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Altair Privacy Policy for Veterans

Altair Data Resources Privacy Policy

Last amended: January 3, 2022

Altair Data Resources (“Altair”) provides a variety of data, marketing, hygiene, and analytics products (the “Services”) designed to help for-profit and not-for-profit organizations market their own products and services or to assist their end user customers in marketing their products and services. Our solutions, many of which are described on this website, are used via direct mail, email, online and other marketing channels.  All marketing offers to Veterans are vetted to make sure they are offering a significant value or cost-savings to the Veteran consumer from only industry-leading marketers.

We take very seriously the privacy interests of the individuals whose information we handle and maintain in our database. We provide this Privacy Policy (“Privacy Policy”) to explain how we use and manage information, and what rights consumers have to control how their information is used in marketing. We also operate corporate websites, designed for our own customers and prospective customers, and others who want to learn about our services.

1. Information That We Collect and Use in Our Services

In the below tables and sections, we describe:

1. Our Collection of Personal Information – the types of Personal Information that we collect, the types of sources we collect it from,

2. Our Disclosure and Use of Personal Information – the types of recipients to whom we disclose or share Personal Information.

3. Our Business Purposes – our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.

4. Your Privacy Rights and Choices – what rights you have to request that we “opt out” your information from our marketing database or to request categories and personal information that we may have collected about you.

The following sets forth the categories of information we collect and purposes for which we may use Consumers’ personal information:

1. OUR COLLECTION OF PERSONAL INFORMATION

Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.

Category  Categories of Sources
Identifiers, e.g., name; alias; postal address; telephone number; email address.  Data compilers and consumer data resellers. Consumer goods retailers, informational and retail websites, public records and other publicly available sources, content publishers, non-profit organizations, business-to-business companies, consumer surveys and survey companies, affiliate networks. (Note that above categories may be overlapping in nature.) • Advertising networks, data analytics providers, operating systems and platforms and social networks. • Corporate affiliates. (Collectively, “Commercial Data Sources.”) • Government sources such as U.S. Census Bureau.  
Characteristics of protected classifications under California or US law E.g., race; color; religion; sex/gender; marital status; medical condition; military or veteran status; national origin; ancestry; self-reported health information.          Commercial Data Sources.  
Commercial or transactions information E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.            Commercial Data Sources.  
Internet or other electronic network activity information E.g., browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer’s interaction with a website, application, or advertisement.          Commercial Data Sources, Digital Marketing Service Providers  
Geolocation dataCommercial Data Sources, US Postal Service.  

2. How We Use the Information We Collect or Receive

Altair uses the Information for various purposes, including the following.

As Part of Our Services

Data Marketing Services. Our Services include creating marketing campaigns using direct mail, email or digital social media ads or banner ads to send relevant offers for mortgages, auto loans and consumer loans that will be of significant benefit to the consumer.  Our customers that implement these marketing campaigns are printers, digital agencies, marketers, and lenders.

• Additional Marketing Services. Other Services we may sometimes provide to our customers (or that they may provide to their own customers), which may overlap with or supplement the above, may involve (a) assistance in targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing; (b) measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases; (c) analyzing and optimizing our customers’ (or their service providers’) proprietary databases; or (d) providing data “hygiene” services, which is how companies update and/or “clean” their databases by either verifying, removing or correcting old, incorrect or outdated information.

To Operate Our Services

We use your information as a prospect or as our customer to help us personalize and continually improve your query/count and order experience with us. We do not sell, rent or trade, or share your business contact information with other companies for their own marketing purposes.

3. How We Share Information with Third Parties

Altair may share the Information with marketing services, platforms and service providers that we retain in order to provide the Services we have described above and as described below. This includes:

• Customers: As described above, our customers use the information in their direct marketing offers through direct mail, email and digital social media and banner ads when we provide our Services.

• Partners: We also may share the Information, including personally identifiable information, with business and data partners for related services to provide more tailored targeted marketing, advertising, and communications. Likewise, we may do so for analytical purposes, including to help these other parties measure campaign performance, inform future campaigns, or to handle, analyze, or segregate this Information on our or our customers’ behalf.

