Data Privacy

Contents

We at Advantus Corporation, including Advantus-owned companies, brands, and websites (referred to as “Advantus,” “we,” “us,” or “our”) recognize the importance of protecting the privacy of certain information collected about our customers and prospective customers (referred to as “Customers,” “you” or “your”). This privacy statement discloses what information we gather, how we use it, and how to correct or change it. At Advantus it is our intention to give you an understanding about how we collect your information and the use we make of it in the course of our business. To that end, Advantus gathers two types of information about Customers: data that Customers provide through optional, voluntary registration on our sites, use of our services, or purchase of our products, including your name, mailing address, email address, telephone number, and, if required to complete a purchase or if you voluntarily add it to your account, your payment/billing information (“Personal Information”); and data Advantus gathers through aggregated tracking, mainly by tallying page views throughout our sites (“De-Identified Data” or “Aggregated Data”). Such information enables us to tailor our content to fit Customers’ needs better and to help our advertisers understand our audience. However, be assured that Advantus will not disclose Personal Information to third parties without your consent, except as may be noted in this Privacy Policy.

How does Advantus collect information?

Site registration, service request, or product purchase:

We collect information by specifically requesting it from you. Generally this occurs when you register at a site or request information or a service. Usually, the Advantus sites and Advantus’s service partners use your information to operate the sites and to deliver services. Advantus sites also use your information to inform you about other products or services available from Advantus and its affiliates. If you make a purchase from one of our sites, then we collect Personal Information to meet our obligation to fulfill your order(s).

Provision of this Personal Information is mandatory in some instances, for example, you need to provide an email address to create a user account and you need to provide several categories of Personal Information to allow Advantus to fulfill an order.

Usage tracking

Use of Internet Protocol (“IP”) Addresses:

An IP address is a unique number that is automatically assigned to your computer whenever you’re surfing the Internet so that your computer can be identified by the main computers, known as “Web servers,” that “serve up” Web pages.
Advantus and/or its affiliates collect IP addresses for the purposes of system administration and to audit the use of our site. When Customers request pages from Advantus’s and/or its affiliates’ sites, our servers log the Customers’ IP addresses. We do not normally link IP addresses to anything personally identifiable, which means that a Customer’s session will be logged, but the Customer will remain anonymous to us. We can and will use IP addresses to identify a Customer when we feel it is necessary to enforce compliance with our site terms of use or terms of service or to protect our service, site, customers or others.

Use Of Cookies:

What are cookies? Cookies are small pieces of information that a Web site sends to yours computer for record-keeping purposes, which information is stored in a file on your computer. Cookies make Web surfing easier for you by saving your preferences so that we can use the saved information to facilitate your use of our Web site when you return to the site. Cookies do not tell us your individual identity unless you have chosen to provide it to us. We never save passwords or credit card information in cookies. The use of cookies is an industry standard, and as such, you’ll find that most major Web sites use them.

By showing how and when Customers use a site, cookies help us see which areas are popular and which are not. Many improvements and updates to the site are based on such data as total number of visitors and pages viewed. This information is most easily tracked with cookies. We use the information from cookies to provide services better tailored to our Customers’ needs.

Most cookies expire after a defined period of time, or you can delete your cookie file at any time. Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or indicate when a cookie is being sent. However, note that some parts of Advantus and/or its affiliates’ services will not function properly or may be considerably slower if you refuse cookies. For example, without cookies, you will not be able to set personalized preferences, and/or may have difficulty completing marketing transactions.

Advantus and/or its affiliates primarily use cookies to track Customers’ Web site usage trends and patterns. This helps us understand our Customers’ needs better and improve areas of Advantus’s and/or its affiliate’s services that our Customers find valuable. While both of these activities depend on the use of cookies, you have the option of disabling the cookies via your browser preferences.

As a general rule Advantus will not disclose any specific Personal Information that you submit to us about you in a manner that connects you with the Personal Information, except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under the circumstances described below. The following describes some of the ways that your Personal Information may be disclosed.

Aggregated Data: Advantus may keep track of what portions of the Web site Customers are visiting and other Customer statistics, and aggregate this information to help us create a better experience for users of our Web site. This is all done without Advantus knowing your name or other Personal Information in order to describe our viewers and services to prospective partners and for other lawful purposes.

Other: Advantus may also disclose Personal Information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating Advantus’s terms of use or terms of service, or may be causing injury to or interference (either intentionally or unintentionally) with any of Advantus’s rights or property, other Advantus Customers, or anyone else. Advantus may disclose or access Personal Information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service, and improve our products and services.

Sales of Personal Information

In the preceding twelve (12) months, Advantus has not sold Personal Information.

Categories of Personal Information Collected or Disclosed

We have collected or disclosed the following categories of Personal Information from consumers within the last twelve (12) months:

Category	Collected	Disclosed
A. Identifiers.	YES	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	YES	YES
C. Protected classification characteristics under California or federal law.	NO	NO
D. Commercial information.	YES	YES
E. Biometric information.	NO	NO
F. Internet or other similar network activity.	YES	YES
G. Geolocation data.	YES	YES
H. Sensory data.	NO	NO
I. Professional or employment-related information.	NO	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	NO	NO
K. Inferences drawn from other personal information.	YES	YES

Sources of Collections:

Advantus obtains the categories of Personal Information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products you purchase.
Indirectly from you. For example, from observing your actions on our websites.
From third-party business partners such as social media sites, ad networks, and analytics providers.

Use and Disclosure of Personal Information:

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

To carry out the business purposes for which you provided the information. For example, to ship an order to you, Advantus may collect your e-mail address and mailing address through a web-based order form and then disclose your mailing address to a third-party carrier such as Federal Express.
To provide, support, personalize, and develop our websites and products
To help maintain the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our websites, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

Employee Privacy

Employee Data Privacy

State Requirements

California

CSC Top 20 can address security mandates that cite “reasonable security procedures”

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (CCPA), enacted in 2018, creates new consumer rights relating to the access to, deletion of, and sharing of personal information that is collected by businesses. Businesses are subject to the CCPA if one or more of the following are true:
o Has gross annual revenues in excess of $25 million;
o Buys, receives, or sells the personal information of 50,000 or more consumers, households, or devices;
o Derives 50 percent or more of annual revenues from selling consumers’ personal information.
As proposed by the draft regulations, businesses that handle the personal information of more than 4 million consumers will have additional obligations.