CSID® Privacy Policy

Last Updated: August 20, 2020

Summary

Personal Information We Collect

How We Use Personal Information

How We Share Personal Information

Cookies and Tracking Technologies

Choices You Have

How You Can Update Your Personal Information

How We Secure Your Personal Information

Your California Privacy Rights

Changes to This Policy

Contacting Us

Other Important Privacy Information

Summary

CSIdentity Corporation (d/b/a Complete ID) (“we,” “us” and “our”) respects individual privacy and values the confidence of our subscribers. We want you to be familiar with what information we collect about you, how the information is being used and what choices you have regarding the collection and use of the information. The privacy principles that we follow with respect to the collection, use, disclosure and protection of information in the course of providing our products and services are consistent with relevant U.S. federal and state laws.

This Privacy Policy (the “Policy”) applies to and describes our privacy practices and principles in connection with Complete ID subscribers who are Costco members and consumers who access this website. The Policy covers information that we collect directly from you, automatically when you interact with our websites and mobile applications and from third party data sources.

By using our websites, mobile applications and/or our products and services, you consent to the privacy practices described in this Policy. You also agree to obtain annual notices of, and changes to, this Policy electronically by visiting our website.

Personal Information We Collect

Personal information is information about you that identifies you as an individual. The personal information we collect depends on how you interact with us and the products and services that you subscribe to. We collect personal information directly from you through our websites and mobile applications as well as interactions with you over the phone with our customer service (collectively, the “Site”). We also collect personal information from third party data sources.

• Information provided by you when you subscribe for products and services including contact and identity information such as your name, date of birth, postal and e-mail address, phone number and social security number. We also collect your Costco membership number and payment information when you subscribe.
• Information provided by you about your children when enrolling your children in our child identity protection products such as their name, social security number and date of birth.
• Information provided by you when using our products and services such as other e-mail addresses, income, additional phone numbers and financial account information.
• Information you provide us when you contact our customer service
• Information obtained from others on your behalf, including information from our affiliated third parties, such as account balances, payment and credit histories.

How We Use Personal Information

We use personal information:

• To verify your identity, provide you with the products, services and/or features you have requested, administer our relationship with you and to communicate with you.
• To verify your Costco membership and to process payments for the products you have requested.
• If applicable, to verify your children’s identity and provide products, services and/or features you have requested on behalf of your children.

Depending on the information you provide and your products, services and/or features, personal information is used to access and monitor various data sets that you have requested that we monitor and provide you with identity protection services.

We also use personal information for internal business purposes including support, security, fraud prevention, research, development and analysis.

Non-personal information is aggregated, de-identified or any other information that does not reveal your specific identity and may be used for any purpose unless otherwise prohibited by applicable law. This includes information described under “Cookies and Tracking Technologies” unless combined with personal information. If we combine any non-personal information with personal information so that it personally identifies you, the combined information will be treated by us as personal information as long as it is combined.

How We Share Personal Information

As a part of Experian, we share personal information with Experian companies (“affiliates”) for the purposes noted in this Policy. We also share personal information with other non-affiliated third parties as described:

Service Providers: To provide you with the products, services and/or features you request, we will share your personal information with our affiliates and other third parties who perform services on our behalf (“service providers”). We will also share your personal information with service providers for billing, communications, fraud prevention and other business purposes.

Costco: We will share limited personal information, such as your contact information and Costco membership number, with Costco. Costco may use this information for its internal business purposes (such as providing customer service, resolving complaints, and analyzing data or member activity) or for marketing purposes. Please refer to Costco’s privacy policy for more information on Costco’s privacy practices. We do not sell or share your personal information with any other third parties for their promotional use or for their marketing purposes.

Legal: We may share your personal information, as necessary and permitted by law, to comply with a subpoena or other legal process, to protect our rights, protect your safety or the safety of others, investigate fraud or to respond to governmental requests.

Business Transfers: In the event of a merger, acquisition or reorganization of some or all of our assets, we may share and transfer your personal information to an affiliate or a third party.

We may share aggregated and de-identified information with third parties for any purpose.

Cookies and Tracking Technologies

We and our service providers, including analytics and advertising partners, collect information automatically when you access and use the Site which we will store in log files. The types of information collected and how that information is used depends on how you interact with the Site and choices you make including:

• Cookies: A cookie is a small piece of text sent to your browser by a website you visit. The Site collects and uses session and persistent cookies. Session cookies expire when you close your browser and are used to store your preferences and settings. Persistent cookies remain on your hard drive for an extended period of time. Persistent cookies also enable us to track various internal metrics and track and target the interests of our website visitors to enhance their experience on our Site. We may use cookies to determine whether you are already a CompleteID subscriber and share that information with Costco, its marketing partners and/or service providers so they can provide you with relevant information about other Costco products and services.
• Tracking Technologies: In addition to cookies, the Site automatically collects and uses other tracking technologies, including web beacons which are electronic images also called pixel tags or clear gifs. These technologies collect information about your online activities over time and across different websites or online services. The Site also collects your activity on our Site, links that you click on and pages viewed, the URL of the website you came from and emails that you opened or forwarded. That information is used for a variety of purposes including Site administration, performance, custom content and improvements; enabling you to enroll and log-in to the Site; tracking Site usage and user movements; delivering and tailoring interest-based advertising; developing of new products and services and fraud prevention. We and/or our service providers also share the information we collect with third parties for these purposes. We and Costco have access to reports produced by service providers that contain aggregated trends and statistics about website usage on our proprietary platforms.
• Device and Identifiers: The Site collects information about your devices and other identifiers including internet protocol (IP) addresses, browsers, device type identifiers and operating systems. This information will be used to analyze trends, track users’ movements on our site and gather demographic information about the Site’s users as a whole. If you access our website using a mobile device, we also collect information about your mobile device, such as the device ID or another identifier as permitted by the manufacturer.