• Corporate transfers: If Altair, its stock or its significant assets are acquired by or merged into another entity, our information will be transferred to that entity, and may be shared during due diligence in anticipation of any such transaction.  In the event of any transfer due to an ownership change, the new company must agree to the same Terms and Conditions of Altair’s Privacy Policy.  If not, consumer information in this database will be deleted.  All users will be notified of a change in ownership via public posting as well as via email.

• As required by law or to protect any person or entity: Altair may disclose Information if we believe that such disclosure is necessary to (a) comply in good faith with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect or otherwise defend the rights, property or safety of Altair, our customers, or any other person or entity.

Third Party Responsibilities

All third parties are bound to the same terms and conditions as are included in Altair’s Privacy Policy.  Third Party use or disclosure of consumer information (including non-personalized or anonymized data) is prohibited for any reason unless consented to by the consumer or user.

4. Your Marketing Rights and Choices

Without being discriminated against for exercising these rights, users have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the use of your personal information, subject to certain restrictions. This section describes how to exercise those rights and our process for handling those requests. Please note that sometimes we act as a “service provider” for our clients, in which case we receive and act on instructions from the client(s) as to the client data provided: any requests to exercise rights with respect to data we handle on behalf of a client should be directed to the particular client.

a. Right to request access to your personal information

Consumers have the right to request that we disclose what categories of your personal information that we collect, use, or share. You may also request the specific pieces of personal information that we have collected from you.

b. Right to request deletion of your personal information

Consumers may also request that we delete any personal information that we collected from you, such as if you have been a customer of ours. (Note that this is different from your right to “opt out” of us sharing your personal information, which is described below). However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. Additionally, we need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.

c. Right to “opt-out” of the sale of your personal information.

Consumers may opt out of the use or sharing of their personal information. Your information will only be used or shared in exchange for “valuable consideration” of products or services that will be of benefit to you.

Depending what information we have about you, and whether we have included any of it in our marketing products and services, we may have shared certain categories of information about you in the last 12 months.

If you would like to opt out, you may do so as outlined on the following page.

d. How to exercise your access and (if applicable) deletion rights

Consumers may exercise their privacy rights by sending an email to privacy@altairdata.com, submitting your request or by contacting us at (800) 241-6631. Or, if you prefer, you can contact us directly by mail at:

Veterans Financial Deals

c/o Altair Data Resources, Inc.

Attn: Privacy Officer

1749 Mallory Lane, Suite 201

Brentwood, TN 37027

We will process your request within 30 days from the time we received the request, or sooner where required by law.

For security purposes (and as required by law), we will verify your identity when you request categories or specific pieces of personal information, we may have received about you. You will need to confirm your identity by answering a series of questions that confirm you are the person you claim to be.

Once we have verified your identity, we will respond to your request as appropriate:

• Where you have requested the categories of personal information that we have collected about you, we will provide a list of those categories.

• Where you have requested specific pieces of personal information, we will provide the information you have requested provided we do not believe there is an overriding privacy or security concern to doing so.

• Where you have requested that we delete personal information that we may have collected from you, we will seek to confirm whether your request is for an “opt out” or a “deletion”: because “opt out” or “do not share” rights enable us to maintain your information for “suppression” purposes – i.e., to prevent us from sharing information about you in the future (which is what many consumers requesting “deletion” actually desire to occur) — we try to explain this in order to ensure we are meeting consumers’ preferences. (In addition, “deletion” rights only apply to information that we have collected “from” consumers – which does not apply to much of the information in our databases.)

• Upon completion of the above process, we will send you a notice that explains the categories of personal information or specific pieces of information we were able to locate about you, whether we (1) deleted, (2) deidentified, or (3) retained the information we collected from you in our suppression file. Certain information may be exempt from such requests under applicable law.

If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.

• If you would like to opt out of direct mail advertising in general, we recommend that you visit the DMA Choice website, at dmachoice.thedma.org. The DMA Choice service is managed by the ANA (Association of National Advertisers) and allows you to follow a few easy steps to ensure that your marketing preferences are honored. Many of our partners will only accept requests directly from you, and our Consumer Name Removal Guide contains the information that you will need.

e. Right to nondiscrimination. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.

f. Information about persons under 16 years of age

 We do not knowingly collect personal information from minors under 16 years of age in unless we have received legal consent to do so. If we learn that personal information from such residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).

g. Authorized agents

You may also designate an agent to make requests to exercise your rights. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.

