parties in the preceding year and, if so, what categories of Personal Information were shared, as well as the categories of third parties with whom we shared that Personal Information. Please see below for a more complete description of your rights under the CCPA as a California resident.


Privacy Policy Quick Links

Below are links to key sections of our Privacy Policy:

Your Nevada Privacy Rights

Personal Information Collected

Use and Sharing of Personal Information

Non-Personal Information Collection and Use

Behavioral Tracking

Security of Your Personal Information

Children's Privacy

Opt-Out/Unsubscribe

Deleting, Modifying and Updating Your Information

Changes to this Privacy Policy

Contact Us

Your Nevada Privacy Rights

If you are a resident of the State of Nevada and would like to opt-out from the sale of your personal information to any third party data broker, please e-mail us at [email protected]; or sending us U.S. mail to: Two Union Plaza, Suite 104 New London, CT 06320

Personal Information Collected

[Please see our Privacy Provisions for California Residents for additional details regarding the categories of personal information collected] 

For the purposes of this Privacy Policy, “personal information” shall mean individually identifiable information from or about an individual. We collect personal information when you access certain of the Helping Americas Seniors Offerings and complete the required information request form and/or otherwise provide such information to us. Where a user attempts to utilize the Helping Americas Seniors Offerings, that user may be required to submit, and Helping Americas Seniors may collect, some or all of the following information: (a) full name; (b) full mailing address; (c) telephone number; (d) e-mail address; (e) date of birth; (f) gender; and (g) any other information requested on the Form. In addition, where a user enters a Contest and, where applicable, is selected as a potential prize winner in connection therewith, Helping Americas Seniors may collect some or all of the following: (i) Social Security Number (for prize winners); (ii) picture proof of identification, which may include a driver’s license, passport, voting card or similar government issued identification (for prize winners); and (iii) any other information requested in connection with the applicable Contest.

Use and Sharing of Personal Information

[Please see our Privacy Provisions for California Residents for additional details regarding our use and sharing of personal information]

By submitting your personal information by and through the Helping Americas Seniors Offerings, you agree that: (a) we may share, sell, rent, lease or otherwise provide that personal information to any third-party for any purpose permitted by law; (b) the third parties that we share, sell, rent, lease or otherwise provide your personal information may also re-sell your personal information to additional third parties; and (c) we may work with other businesses to bring selected retail opportunities to our users. These businesses and third-parties may include, but are not limited to: (i) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (ii) e-mail marketers; (iii) telemarketers (where permitted by applicable law); and (iv) direct marketers. We may also use your personal information to send you promotional messages regarding various Helping Americas Seniors products and/or services, as well as third-party products and/or services that we think may be of interest to you.

Where you submit personal information, we use the personal information that you make available to personalize your experience with the Site and to facilitate the delivery of the applicable Helping Americas Seniors Offerings to you, including to respond to any inquiries made by you.

Your email will only be shared with our preferred mailing partner for the purpose of sending third party promotional email communications.

You also agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Helping Americas Seniors Offerings, and to keep you informed of our other products and services.

We may also employ other companies and individuals to perform certain functions on our behalf. Examples include sending direct and electronic mail, removing duplicate information from user lists, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to our users’ personal information as needed to perform these functions for us, but we do not permit them to use user personal information for other purposes.

We will also use your personal information for customer service, to provide you with information that you may request, to customize your experience with the Helping Americas Seniors Offerings and/or to contact you when necessary in connection with your use of the Helping Americas Seniors Offerings. We may also use your personal information for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the Helping Americas Seniors Offerings. We may also combine the information we have gathered about you with information from other sources.

By submitting your personal information by and through the Helping Americas Seniors Offerings, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.

Where you provide “prior express consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive telephone calls from Helping Americas Seniors, including artificial voice calls, pre-recorded messages and/or calls (including SMS text messages) delivered via automated technology, to the telephone number(s) that you provided. Please note that you are not required to provide this consent in order to obtain access to the Helping Americas Seniors Offerings, and your consent simply allows Helping Americas Seniors to contact you via these means. Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes. Without limiting the foregoing, if you: (A) have your telephone number reassigned to another person or entity; (B) give up your telephone number so that it is no longer used by you; (C) port your telephone number to a landline or vice versa; or (D) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify Helping Americas Seniors of the Phone Number Change via e-mail at: [email protected], or by using one of the methods set forth in the “Contact Us” section below.

We reserve the right to release current or past personal information: (I) in the event that we believe that the Helping Americas Seniors Offerings are being or have been used in violation of the Terms and Conditions or to commit unlawful acts; (II) if the information is subpoenaed or requested pursuant to any court order or legal proceeding; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena/court order, prior to disclosure of any personal information pursuant to a subpoena; or (III) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if Helping Americas Seniors is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.

