LEGAL
California Privacy Notice
This Privacy Policy provides additional information solely for California residents, as required under the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"). As a California resident, you have certain rights, subject to legal limitations, regarding the collection, use, and sharing of your personal information described below.
Scope of this notice
This notice applies to LOYALTY LTD, a Nevada limited liability company ("LOYALTY LTD," "we," "us," or "our"), located in Henderson, NV.
The information below applies to personal information as defined in the CCPA collected both online and offline. For purposes of this section, "personal information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household.
Personal information does not include publicly available information, information that has been de-identified, aggregated consumer information, and information excluded from the CCPA's scope, like:
- 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;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
If you have a financial product or service with us, we will use and share any information that we collect from or about you in accordance with our Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.
Categories of Personal Information We Collect & Disclose
In the past 12 months, we have collected, and disclosed to third parties for our business purposes, the following categories of Personal Information relating to California residents:
- A. Identifiers — Name, alias, postal address, unique identifier, IP address, email address, account name, SSN, driver's license number, passport number. Collected: Yes / Disclosed: Yes
- B. Customer Records Information — Name, signature, SSN, address, phone, passport number, driver's license/state ID, bank/credit card numbers. Collected: Yes / Disclosed: Yes
- C. Commercial Information — Records of property, products/services purchased or considered, purchase histories/tendencies. Collected: Yes / Disclosed: Yes
- D. Internet Activity — Browsing history, search queries, interactions with site/app/ads. Collected: Yes / Disclosed: Yes
- E. Sensory Data — Audio, visual, thermal, olfactory, or similar data, including call recordings and images submitted for identity review. Collected: Yes / Disclosed: Yes
- F. Professional/Employment Info — Employment history, qualifications, licensing, disciplinary records. Collected: Yes / Disclosed: Yes
- G. Inferences — Profiles reflecting preferences, characteristics, attitudes, behavior, abilities. Collected: Yes / Disclosed: Yes
Retention
We retain each category of personal information for as long as necessary to fulfil the purposes described in this notice, and thereafter as required to comply with our legal, tax, recordkeeping and dispute-resolution obligations. Consent records evidencing telephone contact consent are retained for at least five years. Identity verification documents are retained for no longer than two years from collection unless a longer period is required by law.
Sources of Collection
We may collect personal information from:
- You or your agent
- Activity on our services
- Transactions with us or affiliates
- Subsidiaries or affiliates of LOYALTY LTD
- Third-party providers, marketing partners, credit agencies, card companies
- Public sources
Purposes of Use
We use personal information for:
- Auditing traffic/consumer interactions
- Security and fraud prevention
- Debugging services
- Ad customization
- Service performance (account handling, transactions, hosting, marketing)
- Internal research and product enhancement
- Safety and quality verification
- Commercial activities including contests, promotions, sales/mergers
Sharing with Third Parties
We may disclose personal information to:
- LOYALTY LTD affiliates and subsidiaries
- Vendors/service providers
- Authorized third parties connected with products/services
- Government agencies as legally required
- Entities involved in business sales/transfers
Sale of Personal Information
We sell personal information subject to the CCPA. Loyalty LTD operates lead generation, pay-per-call and performance marketing services. When a consumer submits an inquiry or places a call through one of our properties or through one of our media partners, we transfer the personal information in that inquiry to one or more buyers, advertisers, service providers or business partners for monetary or other valuable consideration. That transfer is a "sale" under the CCPA.
In the past 12 months, we have sold the following categories of personal information:
- A. Identifiers — name, postal address, email address, telephone number, IP address and unique identifiers
- C. Commercial Information — records of the products or services a consumer inquired about or considered
- D. Internet Activity — campaign, source and interaction data associated with the inquiry
- E. Sensory Data — call recordings, where a consumer's inquiry was placed by telephone
- G. Inferences — attributes derived from the inquiry for the purpose of matching it to a buyer
We have sold these categories to the following categories of third parties: lead buyers and advertisers; call buyers; contractors and service providers operating in home services and regulated financial verticals; affiliate networks, publishers and marketing partners; and analytics, verification and data enrichment providers.
We do not sell sensitive personal information. Social Security numbers, driver's licence, state identification and passport numbers, financial account information, and images of government identity documents are collected for identity verification, tax and compliance purposes only. They are not sold, and they are not shared for cross-context behavioural advertising.
We do not sell the personal information of any consumer we know to be under 16 years of age.
Your Right to Opt Out of the Sale of Your Personal Information
You have the right to direct us not to sell your personal information. You may exercise that right by either of the following methods:
- Using the Do Not Sell or Share My Personal Information link available in the footer of every page of this website; or
- Emailing privacy@loyaltyltd.co with the subject line "Do Not Sell My Personal Information".
We will act on your request within 15 business days of receiving it. If we have sold your personal information to a third party after you submitted your request, we will notify that third party of your request.
Opting out of the sale of your personal information does not require you to create an account with us, and we will not discriminate against you for exercising this right.
Opt-Out Preference Signals
We recognise and honour opt-out preference signals, including the Global Privacy Control (GPC), transmitted by your browser or an authorised agent. Where we detect such a signal, we treat it as a request to opt out of the sale of personal information associated with that browser.
Sensitive Personal Information
Some of the personal information we collect is "sensitive personal information" under the CPRA. This includes your Social Security number, driver's license number, state identification card number or passport number, account log-in or financial account information, and images of government identity documents you submit to us.
We collect and use sensitive personal information only for the purposes permitted under the CPRA without triggering the right to limit, namely: to perform the services you or your business have requested; to verify your identity; to prevent, detect and investigate security incidents and fraudulent or illegal activity; to comply with our legal obligations, including tax and recordkeeping requirements; and to verify and maintain the quality and safety of our services. We do not use or disclose sensitive personal information to infer characteristics about you.
Right to Limit the Use and Disclosure of Sensitive Personal Information. You have the right to direct us to limit our use and disclosure of your sensitive personal information to the permitted purposes described above. Because we already limit our use of sensitive personal information to those permitted purposes, we do not offer a separate "Limit the Use of My Sensitive Personal Information" mechanism. If you believe we have used your sensitive personal information for any other purpose, or you wish to make a request regarding that information, email privacy@loyaltyltd.co and we will respond within the time period described below.
Your CCPA Rights
You have the right to:
- Opt-out of Sale — Direct us not to sell your personal information, as described in the Sale of Personal Information section above.
- Access — You may request details of categories, sources, purposes, third-party disclosures, and specific pieces collected.
- Delete — Request deletion of your personal information, subject to exceptions for legal or operational needs.
- Correct — Request correction of inaccurate personal information we maintain about you.
- Limit Sensitive Personal Information — As described in the Sensitive Personal Information section above.
Submission of Requests:
CCPA Request Form
Email privacy@loyaltyltd.co
Verification: Requests require identity verification before processing.
Response Time: Within 45 days (extendable to 90 days with notice).
Non-Discrimination
We will not discriminate against you for exercising rights under the CCPA.
Changes to This Notice
This notice may change to meet legal and operational requirements. Updates will be posted with an updated "Last Revised" date, and continued use signifies acceptance.
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