5. Cookies and Similar Technologies

Cookies and How We Use Them

Altair and its business partners use certain industry-standard technologies, including cookies and similarly functional technologies, which we describe below. (We use these technologies on our website, for instance, and our partners may use these technologies in their own marketing services.)

We may work with third parties to provide or enhance our services (e.g. for purposes of tailoring ads, or placing browser cookies), or to offer marketers ways to access or use our Information, often in de-identified form. These partners may set and access their own cookies, pixel tags and similar technologies on your device, which may have cookies with varying expiration periods. Those partners may, likewise, collect various types of information about your browser, device, or browsing activities through use of these cookies.

Cookies, in turn, are small data files that contain a string of characters, such as a unique browser identifier. Cookies are stored on your computer or other device and act as tags that identify your device. Our (or other companies’) servers send your device a cookie when you visit a website. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access web pages (such as the website of a marketer), pixel tags may generate a generic notice of the visit and permit our partners (or sometimes, us) to read the cookies that a respective company or server has deployed. Pixel tags are used in combination with cookies to track the activity on a site by a particular device. When you turn off cookies, pixel tags simply detect a given website visit.

We or our service providers, and other online marketing platforms that we or they work with, may use cookies to, among other things, “remember” you, determine visitor patterns and trends, collect information about your activities on our clients’ sites, or interact with the advertising you see. Cookies are used in this way to provide relevant content to you and replace non-relevant communications with ads that better match your interests.

Disabling Cookies

Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of our website and other services may be difficult to use or become inoperable.

6. Data Sharing Risks, Benefits and Limitations

If you access third-party services, such as Facebook, Google, or Twitter, through the Sites to login to the Sites or to share information about your experience on the Sites with others, these third-party services may be able to collect information about you, including information about your activity on the Sites, and they may notify your connections on the third-party services about your use of the Sites, in accordance with their own privacy policies.

If you choose to engage in public activities on the Sites, you should be aware that any information you share there can be read, collected, or used by other users of these areas.  You should use caution in disclosing personal information while participating in these areas. We are not responsible for the information you choose to submit in these public areas.

Altair collects information on consumers for the sole purpose of identifying beneficial offers and needs that a products and services may solve for a consumer and facilitating relevant marketing offers to that consumer.  For consumers, this data sharing provides access to special offers and products that would not normally be accessible or available to them.   

8. Security and Data Integrity

Altair takes steps to help ensure that the data we possess is housed and transmitted securely. This may include various types of physical and electronic security, including firewall protections, encryption, hashing or truncation of data, and access controls to personal information. While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we employ efforts that are designed to ensure that this does not occur.

In the unlikely event that a breach should happen where sensitive data is accessed, Altair will publicly post on our website with a link to all of the pertinent information about the breach and will include instructions for further actions consumers may take.  Additionally, an email to all affected users will be sent notifying them of the breach and instructions for further actions they may take.

7. Changes to this Privacy Policy

From time to time, we may update this Privacy Policy. Any changes to it will become effective when it is posted to our website. Please check back to learn of any changes to this Privacy Policy. In addition, any policy changes affecting users will be communicated via email in advance with instructions of further actions they may take.

10. Storage of Information in the United States

Data will be stored for no more than 12 months for accounts with no activity. If no activity has been registered for 12 months, consumer information will be removed from the database.

If you are accessing our website from a location outside of the United States, your connection will be through and to servers located in the United States and all Information you provide will likely be processed and securely maintained in our web servers and internal systems located within the United States. (We likewise generally store the Information used in our Services in the United States.) Thus, you should be aware that in accessing this website or otherwise communicating with us, the information we collect or receive from you may be subject to laws with lesser or different privacy standards than those in your own country (such as if you are in a country located in the European Union).

11. Contact Us

Altair has a designated privacy contact. If you have questions related to this Privacy Policy, or regarding our products or services, please contact us:

Privacy Officer

Veterans Financial Deals

c/o Altair Data Resources, Inc.

1749 Mallory Lane Suite 201

Brentwood, TN 37027

Email: privacy@altairdata.com