Last Updated: August 22, 2022
This Notice explains how True Link collects, uses, and discloses personal information relating to California residents covered by the CCPA. Under the CCPA, “Personal Information” is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.
Personal information does not include:
Publicly available information made lawfully available from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.
This CCPA Notice relates to the Company’s collection, use and disclosure of California consumers’ personal information. “Personal information” generally means information that is reasonably capable of being associated with you or your household. In the preceding 12 months, we have collected the following categories of personal information:
including name, Social Security number, address, telephone number, driver’s license or state identification card number, bank account number, or other similar identifiers
including Internet Protocol address, email address, account name, or other similar identifiers
information, including assets owned, sources of assets, products or services purchased, or other purchasing or consuming histories, and securities transactions
including where the True Link Visa Card has been used
including, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement
including inferences about an individual’s preference and characteristics (please note: we do not infer information about protected characteristics)
including in reviews, questions, and comments that are shared in a public forum or in response to surveys
We may have shared any of the categories of personal information listed above in Section 1 with the following third parties for our business purposes:
Card Administrators, Representative Payees, Trustees, Guardians, Conservators and other similarly situated person(s) or entities;
Public Forum participants; and
Special Circumstances Recipients
We do not provide personal information about you to other companies for money. We do share personal information with companies that we work with, including to help us market or advertise to you. Even though we do not provide personal information to these companies for money, California law may characterize our providing the following categories of information we share with companies that provide services to you or to us, such as personalizing your experience with us or helping us to market or advertise our products and services to you, as "sales" of personal information:
Online identifiers, including Internet Protocol address, email address, account name, or any other similar identifiers
Internet or other electronic network activity information, including, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement
These categories of personal information may have been “sold” to the following categories of third parties:
Our marketing partners which may consist of third-party partners who we conduct joint-marketing activities with or who we offer a co-branded service with. Marketing partners also include those entities who maintain a link to our services on their site, or a True Link widget on their site, when you interact with that widget or click from their site to our Services. See the "How to Exercise Your CCPA Rights" section below to request to opt out of such “sales”. True Link does not knowingly "sell" the personal information of minors under 16 years of age without affirmative authorization.
Subject to certain exceptions, the CCPA affords you the following rights with respect to your personal information. It’s worth noting that these rights do not apply to personal information we collect about California consumers who apply for or obtain a financial product and service for personal, family, or household purposes (in other words, information regulated by the Gramm-Leach-Bliley Act). For information about how we collect, disclose and use information relating to these consumers and the choices relating to such information, please refer to our GLBA Notice.
Subject to certain exceptions, you have a right to request that the Company disclose what personal information it collects, uses, discloses, and sells during the preceding 12 months. Subject to exceptions, it includes a request for any or all of the following:
Specific pieces of personal information that the Company has about you;
Categories of personal information the Company has collected about you;
Categories of sources from which your personal information is collected;
Categories of personal information that the Company has sold or disclosed for a business purpose about you;
Categories of third parties to whom your personal information was sold or disclosed for a business purpose; and
The business or commercial purpose for collecting or selling personal information.
Subject to certain exceptions, you have a right to request that the Company delete your personal information that we have collected from you.
You have a right to request that the Company not “sell” your personal information to third parties.
You have a right not to receive discriminatory treatment by the Company for the exercise of the privacy rights conferred by the CCPA.
True Link does not engage in the sale of personal information as contemplated by the CCPA and therefore we do not offer a means to opt-out.
Once you submit a request, we will verify that you are the consumer to which the request pertains by matching your name, email address and physical address with information we maintain. Depending on the type of request you submit, we will attempt to match either two or three of these data points to the information maintained in our systems. If we are unable to verify your request with the data points you provided, we may reach out to you for additional information to verify your request. We may also reach out to you for additional verifying information for requests requiring a higher degree of verification because of the type or sensitivity of the request. In some instances, we may not be able to honor your request, such as when an exception applies or when we cannot verify your identity. All requests for Your Right To Know will be honored within forty-five (45) days of receipt, unless we are unable to process your request in such a time (unless an exception applies) in which case we will provide you an explanation for the delay.
You may designate an authorized agent to submit a request on your behalf. We may require that you provide the authorized agent with written permission to act on your behalf and that you verify your identity directly with us.
If you have a disability that prevents or limits your ability to access this CCPA Notice, please email us at email@example.com or call us at 1-855-244-1209 We will work with you to provide this notice in an alternative format.