Terms & Conditions

THIS AFFILIATE AGREEMENT (the "Agreement"), together with any amendments, are entered into by and between LeadVision Media, LLC DBA RevenueAds ("RevenueAds"), and the applying party submitting the Application For Affiliate Status (the "Affiliate"), also referred to herein jointly as the parties ("Parties", each a "Party"). This Affiliate Agreement supplements all other Campaign Terms subsequently agreed to by the Affiliate.

WHEREAS, RevenueAds and Affiliate desire to provide for the terms and conditions of this Affiliate Agreement as more specifically set forth herein;

THEREFORE, the Parties agree to be legally bound as follows:

1.Definitions.

1.1. "Opt-in" or "Opted-in" means that the consumer has made an active, affirmative choice to receive Ads from the Affiliate.

1.2. "User" means any person using the Internet.

1.3. "Action" means a User's completion of an action (such as a click, sale, lead, or call) defined by the Advertiser or RevenueAds.

1.4. "Network" means the advertising network operated by RevenueAds, which is made up of Affiliates and Advertisers.

1.5. "Advertiser" means the advertiser, merchant or advertising agency providing advertisements to RevenueAds for use by the Affiliate.

1.6. "Ad" means the advertisement in the form of graphics and/or text supplied to RevenueAds for inclusion in the RevenueAds Network and to be made available for Affiliate use.

1.7. "Spam" means unsolicited bulk email where recipients have not agreed in advance to receive Ads.

1.8. "Campaign Terms" means the specific guidelines for each Advertiser campaign as listed in the RevenueAds network.

2.Amendments.

2.1. From time to time, RevenueAds may amend, replace or supplement the Agreement, including but not limited to changing Advertiser payouts, by posting an updated Agreement or Campaign Terms on the RevenueAds website, and it shall be deemed effective immediately unless otherwise noted, and Affiliate will be deemed to have consented to, and agreed to be bound by, the updated Agreement or Campaign Terms. It is the responsibility of the Affiliate to read and keep up to date with the Agreement and Campaign Terms with or without notice of change from RevenueAds.

3.Affiliate Requirements.

3.1. Affiliate is subject to review and may be rejected for any reason, and at any time, by RevenueAds.

3.2. Affiliate must submit valid and correct contact information, including but not limited to name, e-mail address, street address, and telephone number. Affiliate must ensure this information remains up-to-date at all times within the RevenueAds Network. Affiliate must accurately, clearly and completely describe all promotional methods in their descriptions and provide additional information when necessary.

3.3. Affiliate websites must not be associated with or contain any illegal activity, or pornographic, obscene, racist, or hateful content, or deceptive advertising, piracy, libelous or defamatory statements.

3.4. Affiliate websites must not contain any mechanisms that could be downloaded on to a User's computer without the User's explicit knowledge and consent.

3.5. In its sole discretion, if at any time RevenueAds deems the Affiliate's website or advertising activities are contrary to the terms set out in the Agreement, the Affiliate shall be terminated from the Network and shall forfeit any and all commissions and earnings.

4.Affiliate Rules.

4.1. Failure to adhere to the following rules is a violation of the Agreement and will result in immediate termination of the Affiliate from the RevenueAds Network with forfeiture of all monies due to Affiliate.

4.2. Affiliate must not load Advertiser's website within a frameset or iframe unless prior written approval is obtained from RevenueAds.

4.3. Affiliate must not modify the Ads supplied by RevenueAds in any way unless prior written approval is obtained from RevenueAds.

4.4. Affiliate must indicate whether he uses incentive traffic, and only offer incentives to Users to respond to Ads with permission from RevenueAds and the Advertiser as indicated on the Network and Campaign Terms, or in writing. RevenueAds reserves the right to define the term incentive.

4.5. Affiliate must not make misleading or disparaging statements, oral or written, about any Ad, Advertiser or RevenueAds.

4.6. Affiliate must agree to receive periodic communications from RevenueAds. This communication could be in the form of e-mail, instant message, postal mail, telephone or fax.

4.7. Affiliate must not display any Ad in third party newsgroups, social networks, message boards, blogs, link farms, counters, chatrooms or guestbooks without the consent of such third party entity.

4.8. Affiliate must comply with all Campaign Terms as outlined in Ads.

4.9. Affiliates must not use SMS/text messages to deliver Ads to Users. Affiliates may not engage in any form of telemarketing, use automated or pre-recorded telephone calls or deliver any Ads to Users via telephone in any manner.

