WEbsite Notice at Collection

1. Overview

This Notice at Collection explains your rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”) (Cal. Civ. Code § 1798.100 et seq.) and helps you understand how Veteran Benefits Guide (“VBG”) collects and uses your Personal Information in compliance with the CCPA. In this Notice, the terms “Company,” ”us,” “we,” and “our” refer to VBG and its affiliates. “You” refers to users of our website.

2. What Information We Collect

When you use our website and/or submit information through our webform(s), VBG collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”). The following discusses the categories of Personal Information we collected in the last twelve (12) months. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different purposes without first providing you notice.

• Identifiers. We collect your name, email address, telephone number, date of birth, and gender identity when you complete the Get Started webform on our website. If you complete the Contact Us webform on our website, we collect your name, email address, and telephone number. Under California law, Internet Protocol (“IP”) address is also considered to be an identifier; we collect IP addresses from every website visitor.
• Characteristics of protected classifications under state or federal law. We collect your date of birth and veteran/military status information when you complete the Get Started webform on our website.
• Internet or Other Electronic Network Activity Information, such as browsing history, search history, history of interactions with our website, IP address, session statistics, your computer’s or mobile device’s operating system type and version number, manufacturer and model, date and time of your visit, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access and other functional information on website performance (like diagnostics and crash logs).
• Geolocation Data. We collect information regarding the city and country where your device is telling us it is located.
• Marketing information. We collect information regarding your referral sources and the means through which you have visited the website or otherwise interacted with us.

3. How We Use the Information We Collect

We use the Personal Information we collect for the following purposes:

• Providing our Product Offerings.  We use identifiers, internet or other electronic network activity information, characteristics of protected classifications under state or federal law, and marketing information to facilitate the generation of new business opportunities, and to allow clients to contract for and engage us to provide our product offerings to them.
• Transactional Purposes.  We use identifiers to communicate with you and provide you with assistance.
• Business Operations. We use identifiers, internet or other electronic network activity information, and characteristics of protected classifications under state or federal law  for our day-to-day business operations including maintaining records, database administration, reports, compliance, audit, investigative purposes and other ethics and compliance reporting tools, and to support our business operations.
• Maintenance and Improvement of our Website and Systems. We use identifiers and internet or other electronic network activity information to improve our website and systems, provide and maintain functionality on our website and systems, and help us diagnose technical and service problems and administer our website and systems. Maintenance of our systems includes activities such as applying security controls for company systems, providing new system implementations, applying change management processes, and providing I.T. support services.
• Security and Fraud Prevention. We contact identifiers and internet or other electronic network activity information to: (i) protect us, our employees, and our website, premises, assets, systems, products, services and intellectual property, including from fraud, theft, and misconduct; (ii) enforce our policies and terms; (iii) conduct vendor and customer due diligence; and (iv) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business or otherwise interacting with.
• Complying with Legal and Ethical Obligations and Legal Process. We use identifiers and internet or other electronic network activity information to comply with our legal obligations, including responding to requests under the CCPA, reporting requirements and responding to court orders, warrants, or subpoenas, defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.

We do not collect sensitive personal information on our website.

4. Additional Rights Under California Law

You may have certain rights under California law. This may include a right to access, correct, or delete certain Personal Information we collect about you, subject to applicable exceptions. You may also have the right to opt out of processing of personal information for personal data sales.

To exercise your rights, you may email us at compliance@vbg.com, call us toll free at (866) 412-8135, or use the Contact Us webform on our website to submit a request.

Under the CCPA, we are required to tell Californians if we “sell” or “share” information as that term is defined by applicable law. Sell is defined under the law as disclosing personal information to a third party for monetary or other valuable consideration. Share is specifically defined under the law as well. Sharing means sharing personal information with a third party for cross-context behavioral advertising.

While we do not receive compensation from third parties when we disclose personal information to our marketing and analytics vendors, the disclosure of such information may be considered to be a “sale” or “sharing” under the CCPA.

If you interact with the Company in other ways you may have different rights. If you are a client or consumer of VBG, the privacy policy on our website applies to our interactions with you as a customer or consumer.

5. How We Retain Your Personal Information

To the extent permitted by applicable law, VBG will retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to meet any business, legal, accounting, or other reporting requirements or obligations.  We use the following criteria to determine retention periods:

1. how long the information is needed to provide our services and operate our business;
2. whether there are contractual or legal obligations that exist that require us to retain the information for period of time;
3. whether any law, statute, or regulation allows for a specific retention period;
4. whether an individual has agreed to a longer retention period;
5. whether the data is considered to be sensitive data; and
6. what the expectation for retention was at the time the data was provided to us.

6. How You Are Protected Against Discrimination

VBG will not unlawfully discriminate against you for exercising any of your rights under the CCPA.