My Secure Advantage®

PRIVACY POLICY

Last Updated on 12/19/2025

My Secure Advantage, Inc. takes data privacy seriously. This privacy policy explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights.

We recommend that you read this privacy policy in full to ensure you are fully informed. To make it easier for you to review the parts of this privacy policy that apply to you, we have divided up the document into sections:

Privacy for employer and sponsor customers (Section 2)
Privacy for our end user customers (Section 3)
Privacy for website visitors (Section 4).

If you have any questions or concerns about our use of your Personal Information, please contact us using the contact information provided at the end of Section 14.

About Us
Privacy for Employer and Sponsor Customers
Privacy for End User Customers
Privacy for Website Visitors
Your Privacy Choices
International Transfers
Children's Privacy
Do Not Track
Cookie Policy
Change of Control
Data Retention
Security Protections
Policy Changes
Contact Information

1. ABOUT US

My Secure Advantage, Inc. operates a variety of websites and financial wellness services (the "Services"). A reference to “My Secure Advantage,” “we,” “us” or the “Company” is a reference to My Secure Advantage and its relevant affiliates involved in the collection, use, sharing, or other processing of Personal Information.

Find out more about our Services at www.mysecureadvantage.com.

This section applies to the Personal Information we collect and process from our customers who are employers or sponsors who obtain our Services for their employees. If you are not an employer or sponsor, the end user customer or website visitors section of this policy may be more applicable to you and your data. In this section, "you" and "your" refer to employer and sponsor customers.

a. Information We Collect

The Personal Information that we may collect broadly falls into the following categories:

Information You Give Us. You may give us information about you. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service, or communicate with us in any other way. The categories of information include:

Identifiers such as real name, address, email address, phone number, company, job title;
Personal information under California Civil Code section 1798.80;
Commercial information such as purchases of the Services;
Geolocation data, such as the approximate location of your device;
Internet or other electronic network activity information, such as IP address and browser type;
Professional or employment-related information such as company name; and,
Inferences drawn from any of the above information categories.

Information We Automatically Collect. Like many website operators, we collect information that your browser sends whenever you visit our website. We use cookies and other tracking technologies to collect some of this information. Learn more in our Cookie Policy.

The categories of information include:

Device information: We collect information about the device and applications you use to access the Services, such as your IP address, your operating system, your location, your browser ID, and other information about your system and connection.
Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services.
Product usage data: We collect usage data about you whenever you interact with our Services, which may include the dates and times you access the Services and your browsing activities (such as what portions of the Services are used). We also collect information regarding the performance of the Services.

We generally collect this information in the aggregate. We do not associate this information with you or your computer, unless you specifically ask us to troubleshoot any technical or security issues you have with using our websites, or we need to investigate a violation of our Terms.

Information We Collect From Third Parties. From time to time, we may obtain information about you from third-party sources, such as public databases, and third-party data providers. We take steps to ensure that such third parties are legally and/or contractually permitted to disclose such information to us.

b. How We Use the Personal Information

We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:

To provide you with the Services, which includes:
- Maintaining and servicing accounts,
- Communicating with you about your account and providing customer support,
- Processing and fulfilling orders and transactions,
- Verifying your information, and,
- Processing payments.
To provide analytics services, such as analyzing customer usage and improving services offered.
To market our products and/or services to you.
Through our website cookies, which you may manage through our cookie banner, to share with third-party marketing platforms (e.g. Google Ads) to provide tailored advertising on our websites and other websites that you may visit.
To analyze website usage and improve the services offered.
For market research, project planning, troubleshooting problems.
For detecting and protecting against security incidents, errors, fraud or other criminal activity, and maintaining the overall quality and safety of our website and services.
To enforce compliance with our Terms and applicable law, and to protect the rights and safety of our customers and third parties, as well as our own. This may include developing tools and algorithms that help us monitor the use of our Services and prevent violations.
To fulfill our legal and financial obligations.

Affiliates and Service Providers. We share your information with our third-party service providers, affiliates, and any subcontractors as required to offer you our products and services. These service providers are under a duty of confidentiality. These entities help us to:

Run, operate, and maintain our website and services through third-party platforms and software tools;
Perform crash analytics;
Run email messaging campaigns;
Perform marketing analytics
Provide measurement services and targeted ads (you can opt out of these services at websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu/);
Provide payment attribution; and,
Provide technical and customer support.

Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) in accordance with their own privacy policy. These external service providers do not share your financial information, like credit card number, with us, but may share limited information with us related to your purchase, like your zip code.

Third Party Links and websites. Our website may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.

Third Party Marketing and Advertising Organizations. Through website cookies, which you may manage through our cookie banner, we share your information with third party marketing and advertising partners, such as Google, to provide tailored advertising on our Sites and other websites that you may visit.

Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your Personal Information to comply with any legal obligation, to enforce or apply our Terms and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

d. Legal Bases for Processing (EEA, UK, and Swiss Residents)

If you are from the European Economic Area, UK, or Switzerland, our legal bases for collecting and using your Personal Information is as follows:

The performance of your contract or to enter into the contract and to take action on your requests.
Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and services, direct marketing to you, and improvement of our services.
Compliance with a mandatory legal obligation. For example, accounting and tax requirements, which are subject to mandatory retention periods. We may also collect your Personal Information to record your requests to exercise your rights and to verify your identity for such requests.
Consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time.
In some limited cases, we may also have a legal obligation to collect Personal Information from you, in response to lawful requests by public authorities, including to meet law enforcement requirements, as described above in “How We Share the Personal Information”.

If you have questions about or need further information concerning the legal bases on which we collect and use your Personal Information, please contact us using the contact details provided in the "Contact Information" section below.

3. PRIVACY FOR END USER CUSTOMERS

This section applies to the Personal Information we collect and process from individuals who maintain a direct relationship with us.

If you are an end user who has signed up to our Services through your plan sponsor (e.g. employer), please note that we act as a processor or service provider to your plan sponsor. We encourage you to refer to your plan sponsor’s privacy policy or employer’s HR department for more information on how your plan sponsor uses and shares your data.

In this section, "you" and "your" refer to our end user customers.

a. Information We Collect

The Personal Information that we may collect broadly falls into the following categories:

Information You Give Us. You may choose to give us information about you directly. You may provide us information in the following ways:

By using our Services or through our platforms.
By contacting our customer service team.
By contacting us directly through a webform, email, social media message, or otherwise submit inquiries through our websites.

The categories of information include:

Identifiers such as real name, address, email address, job title, company, or phone number;
Personal information under California Civil Code section 1798.80;
Commercial information such as your balances and expenses;
Internet or other electronic network activity information;
Geolocation data, such as the approximate location of your device;
Audiovisual information such as call recordings when you use our coaching service;
Professional or employment-related information such as your job title, employer; and
Inferences drawn from any of the above information categories.

Sensitive categories of information include:

National identifiers such as social security number or tax identification information;
Financial account information such as credit card information.
Information We Automatically Collect. Like many website operators, we collect information that your browser sends whenever you visit our website. We use cookies and other tracking technologies to collect some of this information. Learn more in our Cookie Policy.

The categories of information include:

Device information: We collect information about the device and applications you use to access the Services, such as your IP address, your operating system, your location, your browser ID, and other information about your system and connection.
Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services.
Product usage data: We collect usage data about you whenever you interact with our Services, which may include the dates and times you access the Services and your browsing activities (such as what portions of the Services are used). We also collect information regarding the performance of the Services.

We generally use this information in the aggregate to improve our services. We do not associate this information with you or your computer, unless:

You have chosen to sign up for Services that require tracking across websites.
You have asked us to troubleshoot any technical or security issues you have with using our website or application.
We need to investigate a violation of our Terms.

Information We Collect From Third Parties. From time to time, we may obtain information about you from third-party sources, such as public databases, and third-party data resellers. We take steps to ensure that such third parties are legally and contractually permitted to disclose such information to us.

b. How We Use the Personal Information

We may use the Personal Information we collect from end user customers or other sources for a range of reasons, including:

To provide our Services, which includes:
- Maintaining and servicing accounts,.
- Communicating with you about your account and providing customer support,
- Processing and fulfilling orders and transactions,
- Verifying your information, and,
- Processing payments
Through our website cookies, which you may manage through our cookie banner, to share with third-party marketing platforms (e.g. Google Ads) to provide tailored advertising on our websites and other websites that you may visit.
To market our products and/or services to you.
To analyze website usage and improve the services offered.
For market research, project planning, troubleshooting problems.
For detecting and protecting against security incidents, errors, fraud or other criminal activity, and maintaining the overall quality and safety of our website and services.
To enforce compliance with our Terms and applicable law, and to protect the rights and safety of our customers and third parties, as well as our own. This may include developing tools and algorithms that help us monitor the use of our Services and prevent violations.
To fulfill our legal and financial obligations.