4.10. Affiliate must not generate any Actions in bad faith or through fraudulent mechanisms. This includes, but is not limited to, generating own Actions using manual or automated processes, misrepresenting product or service offered by Advertisers, deceiving Users into obtaining product or service offered by Advertisers, and encouraging or educating Surfers to cancel any product purchase or service provided by Advertisers.

4.11. Affiliate must not share, lend, lease, sell or transfer their account to any third party unless prior written approval is obtained from RevenueAds.

4.12. Any Affiliate engaged in the distribution of Ads via email must comply with all of the following rules:

4.12.1. Affiliate must distribute Ads only to those recipients who have Opted-in to receive such email from the Affiliate. RevenueAds prohibits the use of Spam. Any use of Spam whatsoever by Affiliate will result in the forfeiture of Affiliate's entire commission for all campaigns, and the termination of the Affiliate's account. Affiliate will also be held liable for any and all damages resulting from a violation of this provision including reasonable court costs.

4.12.2. If requested by RevenueAds, Affiliate must be able within 24 hours of such request, to supply the name, date, time, IP address and URL where the User gave permission to the Affiliate to receive such Ads through e-mail.

4.12.3. Affiliate must ensure each email recipient is provided with a valid opt-out mechanism within each email delivered in order for the recipients to "opt-out" of future mailings from Affiliate.

4.12.4. Affiliate must not use the Advertiser or RevenueAds name (including any abbreviation thereof) in the originating email address line ("From" line) or subject line of any email transmission, unless specific permission is given otherwise.

4.12.5. Affiliate must not use falsified sender information or falsified IP Addresses.

4.12.6. Affiliate must use only pre-approved Advertiser subject lines and from lines as set out in Campaign Terms.

4.12.7. Affiliate must use only legitimate routing information.

4.12.8. Affiliate must use their own tracking links that redirect to the tracking links supplied by RevenueAds.

4.12.9. Affiliate must have a proper privacy policy on their website, and it must be in compliance with all FTC guidelines, rules and regulations in respect to online privacy and shall warrant that email campaigns are conducted in accordance with that privacy policy, and in accordance with any applicable local or international laws.

4.12.10. Affiliate must ensure each email contains Advertiser's unsubscribe mechanism as set out in Campaign Terms.

4.12.11. Affiliate must not send email to any email address or domain contained in an Advertiser's suppression list as set out in Campaign Terms.

4.12.12. Affiliate must ensure each email clearly contains the Affiliate's physical address, which cannot be a PO BOX.

4.12.13. Affiliate must comply with all campaign instructions from RevenueAds and Advertiser as set out in Campaign Terms.

4.12.14. Affiliate must comply with any and all applicable rules, regulations and laws, specified or not within this Agreement, in respect to email distribution and advertising and relating thereto, including the CAN-SPAM Act of 2003.

5.     Advertising Services and Warranties.

5.1. Provided that Affiliate complies with all provisions of this Agreement and Campaign Terms, RevenueAds hereby grants to Affiliate a non-exclusive, limited, revocable license to market, display, perform, copy, transmit, and promote the Ad in connection with its obligations hereunder; and market display, perform, copy, transmit, and promote the Ad to third parties in connection with its obligations hereunder. Affiliate's use of Ads or copyrighted materials in violation of this Agreement is strictly forbidden and will result in this limited license being immediately withdrawn and may further result in the termination of the Affiliate's account and being held liable under applicable law.

5.2. RevenueAds's sole obligation to the Affiliate under this Agreement with respect to Ads shall be to provide such Ads for use in their advertising efforts. The advertising services provided by RevenueAds are provided "as is". RevenueAds makes no warranties, guaranties, promises, or estimates, expressed or implied, oral, written or otherwise except as specifically set forth herein, AND does not guarantee, including but not limited to, demographic profiling of Users, click to Action conversion rates, response rates or conversion rates from Action to sale.

5.3. No additional warranties are provided.

6.     Commission Earnings and Payments.

6.1. RevenueAds shall send Affiliate's commission payment approximately fifteen (15) days from the last business day of each month in which earnings are accrued if the amount due to Affiliate exceeds either fifty (50) dollars USD or the minimum payment amount requested by the affiliate, whichever is higher. Commissions will only be earned on Actions reported by the Advertiser, and only after RevenueAds receives full payment from the Advertiser. RevenueAds is under no obligation to pay Affiliates for Actions which are not paid by the Advertiser.

