Last Updated: October 18, 2023
We collect, process, and retain information from you and any devices you may use when interacting with the Websites, and in other ways described below.
Information You Give Us: We receive and store information you provide to us through the Websites when you register for an account or give to us in any other way, including your name, mailing address, phone number, email address, and business or employment information.
Information We Automatically Collect: We collect information about your use of the Websites, such as the pages you view and other interactions you have. We receive and store certain types of information whenever you interact with the Websites. The Websites use “cookies,” tagging, and other tracking technologies to help enable us to enhance or personalize your experience. This information includes computer and connection information such as statistics on your page views, traffic to and from the Websites, referral URL, ad data, your IP address, and device identifiers. This information also may include your browsing history, transaction history, and your web log information.
Information From Other Sources: We may supplement the personal information we collect with information from third parties or collected offline, such as information collected by ACA over the phone, and add it to your account information. This information may include, but is not limited to, demographic information, additional contact information, group affiliations, and occupational information. We also may collect information about you from credit reporting agencies, for example, to determine your creditworthiness, credit score, and credit usage.
We use your information to help us personalize and continually improve your experience on the Websites, including fulfilling requests for information, analyzing and compiling trends and statistics, and communicating with you.
We also may use your information to:
We may use the information from one portion of the Websites on other portions of the Websites, and we may combine information gathered from multiple portions of the Websites into a single record. We also may use or combine information that we collect offline or we collect or receive from third-party sources for many reasons, including to enhance, expand, and check the accuracy of our records. Additionally, information collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected.
We share your personal information with third parties as described below. In addition, we may share information that does not specifically and personally identify you, such as aggregate information, device identifiers or other unique identifiers to third parties.
Third-Party Service Providers: We engage third-party service providers to perform functions on our behalf such as: hosting, technical integration, analytics, customer service, and fraud protection. For example, we use third parties to process payments made to us. These third parties may have access to your personal information when needed to perform their functions.
Business Partners: We may share information that personally identifies you with business partners.
Law Enforcement, Legal Process, and Emergency Situations: We may also use or disclose your personal information if required to do so by law or on the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Websites; (b) protect and defend our rights or property, the Websites or our users, or (c) act to protect the personal safety of us, users of the Websites or the public.
You can update your account information through the account settings page within the Websites.
If you would like to request access, modification, correction, or deletion of personal information that you have provided to us or that you believe we may have collected about you, please contact us at [email protected]. We may not be able to delete your personal information without also deleting your user account. You will not be permitted to examine the personal information of any other person or entity. In order to verify your identity, you may be required to provide us with personal information prior to accessing any records containing information about you. We may not accommodate a request to change or delete personal information if we believe doing so would violate any law or legal requirement, or cause the information to be incorrect.
When you create an account through the Websites or sign up for certain communications, you are required to provide us with an accurate e-mail address through which we may contact you. Such registrations or requests through the Websites constitute your express acknowledgment that we may use your e-mail address to communicate with you about product or service offerings from us and our selected partners. While you cannot opt-out of receiving notifications and other communications regarding your account or your transactions, you can opt-out of receiving promotional and other marketing emails from us by: (1) using the “unsubscribe” feature in our marketing e-mails; or (2) contacting us at [email protected].
Like many websites, we use tracking technologies such as cookies, web beacons, and similar technologies to record your preferences and track the use of the Websites. We may also use these technologies to monitor traffic and improve the Websites.
Some content or applications on the Websites may be served by unaffiliated third parties. We do not control these third parties’ tracking technologies or how they may be used. We are not responsible for the content or privacy practices on any website not operated by us to which the Websites link or that link to the Websites.
Online Tracking Choices: You also have choices to limit some tracking mechanisms that collect information when you use the Websites. Many web browsers automatically accept cookies, but you can usually modify your browser’s settings to decline cookies if you prefer. If you choose to decline cookies, certain features of the Websites, including the Websites themselves, may not function properly or remain accessible to you. In addition, you may also render some web beacons unusable by rejecting or removing their associated cookies. Note that if you choose to remove cookies, you may remove opt-out cookies that affect your advertising preferences.
We maintain safeguards to protect your personal information. However, no system is completely secure or error-free. We do not, and cannot, guarantee the complete security of your personal information. You can help protect the privacy of your own information by using encryption and other techniques to prevent unauthorized interception of your personal information. You are responsible for the security of your information that you transmit to us or view, download, or otherwise access when using unencrypted, public, or otherwise unsecured networks.
