Effective Date: January 1, 2020
- Introduction and Overview
If you are contacting us about a potential claim, we will request certain information from you as described in more detail below. You may always choose not to provide the requested information, but if you do not provide the information you will not be contacted regarding the merits of your potential claim. You can access, update, or remove any information you submit to us about a potential claim, or request at any time that we not share it with our lawyer clients by e-mailing [email protected]
- Information Collection
- Information You Provide
We collect information you provide, such as when you submit a potential claim for review. We may use Service Providers (defined below) to collect this information. The categories of information we collect and have collected in the last 12 months, include the following:
- Contact Information: your name, e-mail address, phone number, postal address, and similar contact information.
- Demographic Data: demographic information including your age, gender, and state.
- Claim Data: information about your potential claim, such as injury to person or property and associated information, all of which is clearly labeled at the time of collection.
- Content: We collect the content of messages you send to us, such as information about your potential claims, or questions and information you provide. We also collect the content of your communications as necessary to provide you with the Service.
You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.
- Information Collected Automatically
In addition, we automatically collect information when you use the Service. We may use Service Providers to collect this information. The categories of information we automatically collect and have collected in the last 12 months includes: Service use data, including data about the pages you visit, the e-mails and advertisements you view, the time of day you browse, and your referring and exiting pages; device connectivity and configuration data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address; and location data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).
We use various current – and later – developed technologies to collect this information (“Tracking Technologies”), including the following:
- Log Files. A log file is a file that records events that occur in connection with your use of the Service, such as your service use data.
- Cookies. A cookie is a small data file stored on your device that acts as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
For further information on Tracking Technologies and your rights and choices regarding them, see the sections entitled “Analytics and Advertising” and “Your Rights and Choices” below.
- Information from Other Sources.
- Use of Information.
We collect and use your information to conduct a preliminary analysis of your potential claims. We may contact you to verify your information and further explore your potential claims. Other business purposes for collecting and using information, including in the last 12 months, include to:
- Provide and manage our Service.
- Perform services requested by you, such as to respond to your comments, questions, and requests.
- Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
- Prevent and address fraud, breach of policies or terms, and threats or harm.
- Monitor and analyse trends, usage, and activities.
- Conduct research.
- Improve the Service or other AAL websites, apps, marketing efforts, products and services.
- Develop and send you direct marketing, including advertisements and communications about our and third party products, offers, events, and services.
- Send you advertising.
- Fulfill any other business or commercial purposes at your direction, disclosed to you, and/or with your consent.
Notwithstanding the above, we may use information that does not identify you (including information that has been de-identified or aggregated) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.
- Sharing of Information
- Lawyer Clients. We provide our lawyer clients with lead generation services. When you submit information to us regarding a potential claim, we share your information at your direction with our lawyer clients who we think may be a good fit to assist you with your potential claims. Our lawyer clients may then contact you to verify your information and further evaluate your claims. We are not responsible for how our lawyer clients treat your information, and any questions regarding their use of your data should be directed to them, not to us.
- Service Providers. We share your information with our agents and other service providers (collectively “Service Providers”) in connection with their work on our behalf. Service Providers assist us with services such as customer relationship management, data analytics, marketing and promotional services, website hosting, and technical support. Service Providers are prohibited from using your information for any purpose other than to provide their services to us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
- Affiliates. We may share your information with our related entities including our parent and sister companies. For example, we may share your information with our affiliates for lead generation, marketing, and technical operation purposes. Affiliates may act as our service providers, or in certain contexts, independently decide how to process your information.
- Business Partners. We may share your information with our business partners in connection with offering you co-branded services, selling or distributing our products, or engaging in joint marketing activities.
- Vendors and Other Parties. We share your information with vendors and other parties for purposes such as tailoring advertisements, serving Matched Ads (defined below), measuring and improving our Service and advertising effectiveness, and enabling other enhancements to AAL Media products and services. Vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
- Merger or Acquisition. We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
- Security and Compelled Disclosure. We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information to protect the rights, property, life, health, security and safety of us, the Service or any third party.
- Consent. We may share your information for any other purpose disclosed to you and with your consent.
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with other parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.
- Social Media and Technology Integrations
- Analytics and Interest-Based Advertising
We use analytics services, such as Google Analytics, to help us understand and analyze how you access and use the Service and other services. In addition, we work with agencies, ad networks, advertisers, and other technology services to place advertisements about our products and services on the Service and on other services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
As part of the process, we and other parties may incorporate Tracking Technologies on our Service (including in our e-mails and advertisements) and other services. Some of these technologies track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you on the Service and other services after you have left the Service (“Interest-based Advertising”).
We also use audience matching services to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). For example, we use Facebook Custom Audiences to serve Matched Ads. This is done by us incorporating a pixel from the technology service on our own Service or uploading data (such as the email address you provided us when submitting a potential claim for review) to the technology service, and the technology service matching common factors between our data and their data.
For further information on the types of Tracking Technologies we use and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the sections entitled “Information Collected Automatically” and “Your Rights and Choices.”