6.2. RevenueAds shall increase the payment frequency for Affiliate to weekly, provided Affiliate has received one previous payment from RevenueAds and is setup to receive payments electronically. All other conditions and restrictions for payment as outlined in item 6.1 remain in force for weekly payments. RevenueAds in its sole discretion may disqualify any Affiliate from being eligible for weekly payments.

6.3. In the event of non-payment by an Advertiser, and If RevenueAds elects in its own discretion not to make payment to Affiliate, an Affiliate's recourse for any earned commissions not paid shall be to make a claim against the relevant Advertiser(s), and RevenueAds disclaims any and all liability for such payment.

6.4. RevenueAds or the Advertiser may reverse any Action generated by the Affiliate. Circumstances for Action reversals include but are not limited to duplicate Actions, fraudulently generated Actions, non-payment, Affiliate's failure to comply with the Agreement, invalid or incomplete data, or product returns. Reversals may be applied at any time, including for Actions during a period where payment has already been issued to the Affiliate.

6.5. In the event reversals are applied to Actions for which an Affiliate has already been paid, Affiliate is required to return payment for these Actions to RevenueAds.

7.      Referral Program.

7.1. Affiliate shall earn a 1% referral fee on the commission payments made to any other new Affiliates (excluding bonuses, rewards, additional payouts, Affiliate earnings where the Affiliate is an advertising network, and referral income) who have been referred to RevenueAds using the specified link code. Affiliate shall earn this fee on the commission payments of a referred Affiliate for a period of twelve (12) months after the referred Affiliate joins the RevenueAds Network. Secondary accounts held by Affiliate are excluded from the referral program. RevenueAds reserves the right to terminate an Affiliate referral program, in whole or in part, at any time for any reason, including but not limited to, fraud, questionable activity or breach of the terms set out in the Agreement or Campaign Terms.

8.     Representations and Warranties.

8.1. Each Party represents and warrants they have full corporate right, power, and authority to enter into this Agreement, to grant the rights and licenses granted and to perform the acts required of it.

8.2. Each Party acknowledges that the other Party makes no representations, warranties, or agreements related to the subject matter hereof that are not expressly provided for in this Agreement.

9.     Non-Circumvention.

9.1. Affiliate shall not solicit or recruit, directly or indirectly, any Advertiser that is known to Affiliate to be an Advertiser of RevenueAds, for purposes of offering products or services that are competitive with RevenueAds, nor contact such Advertisers for any purpose, during the term of Affiliate's membership in the RevenueAds Network and for the twelve (12) month period following termination of Affiliate's membership in the RevenueAds Network.

10.     Limitation of Liability.

10.1. UNDER NO CIRCUMSTANCES SHALL EITHER PARTY BE LIABLE TO THE OTHER FOR INDIRECT, INCIDENTAL, PUNITIVE, CONSEQUENTIAL, SPECIAL OR EXEMPLARY DAMAGES OR COSTS, DIRECT OR INDIRECT, (EVEN IF SUCH PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES), ARISING FROM AFFILIATE PARTICIPATION IN RevenueAds's NETWORK. RevenueAds SHALL NOT IN ANY EVENT BE LIABLE TO AFFILIATE FOR MORE THAN THE AMOUNT PAID TO AFFILIATE HEREUNDER. NO ACTION, SUIT OR PROCEEDING SHALL BE BROUGHT AGAINST RevenueAds MORE THAN ONE YEAR AFTER THE DATE OF SERVICE.

10.2. Affiliate agrees to not to hold RevenueAds or Advertisers liable for any of the consequences of interruption or service.

11.     Indemnification.

11.1. Affiliate hereto agrees to indemnify and hold harmless RevenueAds, Advertiser, and each if its agents, officers, directors and employees against all liability to third parties resulting from the acts or failure to act of such indemnifying party, or any act of its customers or users. Affiliate is solely responsible for any legal liability arising out of or relating to the Affiliate's website(s), any material to which Users can link through the Affiliate's website(s) and/or any consumer and/or governmental/regulatory complaint arising out of any e-mail campaign or other advertising campaign conducted by Affiliate, including but not limited to any Spam or fraud complaint and/or any complaint relating to failure to have proper permission to conduct such campaign to the consumer.