We reserve the right to release current or past personal information: (A) in the event that we believe that the Helping Americas Seniors Offerings are being or have been used in violation of the Terms and Conditions or to commit unlawful acts; (B) if the information is subpoenaed or requested pursuant to any court order or legal proceeding; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena/court order, prior to disclosure of any personal information pursuant to a subpoena; or (C) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if Helping Americas Seniors is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.

You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with third-parties for suppression purposes in compliance with applicable law, including the CAN-SPAM Act of 2003, as amended from time-to-time. Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third-parties without permission.

Non-Personal Information Collection and Use

[Please see our Privacy Provisions for California Residents below for additional details regarding the categories and types of non-personal information collected] 


IP Addresses/Browser Type

We may collect certain non-personally identifiable information about you and your desktop computer and/or mobile device when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the Helping Americas Seniors Offerings and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze usage of the Helping Americas Seniors Offerings.

Cookies

When a user visits the Site, we send one (1) or more cookies and/or gif files (collectively, “Cookies”) to assign an anonymous, unique identifier to the applicable user’s computer. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. We use Cookies to improve the quality of the Helping Americas Seniors Offerings, including for storing user preferences and tracking Site-user trends (such as pages opened and length of stay at the Site).

Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even in the case where a user rejects a Cookie, he or she may still use the Helping Americas Seniors Offerings; provided, however, that certain functions of the Helping Americas Seniors Offerings may be impaired or rendered inoperable if the use of Cookies is disabled. We reserve the right to retain Cookie data indefinitely.

Notwithstanding any other provision, we partner with third parties that collect information across various channels, including offline and online, for purposes of delivering more relevant advertising to you or your business Our partners may place or recognize a cookie on your computer, device, or directly in our emails/communications, and we may share personal information with them if you have submitted such information to us, such as your name, postal address, email address, or device ID. Our partners may link the hashed or obfuscated personal information we share with them to the cookie stored on your browser or device, and they may collect information such as your IP address, browser or operating system type and version, and demographic or inferred-interest information. Your data may be transferred outside of the country from which it was originally collected. To learn more about interest-based advertising in general and to opt out, please visit http://www.aboutads.info/choices. To opt-out of the use of your mobile device ID for targeted advertising, please see http://www.aboutads.info/appchoices.

Behavioral Tracking

Helping Americas Seniors as well as third party entities such as Google®, Bing® and Facebook®, use Cookies, pixels and other tracking technology (collectively, “Tracking Technology”) in connection with the Site for purposes of tracking users’ activities (such as websites visited, advertisements selected and pages viewed) after they leave the Site. Helping Americas Seniors and its third-party partners, use this Tracking Technology to target applicable users with advertisements featuring Helping Americas Seniors products and/or services, as well as third-party products and/or services, that may be of interest to applicable users.

In general, users may be able to disable some, but not all, of this tracking activity by utilizing the “Do Not Track” setting or similar options within most major Internet browsers. In addition, users may be able to opt-out of this form of tracking utilizing the options made available by the Network Advertising Initiative or Digital Advertising Alliance.

Further, users can opt-out of certain Google®-related tracking technology, and customize the Google® Display Network ads that they receive, by visiting the Google® Ads Settings at: http://www.google.com/settings/ads Google® also recommends installing the Google® Analytics Opt-out Browser Add-on for your web browser, which is available here: https://tools.google.com/dlpage/gaoptout. To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third-parties in connection with the Site.

Bing® is a registered trademark of Microsoft Corporation (“Bing”). Facebook® is a registered trademark of Facebook, Inc. (“Facebook”). Google+® is a registered trademark of Google, Inc. (“Google”). Please be advised that Helping Americas Seniors is not in any way affiliated with Bing, Facebook or Google, nor are the Helping Americas Seniors Offerings endorsed, administered or sponsored by any of the foregoing entities.

Cross Device Tracking

Helping Americas Seniors may track users’ use of the Helping Americas Seniors Offerings across various devices, including users’ personal computers and mobile devices, in order to optimize and personalize use of the Helping Americas Seniors Offerings. Helping Americas Seniors may collect certain user personal information across various devices.

Aggregate Data

Helping Americas Seniors reserves the right to transfer and/or sell aggregate or group data about users of the Helping Americas Seniors Offerings for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of Helping Americas Seniors Offerings users as a group, without disclosing personally identifiable information.

Third-Party Websites

This Site may contain links to third-party owned and/or operated websites including, without limitation, the websites owned and operated by Merchants, Third-Party Providers and/or Social Media Websites. Helping Americas Seniors is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of these third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Helping Americas Seniors has no responsibility or liability relating to them.