Users Outside of the United States: If you use the Websites outside of the United States, you understand and consent to the transfer of your personal information to, and the collection, processing, and storage of your personal information in, the United States and elsewhere. The laws in the United States and these countries regarding personal information may be different than the laws of your state or country.
If you are a California consumer, you have certain rights with respect to the collection, use, transfer, and processing of your “Personal Information”, as defined by the California Consumer Privacy Act (CCPA). We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
Collection of Personal Information
In the preceding 12 months, we have collected the following Personal Information for California Consumers accessing the ACA websites, using ACA services, or contacting ACA:
|Categories of consumer’s Personal Information collected
|Business or commercial purposes for which the information was collected
|Categories of sources from which that information was collected
|Categories of third parties with whom the business shares personal information
|Real Name, Email, Phone Number.
|• When you contact us using our webform.
|This information is collected directly from you.
|Affiliates, analytics providers, service providers, and IT vendors.
|Internet or Electronic Network Activity Information
information regarding a consumer’s interaction with an Internet Web site, application, or advertisement,
internet Protocol address, device ID,
cookies, beacons, pixel tags, mobile ad Identifiers.
|• Provide you with targeted advertising based on your activity on our sites.
• Operate, understand, optimize, develop, or improve our sites, applications, products, services and operations.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Investigate and prevent activities that may violate our policies.
|We collect your internet or other electronic network activity information from your interactions with our website.
|Affiliates, analytics providers, service providers, and IT vendors.
Third Parties with whom Personal Information is Shared or Sold: We do not sell your Personal Information to third parties for money. However, our use of certain analytical and tracking tools may constitute the sale or sharing of information under the CCPA. For the purposes of this section, “share” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal data by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged.
In the preceding 12 months, we have not knowingly sold or shared Personal Information about California consumers under 16 years of age.
Right to Know About Personal Information Collected, Disclosed, Sold or Shared
You have the right to request that ACA disclose the Personal Information it collects, uses, and discloses about you to third parties. There are two types of Right to Know requests you can make:
This information will be provided to you free of charge, unless ACA determines that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.
Right of Deletion
You have the right to request that ACA and our service providers delete any Personal Information about yourself that ACA has collected from you upon receipt of a verifiable request. This right is subject to exceptions.
Right to Correct
You have the right to request that ACA and our service providers correct any inaccurate Personal Information about yourself that ACA has collected from you upon receipt of a verifiable request. This right is subject to exceptions.
Right to Opt-Out of the Sale or Sharing of Personal Information
As noted above under “Third Parties with whom Personal Information Is Shared or Sold,” we do not sell your Personal Information to third parties for money. However, the use of certain analytical and tracking tools may constitute the sale or sharing of information under the CCPA. You have the right to opt-out of the sale or sharing of your Personal Information by clicking on the following link entitled “Do Not Sell or Share My Personal Information.”
Right to Limit Use and Disclosure of Sensitive Personal Information
You have the right to request that ACA limit the use and disclosure of your Sensitive Personal Information to only those purposes specifically authorized under California law. At this time, we do not process or disclose your Sensitive Personal Information for purposes that are not specifically authorized under California law. Should this change, we will notify you and provide you with an opportunity to limit our processing of your Sensitive Personal Information.
You can submit your request to know, delete, or correct Personal Information by calling us toll-free at 866-544-3430. You may also submit a request through a webform available by emailing us at [email protected].
ACA provides California Consumers with the ability to submit requests through our request website, our telephone number, and our email address. ACA must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to three pieces of Personal Information about you when you make a request to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. ACA reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.
You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, ACA requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with ACA. Failure to do so may result in ACA denying your request.
Right to Equal Service
ACA will not discriminate against you because you exercised any of your rights, including, but not limited to, by:
We recognize the Global Privacy Control. Your browser must be able to support the Global Privacy Control for us to recognize your opt-out preference signal.
Your California Privacy Rights, Shine the Light: If you are a California resident, California law permits you to request certain information regarding the disclosure of your personal information by us and our related companies to third parties for the third parties’ direct marketing purposes. To make such a request, please send your request, by email to [email protected].
We do not disclose your personal information to third parties for the third parties’ direct marketing purposes.