12.     Confidentiality.

12.1. Affiliate agrees to refrain from disclosing RevenueAds's confidential information or the Advertiser's confidential information (including but not limited to commission rates, conversion rates, email addresses, fees, identities of Advertisers) to any third-party without prior written permission from RevenueAds.

13.     Force Majeure.

13.1. Neither party shall be deemed in default of this Agreement to the extent that performance of its obligations or attempts to cure any breach are delayed or prevented by reason of any act of God, fire, natural disaster, accident, terrorism, riots, acts of government, shortage of materials or supplies, or any other cause beyond the reasonable control of such party; provided, that the party whose performance is affected by any such event gives the other party written notice thereof within three (3) business days of such event or occurrence.

14.     Relationship.

14.1. The Parties to the Agreement are independent non-exclusive contractors. Neither Party will have any right, or authority to enter into any agreement on behalf of, or incur any obligation or liability of, or to otherwise bind the other Party, nor is either party an agent, representative, partner, employee, or joint venture of the other Party.

15.     Remedies.

15.1. RevenueAds reserves the right to withhold payment and take appropriate legal action to cover its damages against any Affiliate that violates the terms of this Agreement or breaches the representations and warranties set forth in this Agreement, or commits fraudulent activity against RevenueAds. Except as otherwise specified, the rights and remedies granted to a Party under the Agreement are cumulative and in addition to, not in lieu of, any other rights and remedies which the Party may possess at law or in equity.

16.     Entire Agreement.

16.1. This Agreement constitutes the entire and only agreement and supersedes any and all prior agreements, whether written, oral, express, or implied, of the Parties with respect to the transactions set forth herein.

17.     Governing Law.

17.1. The rights and obligations of the parties under this Agreement shall be governed by and construed under the laws of Oklahoma in Oklahoma County without reference to conflict of laws principles.

18.     Termination.

18.1. This Agreement may be terminated by either party. This Agreement may be terminated immediately upon notice for your breach of this Agreement.

18.2. An Advertiser may terminate Affiliate from the Advertiser's program for any or no reason.

18.3. Upon termination of this Agreement, any permissions granted under this Agreement will terminate, and Affiliate must immediately remove all Ads and link to Advertiser(s).

19. The General Data Protection Regulation (“GDPR”) is a new, European-wide law which will become fully enforceable on May 25, 2018. This legislation lays out requirements for data collection, storage and usage practice.

19.1 The data effected would be any information related to a natural person or ‘Data Subject’, that can be used to directly or indirectly identify the person within the EU. It can be anything from a name, a photo, an email address, bank details, posts on social networking websites, medical information, or a computer IP address.

19.2 To comply with the GDPR you must meet a number of requirements. These include but without limitation to:

• Only collect information that you need for a specific purpose.
• Seek consent to store the information you hold.
• Keep it secure.
• Allow the subject access to the information on request.
• Comply with a subject’s ‘right to be forgotten’ and erase personal data upon request.

19.3 You must have clear consent on all data collections and data you manage within the EU.

19.4 The request for consent must be given in an intelligible and easily accessible form, with the purpose for data processing attached to that consent – meaning it must be unambiguous. Consent must be clear and distinguishable from other matters and provided in an intelligible and easily accessible form, using clear and plain language. It must be as easy to withdraw consent as it is to give it.

19.5 If you have any data related questions or concerns in regards to the GDPR, please contact our Data Controller at matt@revenueads.com

IN WITNESS WHEREOF, the Parties have caused this Agreement to be duly executed and binding upon Affiliate's submission and RevenueAds's acceptance of Affiliate's properly completed Affiliate network application without need for further action by RevenueAds.

My California Privacy Rights

Last Updated: January 1, 2023

Qualfon Data Services Group, LLC and its parents, subsidiaries and affiliates (collectively, “we,” “us,” “our”) work hard to build and maintain a relationship of trust with you. This California Privacy Notice (the “Privacy Notice”) provides information to California residents only about our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) (“Site”), such as www.qualfon.com and www.mydegree.com,  and any services, transactions, or other engagements you might have with us (collectively, “Services”). We encourage you to read our full Privacy Policy for additional important information about our privacy practices. 

This Privacy Notice does not apply to our collection, use, or disclosure of Personal Information (as defined below) in performing data processing services on behalf of our clients (collectively, “Clients”). This Privacy Notice also does not apply to our collection, use, or disclosure of Personal Information related to job applicants, contractors, employees, or their dependents and beneficiaries.

