PRIVACY POLICY INTRODUCTION

Better Topics and its wholly and majority-owned entities, respect your concerns about privacy. References in this Privacy Policy to “Better Topics”, “we”, “us”, and “our” are references to the entity responsible for the processing of your personal information, which generally is the entity that obtains your personal information.

This Privacy Policy applies to the personal information we obtain through the Better Topics’s properties, including websites, mobile applications and social media pages that reference this Privacy Policy (“Online Channels”); offline collection in connection with sales, marketing, partner and supplier engagement (“Offline Channels”); and third-party sources, including ad networks and lead brokers (collectively, the “Channels”). This Privacy Policy does not apply to personal information obtained through our Careers website, which is subject to the Candidate Privacy Notice available here, or to products and services that post separate privacy policies.

This Privacy Policy describes the types of personal information we obtain through the Channels, how we may use that personal information, with whom we may share it, and how you may exercise your rights regarding our processing of the information. The Privacy Policy also describes the measures we take to safeguard the personal information we obtain and how you can contact us about our privacy practices.

The Online Channels may provide links to other third-party websites and features, or contain third-party cookies, that are not owned or controlled by the Better Topics. We are not responsible for the privacy practices of third parties, which are subject to their respective privacy policies.

PERSONAL INFORMATION WE OBTAIN

We may obtain personal information through the Channels. The types of personal information we may obtain include:

In addition, in connection with our insurance and financial services products, we may obtain government-issued ID numbers and Tax ID numbers, such as US Social Security numbers.

We use third-party web analytics services in connection with the Online Channels, such as Google Analytics, which use cookies and similar technologies to collect data (such as IP addresses) to evaluate the use of and interaction with the Online Channels. (You may learn about Google’s advertising features, including Google Analytics’ currently available opt-out mechanisms, here. To learn more about these and other analytics services and how to opt out, please view our Cookie Notice page, here.)

Please note that providing personal information to us is voluntary on your part. If you choose not to provide us certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of the Online Channels.

COOKIES AND SIMILAR TECHNOLOGIES

Better Topics uses cookies, web beacons and similar technologies on our Online Channels. You may learn more about these technologies in our Cookie Notice page. To view the list of Better Topics and third-party cookies used on the Online Channels and to make choices about those cookies, please visit our Cookie Notice page, here.

HOW WE USE PERSONAL INFORMATION

We may use the personal information we obtain to:

We may combine personal information we obtain through Online Channels with information we obtain through Offline Channels, as well as other information, for the purposes described above. We may anonymize or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we identify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.

Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.

The legal basis for Better Topics processing your personal information as described above will typically be one of the following:

PERSONAL INFORMATION SHARING

We do not sell or otherwise disclose personal information about you except as described here or at the time of collection.

We may share personal information within Better Topics for the purposes described in this Privacy Policy.

We may share personal information with service providers we have retained to perform services on our behalf (such as payment processing, order fulfillment, customer support and data analytics). These service providers are contractually required to safeguard the information provided to them and are restricted from using or disclosing such information except as necessary to perform services on our behalf or to comply with legal requirements.

We may share personal information with our joint marketing partners and other business partners for the purposes described in this Privacy Policy.

We may disclose personal information about you (1) if we are required or permitted to do so by applicable law or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent.

We reserve the right to transfer to relevant third-parties any information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business combination. In such case, we will require the relevant third parties to provide comparable levels of protection as the ones Better Topics provides with respect to the information we share.

DATA TRANSFERS

We may transfer the personal information we collect through the Channels to, and store such data in, other countries, including the U.S., which may have different data protection laws than the country in which the information was provided. If we do so, we will transfer the personal information only for the purposes described in this Privacy Policy. To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information.

YOUR CHOICES

We offer you certain choices in connection with the personal information we obtain about you. To update your preferences, limit the communications you receive from us, or submit a request, please contact us as specified in the How To Contact Us section of this Privacy Policy.

You also may exercise choice over how information about your interests is used by ad networks to deliver you relevant advertising. To learn how to opt out of ad network interest-based advertising in the United States, please visit Digital Advertising Alliance, the Network Advertising Initiative, and TrustArc. In the European Union, please visit European Interactive Digital Advertising Alliance or TrustArc. The Online Channels are not designed to respond to “do not track” signals received from web browsers.

To the extent provided by the law of your jurisdiction, you may have the right to (1) access certain personal information we maintain about you; (2) request that we update, correct, amend, erase or restrict your personal information; or (3) exercise your right to data portability. Where provided by law, you may withdraw consent you previously provided to us or object at any time to the processing of your personal information on legitimate grounds relating to your particular situation, and we will apply your preferences going forward as appropriate. To request to exercise these rights, please contact us as indicated in the How To Contact Us section of this Privacy Policy. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response.

HOW WE PROTECT PERSONAL INFORMATION TRANSMISSION

We maintain administrative, technical and physical safeguards, consistent with legal requirements where the personal information was obtained, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us through the Channels.

RETENTION OF PERSONAL INFORMATION

To the extent permitted by applicable law, we retain personal information we obtain about you as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Privacy Policy or (2) we have another lawful basis, stated in this Privacy Policy or at the point of collection, for retaining that information beyond the period for which it is necessary to serve the original purpose for obtaining the personal information.

CHILDREN’S PERSONAL INFORMATION

The Online Channels are designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13 through the Online Channels. If we become aware that we have collected personal information from a child under the age of 13, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information, please contact us as specified in the How To Contact Us section of this Privacy Policy.

CHANGES TO OUR PRIVACY POLICY

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices. We will indicate at the top of this Privacy Policy when it was most recently updated.

HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy or if you would like us to update information we have about you or your preferences, please contact us by visiting our General Inquiries Form or write to us at:

Better Topics

Attn: Privacy Policy

157 Park Spring Drive, Sheffield, South Yorkshire S2 3QR, GB

Last Updated June 2, 2020