Security of Your Personal Information

We endeavor to safeguard and protect our users’ personal information. When users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). Where our registration/application process prompts users to enter sensitive information (such as financial information), and when we store and transmit such sensitive information, that information is encrypted with industry standard encryption technology.

Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. All of our users’ personal information is restricted in our offices. Only employees or third-party agents who need user personal information to perform a specific job are granted access to user personal information. Our employees are dedicated to ensuring the security and privacy of all user personal information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store user personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control.

Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site, other Helping Americas Seniors Offerings or otherwise via the Internet or wireless networks, is done at your own risk.

In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

Children’s Privacy

[Please see our Privacy Provisions for California Residents below for additional details regarding the personal information of minors] 

Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information at the Site. Helping Americas Seniors does not knowingly solicit or collect information from visitors under eighteen (18) years of age. Helping Americas Seniors encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Opt-Out/Unsubscribe

[Please see our Privacy Provisions for California Residents below for instructions on how California Residents can opt-out of the sale of their personal information to third parties]

  • To opt-out of receiving e-mail and other forms of communication from us, you can: (a) follow the instructions included in the applicable e-mail message or other communication; or (b) e-mail us at: Helping Americas Seniors
  • To opt-out from telemarketing calls, please follow the prompts on the call or contact customer service;
  • To opt-out from SMS/text messaging, reply STOP to the text/SMS message received;
  • To opt-out of browser-based push notifications, please disable the notifications at the time you receive the notification or disable notifications through your browser’s settings; and
  • To-opt out of cookies, interest-based advertising and/or third-party analytics, please see the section above.

Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Helping Americas Seniors Offerings, your participation in the Contests, as well as to respond to any inquiry or request made by you. To opt-out of receiving Helping Americas Seniors Offerings-related and/or inquiry response-related messages from Helping Americas Seniors you must cease requesting and/or utilizing the Helping Americas Seniors Offerings, cease participating in the Contests and/or cease submitting inquiries to Helping Americas Seniors as applicable.

Deleting, Modifying and Updating Your Information

[Please see our Privacy Provisions for California Residents below for instructions on how California Residents can access and/or delete personal information that we have collected] 

At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected. You may do so by e-mailing us at: [email protected]. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Please be advised that deleting your personal information may terminate your access to certain of the Helping Americas Seniors Offerings. If you wish to continue using the full complement of Helping Americas Seniors Offerings, you may not be able to delete all of the personal information that we have on file for you.

Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

Transfer of Personal Information Internationally

If you are visiting the Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of information across international boundaries. By visiting the Site and/or otherwise communicating electronically with us, you consent to such transfers. Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Privacy Policy.

Changes to this Privacy Policy

Helping Americas Seniors reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site that we are changing our Privacy Policy. If the manner in which we use personal information changes, Helping Americas Seniors will notify users by: (a) sending the modified policy to our users via email; and/or (b) by any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use your information in this different manner and we will only use your information in this different manner where you opt-in to such use.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices in general, please e-mail us at: [email protected]; sending us mail to: Two Union Plaza, Suite 104 New London, CT 06320

 

Privacy Provisions for California Residents

These Provisions for California Residents (“Provisions”) supplement, and do not limit in any way, the Privacy Policy set forth above. These Provisions apply solely to residents of the State of California (“CA Users”). We adopt these Provisions in compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in these Provisions. CA

Categories of Information We Collect

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 CA User or device (“personal information”). In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers. (Category)

EXAMPLE:

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, or other similar identifiers.

Collected: YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). (Category)

EXAMPLE:

A name, signature, Social Security number, physical characteristics or description, postal address, telephone number, passport number, driver's license or State identification card number, insurance policy 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. Some personal information included in this category may overlap with other categories.

Collected: YES

C. Protected classification characteristics under California or federal law. (Category)

EXAMPLE:

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).

Collected: YES

D. Internet or other similar network activity.

EXAMPLE:

Browsing history, search history, information on a CA User's interaction with a website, application or advertisement.

Collected: YES

E. Inferences drawn from other personal information.

EXAMPLE:

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: YES

 

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated CA User information.
  • Information excluded from the CCPA's scope, such as:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources (with the specific categories of personal information indicated in parenthesis):

  • Directly from our CA Users. For example, from online registration forms that our CA Users submit to us in connection with our membership services, our coupons-related products and/or services, our sweepstakes and promotions, and the other products and/or services that we offer by and through the Site. (Category A, B, C and E)
  • Indirectly from our CA Users. For example, through information we collect from our CA Users in the course of providing our products and/or services to them. (Category A, B, C, D and E)
  • Directly and indirectly from activity on the Site. This includes the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet Service Provider. In addition, we obtain certain Site usage details and analytics as same are collected automatically by us and our third party partners. (Category E)
  • When our CA Users interact with us on our social media accounts, including commenting on and/or liking our posts. (Category F)
  • From third-parties that interact with us in connection with the products and/or services that we offer to our CA Users. For example, third party entities that assist us in sending direct and electronic mail, removing duplicate information from CA User lists, analyzing data and providing marketing analysis. (Category A, B, C, D and E)