Run, operate, and maintain our website and services through third-party platforms and software tools;
Perform crash analytics;
Run email messaging campaigns;
Perform marketing analytics
Provide measurement services and targeted ads (you can opt out of these services at websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu/);
Provide payment attribution; and,
Provide technical and customer support.

Social Media. Our website may include social media buttons or widgets (“social media elements”). These social media elements may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media elements are governed by the privacy policy of the social media company providing the feature and/or widget.

Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your Personal Information in order to comply with any legal obligation, to enforce or apply our Terms and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

Deidentified and Aggregate Data. We may share deidentified and aggregate data with third parties to analyze sales and customer trends. This data cannot be reasonably identified to an individual and is not Personal Information.

d. Legal Bases for Processing (EEA, UK, and Swiss Residents)

If you are from the European Economic Area, UK, or Switzerland, our legal bases for collecting and using your Personal Information is as follows:

The performance of your contract or to enter into the contract and to take action on your requests. For example, the processing of your account registration, providing information on your interactions with our platform.
Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and services, direct marketing to you where you have signed up for Services directly, and improvement of our Services.
Compliance with a mandatory legal obligation. For example, accounting and tax requirements, which are subject to mandatory retention periods. We may also collect your Personal Information to record your requests to exercise your rights and to verify your identity for such requests.
Consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time.
In some limited cases, we may also have a legal obligation to collect Personal Information from you, in response to lawful requests by public authorities, including to meet law enforcement requirements, as described above in “How We Share the Personal Information”.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the "Contact Information" section below.

4. PRIVACY FOR WEBSITE VISITORS

This section applies to Personal Information that we collect and process through our websites and in the usual course of our business, such as in connection with our sales and marketing activities, recruitment, and events. In this section "you" and "your" refers to website visitors.

a. Information We Collect

The Personal Information that we may collect broadly falls into the following categories:

Information You Give Us. If you are a website visitor, you may choose to give us information about you directly. You may provide us information in the following ways:

By contacting us directly through a webform, survey, email, social media message, or by otherwise submitting inquiries through our websites.
By attending our events or other business interactions and providing your contact details.
By entering into our sweepstakes or drawings.
By applying for a role with My Secure Advantage.

The categories of information include:

Identifiers such as name, email address, job title, company, or phone number.
Internet or other electronic network activity information;
Geolocation data, such as the approximate location of your device;
Employment information and job history for individuals who apply for a role with us; and
Inferences drawn from any of the above information categories.

The categories of information include:

Device information: We collect information about the device and applications you use to access the websites, such as your IP address, your operating system, your browser ID, and other information about your system and connection.
Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses.

We generally collect this information in the aggregate to improve the performance of our websites. We do not associate this information with you or your computer, unless we need to investigate a violation of our Terms.

b. How We Use the Personal Information

We may use the Personal Information we collect for a range of reasons, including:

To offer our Services to you.
Through website cookies, which you may manage through our cookie banner, we share your information with third-party marketing platforms (e.g. Google Ads) to provide tailored advertising on our websites and other websites that you may visit.
To market our products and/or services to you.
To analyze website usage and improve the services offered.
For market research, project planning, troubleshooting problems.
For detecting and protecting against security incidents, errors, fraud or other criminal activity, and maintaining the overall quality and safety of our website and services.
To communicate with you about employment opportunities and assess your suitability for an employment role at My Secure Advantage.
To enforce compliance with our Terms and applicable law, and to protect the rights and safety of our customers and third parties, as well as our own. This may include developing tools and algorithms that help us monitor the use of our Services and prevent violations.
To fulfill our legal and financial obligations.

Run, operate, and maintain our website and services through third-party platforms and software tools;
Perform crash analytics;
Run email messaging campaigns;
Perform marketing analytics
Provide measurement services and targeted ads (you can opt out of these services at websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu/);
Provide payment attribution; and,
Provide technical and customer support.