- Your Rights and Choices
- Potential Claims
You may access, update, or remove any information you have submitted to us about a potential claim, or request that we do not share it with our lawyer clients, by e-mailing [email protected]
. We will respond to your request to access, update, or delete your information, or stop sharing, within ten (10) business days. Before we are able to provide you with any information, correct any inaccuracies, or delete any information, however, we may ask you to verify your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Further, any request to stop sharing with our lawyer clients will not affect any information previously shared with our lawyer clients, and questions regarding their use of your data should be directed to them, not to us.
- Tracking Technologies Choices
- Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
- Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit https://allaboutdnt.com.
Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly.
- Analytics and Interest-Based Advertising
You can opt-out of your data being used by Google Analytics through cookies by visiting Google Analytics Opt-out Browser Add-on
and downloading the Google Analytics Opt-out Browser Add-on.
Where we work with other parties to engage in Interest-Based Advertising, these parties are often members of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative ("NAI"). These programs offer centralized locations where users can make choices about the use of their information for Interest-based Advertising. To learn more about the DAA’s Self-Regulatory Program for Online Behavioral Advertising and your opt-out options for their members, please visit https://aboutads.info/choices
. To learn more about the NAI and your opt-out options for their members, please visit https://www.networkadvertising.org/choices/
To opt-out of us using your data for Matched Ads, please contact us as set forth in the section entitled “Contact Us” below and specify that you wish to opt-out of Matched Ads. We will remove your information from the Matched Ads or request that the applicable technology service not serve you Matched Ads based on information we provide to it. Alternatively, you may also contact the applicable technology service to opt-out.
Please note that any opt-outs only apply to the specific browser or device from which you opt-out. Further, opting-out through the DAA or NAI only means that the selected members should no longer deliver certain Interest-Based Advertising to you, and does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for the effectiveness of, or compliance with, any other parties’ opt-out options or programs or the accuracy of their statements regarding their practices or programs.
- E-mails. You can opt-out of receiving promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link, or e-mailing us at the e-mail address set forth in the section entitled “Contact Us” below with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that you cannot opt-out of non-promotional e-mails, such as those about your account, transactions, servicing, or AAL’s ongoing business relations.
- Text Messages and Calls. You can opt-out of receiving text messages or calls to your phone number at any time by (i) for text messages, texting “STOP” in response to any text message you receive from us or contacting us as set forth in the section entitled “Contact Us” below and specifying you want to opt-out of text messages; and (ii) for calls, requesting opt-out during any call you receive from us or contacting us as set forth in the section entitled “Contact Us” below and specifying you want to opt-out of calls.
Please note that your opt-out is limited to the e-mail address and phone number used and will not affect subsequent subscriptions.
- Data Security
The Service is not directed to children under thirteen (13) years of age. AAL does not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) from children. If you are a parent or guardian and believe AAL has collected such information, please contact us as set forth in the section entitled “Contact Us” below. We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.
- International Transfer
- Contact Us
Attention: Data Privacy
4778 Dewey Drive
Fair Oaks, CA 95628
- Additional Disclosures for Nevada Residents
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as set out in the “Contact Us” section above.
- Additional Disclosures for California Residents
These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.
- Notice of Collection
In the past 12 months, we have collected the following categories of personal information listed in the CCPA:
- Identifiers, including name, email address, phone number account name, IP address, and an ID or number assigned to your account.
- Customer records, including information about your potential claim, such as injury to person or property and associated information.
- Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
- Commercial information, including engagement with the Services.
- Internet activity, including your interactions with our Service.
- Geolocation data, including location enabled services such as WiFi and GPS.
- Inferences, including information about your interests, preferences and favorites.
For more information on information we collect, including the sources we receive information from, review the “Information Collection” section above. We collect and use these categories of personal information for the business purposes described in the “Use of Information” section above, including to provide and manage our Service.
- Right to Know and Delete
If you are a California resident, you have the right to delete the personal information we have collected from you and the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold;
- The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
- The business or commercial purpose for collecting or selling the personal information; and
- The specific pieces of personal information we have collected about you.
To exercise any of these rights, please submit a request through our Webform
, call our toll free number at 888-970-9060, or email us at [email protected]
. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
- Right to Opt-Out
To the extent AAL sells your personal information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information
or emailing us at [email protected]
- Authorized Agent
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
- Right to Non-Discrimination
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
- Shine the Light
California’s “Shine the Light” law permits customers who reside in California to request, once per year, disclosure regarding how we share certain of their information with third parties and affiliates for those third parties’ and affiliates’ own direct marketing purposes. If this law applies to you and you wish to obtain further information about our sharing, please contact us as set out in the “Contact Us” section above. Requests must state “California Privacy Rights Request” in the subject line or first line of the description and also include your name, street address, city, state, and ZIP code. We are not required to respond to requests made by means other than through the provided e-mail or mail addresses.
- Additional Disclosures for Data Subjects in Europe
- Data Controller
- Lawful Basis for Processing
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or our Service Providers; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.
- Your European Privacy Rights
If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
You may exercise your rights by submitting a written request to us at the address set out in the “Contact Us” section above. We will respond to your request within 30 days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.
If you have a complaint about our use of your personal data or response to your requests regarding your personal data, you may submit a complaint to the data protection regulator in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us.