Use of Personal Information

We may use or disclose the personal information that we collect for one or more of the following business purposes (with the specific categories of personal information indicated in parenthesis):

  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with your registration for our coupons-related products and/or services, sweepstakes and promotions, and/or our other products and/or services, we will use that information to process your registration. (Category A, B, D and E)
  • To provide you with information, products or services that you request from us. (Category A, B, C, D and E)
  • To create, maintain, customize and secure your account with us. (Category A, B, C, D and E)
  • To provide you with e-mail, direct mail and telemarketing messages concerning certain Helping Americas Seniors products and/or services, as well as third-party products and/or services, that we believe may be of interest to you. (Category A, B, C, D and E)
  • To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (Category A, B, C, D and E)
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Site’s Terms and Conditions. (Category A, B, C, D and E)
  • To improve the Site and better present its contents to you. (Category A, B, C, D and E)
  • For customer service purposes and to respond to inquiries from you. (Category A and B)
  • For testing, research, analysis and product development. (Category A, B, C, D and E)
  • As necessary or appropriate to protect our rights, property or safety, and that of our clients or others. (Category A, B, C, E and E)
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Category A, B, C, D and E)
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA. (Category A, B, C, D and E)
  • 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 is among the assets transferred. (Category A, B, C, D and E)

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 with notice.

Sharing Personal Information

Subject to your right to opt-out of such sharing/sale, we may share, rent and/or sell your personal information: (a) with/to third parties for marketing purposes; and (b) for each of the other business purposes set forth above. The third parties that we share/sell your personal information with/to may also re-sell your personal information to additional third parties.

When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from CA Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of CA Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of CA Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months.

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 D      Internet or other similar network activity.

Category E     Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties (with the specific categories of personal information indicated in parenthesis):

  • Our affiliates. Our affiliates may also re-sell your personal information to additional third parties. (Category A, B, C, D and E)
  • Service providers. (Category A, B, C, D and E)
  • Third parties who provide the products and/or services featured on the Site. These third parties may also re-sell your personal information to additional third parties (Category A, B, C, D and E)
  • Third parties who purchase and/or license your personal information for marketing purposes, including: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers. If a third party purchaser of your personal information wants to resell it, that purchaser is required by law to provide you with explicit notice and an opportunity to opt-out of further sales, unless the right to resell it was secured by us at the point of collection. These third parties may also re-sell your personal information to additional third parties. (Category A, B and E)
  • Third parties to whom you authorize us to disclose your personal information in connection with the products and/or services that we provide to you. These third parties may also re-sell your personal information to additional third parties. (Category A, B, C, D and E)

In the preceding twelve (12) months, we have sold the following categories of personal information to third parties:

Category A     Identifiers.

Category B     California Customer Records personal information categories.

Category C     Protected classification characteristics under California or federal law.

Category D      Internet or other similar network activity.

Category E     Inferences drawn from other personal information.

In the preceding twelve (12) months, we have sold the above referenced categories of personal information to the third parties who purchase and/or license your personal information for marketing purposes, as well as the third parties who provide the products and/or services featured on the Site. These third parties may also re-sell your personal information to additional third parties.

Your Rights and Choices

The CCPA provides CA Users (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Opt-Out from the Sale of Your Personal Information

You have the right to opt-out of our sale of your personal information to third parties. To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable CA User request to us by either:

·      Emailing us at: [email protected]

·      Sending us mail to: Two Union Plaza, Suite 104 New London, CT 06320

  • We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) days of the receipt of your request.

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 twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you:

  • 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 have shared 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. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you. 

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. 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 obligations in connection with our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech rights, ensure the right of another CA User to exercise her/his free speech rights or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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, but only if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with CA User expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. 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 your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by either:

·      Emailing us at: [email protected]

·      Sending us mail to: Two Union Plaza, Suite 104 New London, CT 06320

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information.

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

  • Provide sufficient information that allows us to reasonably verify that you are: (1) the person about whom we collected personal information; or (2) 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 that the personal information relates to you. Making a verifiable CA User request does not require you to create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. 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 CA User 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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; and/or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to these Provisions

We reserve the right to amend these Provisions in our discretion and at any time. When we make changes to these Provisions, we will notify you by email or through a notice on the Site’s homepage.

Contact Information

If you have any questions or comments about these Provisions, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either:

·      Emailing us at: [email protected]

·      Sending us mail to: Two Union Plaza, Suite 104 New London, CT 06320






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