Privacy Notice Changes

This Privacy Notice is subject to change. We encourage you to review this Privacy Notice frequently for any revisions or amendments. Changes to this Privacy Notice will be posted on this Site and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Site or Services. 

Information We Collect as a Business

Personal Information

We collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

• Identifiers (e.g., name, IP address, record identifier, mailing address, email address, phone number, date of birth, social security number);
• Characteristics of Protected Classifications under California or federal law (e.g., gender, military or veteran status, citizenship/national origin, marital status, age, religion, race, ethnicity, sexual orientation);
• Commercial Information (e.g., property location & characteristics, move date, SIC code, FIPS county name & code, property price, identifying characteristics of seller/purchaser, loan information, mortgage amounts, vehicle characteristics, history of vehicular moving violations, driver’s license history and status, interest in products or services offered by us or third parties);
• Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, information about your interactions with our Site);
• Geolocation Data both approximate (e.g., location of residence) and precise;
• Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information (e.g., call recordings, text message transcripts);
• Professional or Employment-Related Information (e.g., military experience, nursing or other professional licensure, job title, employer);
• Education Information (e.g., highest level of education, high school/GED graduation year, area of education concentration, degree interest);
• Health Information (e.g., insurance information, personal health information, data in explanation of benefits statements);
• Personal Information as Described in Cal. Civ. Code § 1798.80(e) (only to the extent collected in an above category);
• Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (e.g., consumer response models, propensity to purchase models);

The types of Personal Information we collect about you may vary based on how you use the Site and/or Services and your relationship with us.

Some of the personal information listed above may be considered sensitive under California law (“Sensitive Personal Information”). This includes driver’s license, social security number, and other government identification card information, precise geolocation data, race, ethnicity, citizenship, religion, sexual orientation, and health information. Each type of sensitive personal information may overlap with a category of Personal Information listed above.

Business Information

We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business. If such Business Information relates to a business contact person, we will treat it as Personal Information.

Usage Data and Site Activity

We automatically collect information in connection with the actions you take on the Site (“Usage Data”). For example, each time you use the Site, we may automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Site, and the duration of your visits to the Site. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information under the category of Internet or Other Electronic Network Activity Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.

Communication Recordings

We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

How We Use and Disclose Information as a Business

Generally

We use Personal Information for internal purposes, such as to:

• Provide you with the Site and Services;
• Service consumer and business accounts;
• Market products and services to you;
• Perform marketing and other types of analytics;
• Operate information security and anti-fraud programs;
• Perform day-to-day business operations such as accounting, seeking legal advice, pursuing or defending legal claims, maintaining information security and anti-fraud programs, and facilitating business transactions; and
• Respond to governmental and other legal requests.

We may use Sensitive Personal Information as follows:

• Driver’s license, social security number, and other government identification card information – to verify dependents and for processing related to mailings that relate to renewal of governmental identification cards.
• Precise geolocation data – to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling. 
• Race, ethnicity, citizenship – to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling. 
• Information that reveals sexual orientation – to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling.
• Health information – to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling.

We may also use Personal Information and/or Sensitive Personal Information as described to you at the point of collection, with your consent, or as otherwise required or permitted by applicable laws.

From time to time, we may de-identify Personal Information so that it can no longer be reasonably linked, directly or indirectly, with an identifiable person. We may use and disclose de-identified information for any purpose since it is no longer Personal Information. We will not re-identify de-identified information.

Third-Party Disclosures

We may sell or share your Personal Information with other companies who do not provide services to us (“Third Parties”). When we use the word “share” in this Privacy Policy, we mean sharing solely for targeted or cross-context behavioral advertising purposes. In the past twelve months we have sold and shared Personal Information as follows:

We do not knowingly sell or share Personal Information of individuals under the age of 16 to Third Parties.

Right to Opt-Out of the Sale or Sharing of Personal Information

You have the right to request that we do not sell or share your Personal Information to others. Please note that opting out of the sale or sharing of Personal Information will not impact any sale or sharing of your Personal Information that may have occurred prior to the date of your opt-out request. You may submit your request(s) by calling us toll-free at (405) 740-3210 or by using our online submission form

Personal Information Retention

We retain your Personal Information in accordance with our record retention policies which are informed by our legal, regulatory, tax, and/or accounting obligations as well as business needs. The term for which we retain each element of your Personal Information may be longer or shorter than the term we retain other elements, and the term for which we retain your Personal Information may differ from the term for which we retain other people’s Personal Information depending on your relationship with us.