Third Party Links and websites. Our websites may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.

Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your Personal Information in order to comply with any legal obligation, to enforce or apply our Terms and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

d. Legal Bases for Processing (EEA, UK, and Swiss Residents)

If you are from the European Economic Area, UK, or Switzerland, our legal bases for collecting and using your Personal Information is as follows:

Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and services, direct marketing to you, and improvement of our services.
Compliance with a mandatory legal obligation. For example, accounting and tax requirements, which are subject to mandatory retention periods. We may also collect your Personal Information to record your requests to exercise your rights and to verify your identity for such requests.
Consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time.
In some limited cases, we may also have a legal obligation to collect Personal Information from you, in response to lawful requests by public authorities, including to meet law enforcement requirements, as described above in “How Do We Share Personal Information”.

5. YOUR PRIVACY CHOICES

a. General

Marketing Opt-Out. We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send. You will continue to receive service-related messages concerning our Services.

Exercising Your Privacy Rights. We have listed the privacy rights for several jurisdictions below, but we understand you may have additional rights in your jurisdiction. You may contact us directly at any time about exercising your data protection rights. We will consider your request in accordance with applicable laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

Please note that if you access our services through your plan sponsor (e.g. employer), we are the service provider or processor to your plan sponsor, and we will refer your privacy request to your plan sponsor.

b. For Certain U.S. Residents

Third Party Marketing. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information to third parties for the third parties’ direct marketing purposes. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.

Request for Information or Deletion. Residents of certain U.S. states may have the right to know whether we are processing your Personal Information, and in some instances, you may have the right to request that we disclose to you the categories listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information. In responding to this right, we shall provide you:

The categories of Personal Information we collect about you.
The categories of sources from which your Personal Information is collected.
The business or commercial purpose(s) for collecting, selling, sharing, or disclosing your Personal Information, and the categories of Personal Information disclosed for such purpose(s).
The categories of third parties with whom we share your Personal Information.
The categories of Personal Information we have sold, if any, about you and the categories of third parties to whom your Personal Information was sold, by category or categories of Personal Information for each third party to whom the Personal Information was sold.
The specific pieces of Personal Information we have collected about you.

In addition, you may have the right to request we delete your Personal Information.

Request for Correction. Residents of certain U.S. states may have the right to request the correction or rectification of inaccurate information in the resident’s Personal Information.

Request for Portable Data. Residents of certain U.S. states may have the right to receive, in certain circumstances, a portable format of their Personal Information that allows the data to be transmitted to another entity.

Opting Out of Cookies and Sale/Sharing Using Online Tracking Technologies. Our use of online tracking technologies may be considered a “sale” / “sharing” under applicable law. You may opt out of such technologies through our cookie banner or through your browser settings.

California and certain other U.S. state residents may opt out of tracking technologies by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use. Your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us.

Limiting the Use of Sensitive Personal Information. Residents of California have the right to direct us to use or disclose sensitive Personal Information only for providing goods or services, or as otherwise minimally permitted under applicable law. However, we do not use or disclose sensitive Personal Information for any purpose other than providing our goods and services to you, or as otherwise minimally permitted under applicable law.

Automated Processing & Profiling. Residents of certain U.S. states may have the right to opt out of the processing of Personal Information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

Right to Equal Service & Price. You have the right to receive equal service and price, even if you exercise a privacy right.

c. For EEA, UK, and Swiss Individuals

EEA, UK, and Swiss Privacy Rights. If you are from the European Economic Area, the United Kingdom, or Switzerland, you have the right, under certain circumstances, to:

Access your Personal Information;
Correct inaccurate Personal Information;
Request erasure of your Personal Information without undue delay;
Request the restricted processing of your Personal Information;
Request portability of the Personal Information that you have given us; and
To object to the processing of your Personal Information, including the ability to object to automated processing and/or profiling.

If you are from these jurisdictions, you may also have the right to lodge a complaint with a supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry first to us per the “Contact Information” section below.

You may contact us at the contact information below for more information, or to exercise your rights. Please note that if you access our services through your plan sponsor (e.g. employer), we are the service provider or processor to your plan sponsor, and we will refer your privacy request to your plan sponsor.

6. INTERNATIONAL TRANSFERS

Any data that you provide to us may be accessed, shared or processed by our offices, located in the United States, and service providers located in the United States, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract).