To learn about the third-party analytics and advertising providers we use on our Site and their privacy practices, please see their privacy notices below:

These providers help us perform advertising-related functions such as measuring the effectiveness of our ads, managing how many times you may see an ad, reporting on the performance of our ads, ensuring services are working correctly and securely, providing aggregate statistics and analytics, improving when and where you may see ads, and/or reducing ad fraud.

Choices You Have

You can use a range of tools to control information collection and use as well as make choices about receiving offers of products and services from us. Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our websites do not currently respond to browser DNT signals. If you no longer desire to use our services, you may close your account by contacting us.

Opt-outs:

• If you do not want us to share your personal information with Costco for Costco’s marketing purposes, you may request to opt-out of this information sharing by contacting us.
• We may send you promotional or marketing e-mail communications containing information about other products and services we or other third parties we partner with. If you no longer wish to receive marketing or promotional e-mails from us, you may opt-out of receiving them by following the instructions included in the e-mail or by contacting us. If you opt-out, we will continue to send you non-promotional e-mails.

Controls for Cookies and Tracking Technologies:

• You can choose to accept or decline cookies. Most web browsers automatically accept cookies by default. If you prefer, you can use your browser settings to reject or delete cookies. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated. And, rejecting or deleting cookies may prevent you from taking full advantage of our website.
• E-mail applications have settings which allow you prevent the automatic downloading of images which will disable web beacons in the email messages you read
• Experian and many other companies participate in the Digital Advertising Alliance (DAA) who provides a simple way to opt out of analytics and interest-based advertising. You can access on the “Ad Choices” link here or opt out through the DAA at http://optout.aboutads.info/
• To manage privacy settings for the third-party analytics and advertising providers we use on our Site:

If you access this Site from other devices or browsers, visit the links from those devices or browsers to ensure your choice applies to the information collected when you use those devices or browsers.

How You Can Update Your Personal Information

If you are Complete ID subscriber and personal information that you provided to us changes, you can correct, update or amend it by making changes to your subscriber profile page. You may also make updates by contacting us.

How We Secure Your Personal Information

We have appropriate physical, technical and organizational measures and tools in place to protect your personal information against the loss, misuse and alteration of information that complies with relevant legal requirements and best practices. When you enter sensitive information (such as a credit card, social security number or login credentials) into the Site, we encrypt the transmission of that information using secure socket layer technology (SSL).

When you provide information through the Site, you should be aware that your information may be transmitted across the Internet and no method of transmission over the Internet is 100% secure. Although we take reasonable security measures to protect your information when we receive it, you also need to ensure you take appropriate steps to protect your information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem as soon as possible by contacting us.

Your California Privacy Rights under the California Consumer Privacy Act (CCPA)

CSIdentity Corporation is a part of Experian. If you are a California consumer and would like to learn about Experian’s approach to privacy under the CCPA, please visit Experian’s California Privacy Rights Policy here.

Changes to This Policy

In the future, we may update this Policy to reflect changes to our information practices. You can determine when this Policy was last updated and the effective date of this Policy by referring to the last revised date. We encourage you to periodically review this page for the latest information on our privacy practices and this Policy.

Contacting Us

If you have questions about this Policy or our privacy practices, please contact us by:

Phone: 855.890.CSID (2743)

E-mail: privacy@csid.com

Mail: CSIdentity Corporation d/b/a Complete ID
Attn: Compliance Department
1501 S. Mopac Exp., Suite 200
Austin, TX 78746

Other Important Privacy Information

Third-Party Websites, Links and Social Media:

The Site may contain links to third-party websites. Once you have used these links to leave our Site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information that you provide while visiting such websites and such websites are not governed by this Policy. You should exercise caution and look at the privacy statement applicable to the website in question.

Our Site also includes social media features, such as the Facebook and Twitter buttons or interactive mini programs that run on our Site. These features 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. These features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the social media provider’s privacy policy.

Children’s Privacy

The Site is not directed to individuals under the age of eighteen (18), and we request that such individuals not provide personal information through the Site. If you are under 18 years of age, you may browse our Site; however, you may not provide personal information to us such as name, address, or email address, and you may not register for, enroll in, and/or make product purchases.

For Former Customers

When you close your account or otherwise cease to be our customer, we may continue to use and share your information as described in this Policy.