Contact Us

If you have any questions about our privacy practices, please email us at consumerprivacy@qualfon.com or call us at (888) 380-2190. For general questions regarding our Site, Services, or this Privacy Notice, please email us at privacy@qualfon.com, call us at (888) 380-2190 or send us a letter to the following address:

Qualfon
 Attn: Chief Compliance Officer
 13700 Oakland Avenue
 Highland Park, MI 48203

Privacy Policy

Last Updated: January 1, 2023

Qualfon Data Services Group, LLC and its parents, subsidiaries and affiliates (collectively, "we," "us," "our") work hard to build and maintain a relationship of trust with you. This Privacy Policy (the "Privacy Policy") governs our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) ("Site"), such as www.qualfon.com and mydegree.com, and any services, transactions, or other engagements you might have with us (collectively, "Services").

This Privacy Policy explains what information we collect about you, how we use or disclose such information, how to exercise any rights you may have with respect to your Personal Information (including any rights to opt-out of certain uses of your information), and the safeguards we have in place to reduce the risk of unauthorized access and use.

This Privacy Policy does not apply to our collection, use, or disclosure of Personal Information (as defined below) in performing data processing services on behalf of our clients (collectively, "Clients"). This Privacy Policy also does not apply to our collection, use, or disclosure of Personal Information related to job applicants, contractors, employees, or their dependents and beneficiaries.

Please carefully read this Privacy Policy, which is part of our Terms of Use, before using our Site and/or Services. If you do not agree with our Terms of Use and/or this Privacy Policy, you must refrain from using our Site/Services. By accessing or using our Site or Services, you agree to our use of your information consistent with our Terms of Use and this Privacy Policy.

Privacy Policy Changes

This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. Changes to this Privacy Policy will be posted on this Site and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Site or Services. If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change being used in a materially new way, we will provide you notice before using your Personal Information in the new way.

Conflict Between This Policy and Local Laws and Regulations

When federal, state, and local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy. In addition, the specific requirements of this Privacy Policy apply only when local laws and regulations permit.

Information We Collect as a Business

Personal Information

We collect information that personally identifies, relates to, describes, or is capable of being associated with you ("Personal Information"), including:

• Identifiers (e.g., name, IP address, record identifier, mailing address, email address, phone number, date of birth, social security number);
• Characteristics of Protected Classifications under California or federal law (e.g., gender, military or veteran status, citizenship/national origin, marital status, age, religion, race, ethnicity, sexual orientation);
• Commercial Information (e.g., property location & characteristics, move date, SIC code, FIPS county name & code, property price, identifying characteristics of seller/purchaser, loan information, mortgage amounts, vehicle characteristics, history of vehicular moving violations, driver's license history and status, interest in products or services offered by us or third parties);
• Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, information about your interactions with our Site);
• Geolocation Data both approximate (e.g., location of residence) and precise;
• Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information (e.g., call recordings, text message transcripts);
• Professional or Employment-Related Information (e.g., military experience, nursing or other professional licensure, job title, employer);
• Education Information (e.g., highest level of education, high school/GED graduation year, area of education concentration, degree interest);
• Health Information (e.g., insurance information, personal health information, data in explanation of benefits statements);
• Personal Information as Described in Cal. Civ. Code § 1798.80(e) (only to the extent collected in an above category);
• Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (e.g., consumer response models, propensity to purchase models);

The types of Personal Information we collect about you may vary based on how you use the Site and/or Services and your relationship with us.

Some of the personal information listed above may be considered sensitive under relevant privacy laws ("Sensitive Personal Information"). This includes driver's license, social security number, and other government identification card information, precise geolocation data, race, ethnicity, citizenship, religion, sexual orientation, and health information. Each type of sensitive personal information may overlap with a category of Personal Information listed above.

Business Information

We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, "Business Information"). This information is generally not considered Personal Information because it relates to a business. If such Business Information relates to a business contact person, we will treat it as Personal Information.

Usage Data and Site Activity

We automatically collect information in connection with the actions you take on the Site ("Usage Data"). For example, each time you use the Site, we may automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Site, and the duration of your visits to the Site. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information under the category of Internet or Other Electronic Network Activity Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.

Communication Recordings

We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

De-Identified Information

We may de-identify or anonymize Personal Information so that it is no longer capable of being associated with you and therefore is no longer Personal Information. We may use and disclose de-identified or anonymized information without restriction. We will not attempt to re-identify previously de-identified or anonymized information.