This may entail a transfer of your personal information across international borders. The data protection standards may differ and be lower than the standards enforced in your jurisdiction. We maintain appropriate safeguards as required by applicable law for any personal information transferred internationally.

Data Privacy Frameworks & International Transfers of Data. We may transfer information from or about you or your devices to countries other than the country where you are located (including to the United States), which may not have the same data protection laws as your jurisdiction. For more information regarding our compliance with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework to authorize these data transfers, please review the following disclosures.

My Secure Advantage complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF (“UK-U.S. DPF”), and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) (collectively, the “DPF”) as set forth by the US Department of Commerce. My Secure Advantage has certified that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. My Secure Advantage has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles (collectively, the “DPF Principles”), the DPF Principles shall govern. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov.

With respect to personal data received or transferred pursuant to the DPF, My Secure Advantage is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the DPF Principles, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the DPF should direct their query to privacy@mysecureadvantage.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@mysecureadvantage.com.

As explained in this privacy policy, we sometimes provide your information to third parties to perform services on our behalf. If we transfer personal information received under the DPF to a third party, the third party's access, use, and disclosure of the personal data must also be in compliance with our DPF obligations, and we will remain liable under the DPF for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage. We may be required to disclose personal information that we handle under the DPF in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

DPF Complaints Involving Personal Data We Process as a Controller. For EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received or collected as a controller in reliance on the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-U.S. DPF, please first contact us at: privacy@mysecureadvantage.com.

If your DPF-related complaint cannot be resolved through this channel, My Secure Advantage commits to refer unresolved complaints to JAMS DPF Dispute Resolution, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgement of your DPF Principles-related complaint from us, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS DPF Dispute Resolution are provided at no cost to you.

DPF Complaints Involving Human Resources Data We Receive from Customers. For EU, UK, and Swiss individuals with inquiries or complaints concerning human resources data that we process on behalf of our employment customers, please first refer to your employer’s privacy notice and contact them to resolve the issue.

If your DPF complaint cannot be resolved through this channel, My Secure Advantage commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities, the UK Information Commissioner’s Office and the Gibraltar Regulatory Authority, and the Swiss Federal Data Protection and Information Commissioner with regard to unresolved complaints concerning our handling of human resources data received in reliance on the DPF in the context of the employment relationship.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See DPF Annex 1 at https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

7. CHILDREN'S PRIVACY

Our websites are not directed at individuals under the age of 16. We do not knowingly collect personal information from children under 16. If you become aware that a child has provided us with personal information, please contact us using the contact details provided in the “Contact Information” section below. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information.

8. DO NOT TRACK

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

To make our websites and services work properly, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another.

Google Analytics. We use Google Analytics. We use the information we get from Google Analytics only to improve the Sites. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.

You may wish to restrict the use of cookies. Please be aware that some of the features of our website may not function correctly if you disable cookies.

Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:

Personalized Advertising. We also use advertising cookies, such as Google Ads, to deliver tailored advertising on our Sites and other websites that you may visit. You can learn more about how to control advertising cookies by visiting the Network Advertising Initiative’s Consumer Opt-Out link, the DAA’s Consumer Opt-Out link for browsers, or the DAA’s opt-out link for mobile devices. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications and may make the ads you see less relevant to your interests.

10. CHANGE OF CONTROL

Personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change in control. If we sell, merge or transfer any part of the business, part of the sale may include your Personal Information.

11. DATA RETENTION

We may retain your Personal Information for a period of time consistent with the original purpose of collection or as long as required to fulfill our legal obligations. We determine the appropriate retention period for Personal Information on the basis of the amount, nature, and sensitivity of the Personal Information being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Information, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your Personal Information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of or access to such data.

For more information on data retention periods, please contact us by using the information in the “Contact Information” section, below.

12. SECURITY PROTECTIONS

We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information. For example, when possible, we use encryption to transfer and store data. We further limit access to this data using access controls and confidentiality commitments.

However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be reasonable procedures to protect the confidentiality, security, and integrity of personal information obtained through the websites, we cannot ensure or warrant the security of any information you transmit to us.

13. POLICY CHANGES

We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the websites. We encourage you to periodically review this privacy policy to ensure you are familiar with the most current version.