Last updated June 7, 2022
INFORMATION WE COLLECT ABOUT YOU.¶
We will only collect your personal data (“information”) about you in accordance with applicable law. The information we collect depends on the context of your interactions with us and the choices you make, including your own privacy settings and the specific Services you use. Depending on your particular use, we may collect the following categories of information about you:
personal identifiers (such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers); commercial information (such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); internet or other electronic network activity information (e.g., browsing history, search history, operating system details, URI (Uniform Resource Identifier) addresses, the method utilized to submit the request to the server, the country of origin of the request, and information regarding a consumer’s interaction with an internet website, application, or advertisement (such as time spent on a particular page, details about the path followed within a Service); any other information that you communicate to us directly during your communications with us; and inferences drawn from the foregoing.
SOURCES OF INFORMATION.¶
We may collect your information both online (for example, through your use of our websites and products) and offline (for example at events or over the phone) and we may combine information collected from disparate sources.
Most of the information we collect or maintain about you is provided directly by you to us. If you choose to provide us with information about another person, you shall ensure that you have obtained the consent of that person to share their information with us.
For example, we receive and store information you voluntarily enter on our Services or otherwise provide to us (e.g., when you register for and use the Services, when you make payments to us, or submit requests for support to us or when you have a direct communication with us). Such information typically includes personal identifiers, commercial information, protected classification information and professional or educational information. If you do not want to provide us with your information you may decide at any time not to visit our sites, install our apps, or provide information to us directly. However, if you choose not to provide us with certain information, we may not be able to provide certain Services to you.
HOW WE USE YOUR INFORMATION.¶
At all times in accordance with, and solely where permitted by applicable law, we use the information that we collect from you for such purposes as:
communicating with you, facilitating and responding to your requests, operating, improving, and developing our Services, processing your transactions, customizing your experience, providing you with quality assurance and support for our Services, ensuring our own compliance with legal obligations; preventing or investigating fraudulent or inappropriate uses of our Services, and marketing and analytics purposes, including remarketing and behavioral targeting in some instances and as otherwise permitted by applicable law.
We may also use your information as otherwise disclosed to you at the point of the collection of your information. We may also make full use of data that is aggregated, anonymized or not otherwise in a personally identifiable form.
Cookies and related technology. We may use the information collected from cookies and related technologies for the purposes identified above, as well as to analyze trends, administer the website, track users’ movements, gather broad demographic information for aggregate use and to confirm that a particular individual affirmed his/her consent to specific legal terms (e.g. a clickwrap license agreement). From time to time, electronic communications we provide may contain code that enable our database to understand whether the communication was opened and/or what links (if any) you have clicked. We may combine such information with other information we have about you and may use this information to improve your experience with our Services and/or provide customized communications to you.
Marketing opt-outs. Where permitted by applicable law, and with your prior consent where required by applicable law, we may use your information for marketing and to provide you with promotional communications about our products and services. You can unsubscribe from further marketing at any time by selecting the "unsubscribe" link at the end of the various marketing and promotional communications we send you. Please keep in mind that even if you unsubscribe from our marketing communications, we may still contact you for other legitimate reasons (e.g. in relation to an order you placed, an inquiry you made, a membership you undertook, an event for which you registered, a legally required notice, etc.).
WHEN WE SHARE YOUR INFORMATION WITH OTHERS.¶
We may disclose your information to our affiliates, consultants, service providers, and contractors we use to facilitate the Services and our business operations. These parties provide services directly to us upon our instruction such as delivery services, business administration and payment services, fulfillment services, system administration and technical support, advertising support, public relations, media and marketing services, legal services, call-in centers, e-commerce and other web-related services such as web hosting and web monitoring services.
All such parties are under contractual obligations to safeguard your information and are not permitted to use your information for their own purposes.
We may disclose your information if required to do so by law or if we have a good faith belief that disclosure is necessary to (1) comply with the law or, as applicable, to bring or defend against a legal action; (2) respond to governmental and/or law enforcement requests; (3) protect and defend our rights or property; or (4) act in an emergency to protect someone’s safety.
Finally, we may disclose your information if we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider. In such cases, your information may be sold or transferred in connection with the transaction and as permitted by law and/or contract.
INTERNATIONAL TRANSFER OF YOUR INFORMATION.¶
You may be entitled by applicable privacy laws to request more information about the details of international transfers of your information and the security measures taken by us in connection with that transfer. To obtain more information about exercising your rights, please contact us at: email@example.com.
USERS IN SWITZERLAND OR THE EUROPEAN ECONOMIC EEA.¶
If you are in Switzerland or the European Economic Area (EEA), you may have the right to request access to your personal data; request correction of the personal data; request erasure of your personal data; object to processing of your personal data; request the restriction of processing of your personal data or request the transfer of your personal data to another party.
Additionally, you may have the right to file a complaint with your applicable supervisory authority. We may need to request specific information from you to help us confirm your identity and applicable rights. We may, in limited circumstances, refuse to comply with your request or charge you a reasonable fee if your request is clearly unfounded or excessive. In all cases, we will notify you of any fee in advance. Alternatively, we may refuse to comply with the request in such circumstances. To obtain more information about exercising your rights, please contact us at: firstname.lastname@example.org.
Where we are acting as a data controller under applicable privacy laws, we process your personal data only (i) where the processing is in our legitimate interests (which are not overridden by your data protection interests or fundamental rights and freedoms); (ii) in connection with the creation (at your request) or performance of a contract with you; (iii) where such processing is necessary for our compliance with a legal obligation to which we are subject; or (iv) where we have collected your consent to do so.
If you are a California consumer, you may have additional rights under the California Consumer Privacy Act of 2018 (“CCPA”) regarding how we use and share your information, including:
The right to access your information; The right to request further details about how we collect, use, disclose or sell your information; The right to request that we delete your information that we collected from you; The right to opt-out of the sale of your information, if applicable; and The right not to receive discriminatory treatment from us based on your exercising of any other consumer rights under the CCPA.
To make a consumer rights request or to obtain more information about exercising your rights, including how to designate an authorized agent to make a consumer request for you, please contact us at: privacy@CNO.com. Please be advised that upon the receipt of your request, we may ask you to provide additional information so that we can verify your identity and process your request.
For the purposes of the CCPA, we do not sell your personal information, except where you explicitly consent to such sale, in which case we will present you with further information about how your information may be sold and your ability to opt-out of such sale at the time of collection.
SECURITY AND DATA RETENTION.¶
We follow generally accepted industry standards to protect information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, whether in transmission or storage. Please visit the CNO Trust Center to learn more about our security practices.
Although we will exercise reasonable care in providing secure transmission of information between your computer and our servers, we cannot ensure or warrant the security of any information transmitted to us over the Internet and we accept no liability for any unintentional disclosure.
We will retain your information in accordance with applicable law and, unless otherwise provided by applicable law, for no longer than necessary for the purposes for which your information was processed by us. Where there are technical limitations that prevent deletion or anonymization, we will safeguard and limit the use of information as required by applicable law.
The Services are not intended for or directed to children and we do not knowingly collect any information from children under 13 years of age through the Services. If we learn that we have collected information from children under 13, we will promptly take steps to delete such information.
CNO AFFILIATES; PRIMARY BUSINESS ADDRESS.¶
BeOpenIT, San Francisco, CA 94105, United States