How We Collect Information

Voluntary Disclosure

We may ask you to provide us with Personal Information when you communicate with us (online or offline), make a purchase from us, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services or we may not be able to fulfill your requested interaction.

Third-Party Data Sources

We may collect Personal Information from third-party data sources such as data brokerages, marketing/advertising agencies, analytics firms, ad networks, and government agencies.

Cookies & Other Automated Tools

We use cookies (a small text file placed on your computer to identify your computer and browser) and other automated tools such as tracking pixels to improve the experience of the Site and Services, such as saving your preferences from visit to visit to present you with a customized version of the Site. Many web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of the Site may not work as intended if you delete or disable cookies.

We use the following types of cookies:

• Advertising Cookies : Advertising cookies are used to learn more about you and advertise products/services that might interest you.

• Functional Cookies : Functional cookies enable certain features or non-essential functionality on our Site. For example, we might use these cookies to recognize you and remember your preferences or settings when you return to our Site or to provide you a more personalized experience.
• Analytics Cookies : Analytics cookies help us understand how our Site is working and who is visiting our Site. Google Analytics is one tool we use, and you can learn more by reviewing Google's Privacy Policy.

We employ software technology that enables us to track certain aspects of a user's visit to the Site. This technology helps us better manage content on the Site by informing us what content is effective, how consumers engage with the Site, and how consumers arrive at and/or depart from the Site. The software typically uses two methods to track user activity: (1) "tracking pixels" and (2) "clear gifs." Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user's session and Personal Information, if provided by the user.

If you arrive at the Site by "clicking through" from another website, then certain information about you that you provided to that other website, such as the terms you were searching on that led you to the Site, may be transmitted to us and we may use it. You should review the Privacy Policy of any website from which you reached the Site to determine what information was collected by that website and for what purpose(s) you agreed that website could use that information. We may retain information about you provided to us by other websites and will only use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

Targeted and Cross-Context Behavioral Advertising

We may work with third-party advertisers, search providers, ad networks, and out Clients ("Advertisers") to learn more about you and show you ads or other content that we believe would be relevant to you. Advertisers may collect and use information about your use of the Site or Services as well as other websites and services. These companies may use cookies, tracking pixels, and other online tracking technologies to collect and use your information. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users. Our Privacy Policy does not cover any use of information that an Advertiser may collect from you. Advertisements may be shown via the Site or on third-party websites. If you do not want to reduce your targeted advertising, please visit the Digital Advertising Alliance ("DAA") Consumer Choice Page. The DAA website allows you to opt-out of one or more targeted advertising networks. Opt-outs are device and browser specific; therefore, you will need to set your opt-out preferences for each device and browser. Deleting browser cookies can remove your opt-out preferences; however, the DAA offers browser extensions that help preserve the opt-out preferences you set on the DAA's Consumer Choice Page. Please note that opt-outs only apply to interest-based advertising. You may still receive other types of online advertising. Please also see the Additional Consumer Rights section below regarding rights you may have under state laws to opt our of the sharing of Personal Information for targeted or cross-context behavioral advertising purposes.

Information from Advertisements

If you arrive at the Site via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time).

Social Media Widgets

The Site may include social media features, such as the Facebook, YouTube, LinkedIn, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with features are governed by the privacy policies of the companies that provide them. Before you choose to interact with these features, you should review the relevant social media company's privacy policy.

How We Use and Disclose Information as a Business

Generally

We use Personal Information for internal purposes, such as to:

• Provide you with the Site and Services;
• Service consumer and business accounts;
• Market products and services to you;
• Perform marketing and other types of analytics;
• Operate information security and anti-fraud programs;
• Perform day-to-day business operations such as accounting, seeking legal advice, pursuing or defending legal claims, maintaining information security and anti-fraud programs, and facilitating business transactions; and
• Respond to governmental and other legal requests.

We may use Sensitive Personal Information as follows:

• Driver's license, social security number, and other government identification card information - to verify dependents and for processing related to mailings that relate to renewal of governmental identification cards.
• Precise geolocation data - to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling.
• Race, ethnicity, citizenship - to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling.
• Information that reveals sexual orientation - to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling.
• Health information - to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling.

We may also use Personal Information and/or Sensitive Personal Information as described to you at the point of collection, with your consent, or as otherwise required or permitted by applicable laws.

From time to time, we may de-identify Personal Information so that it can no longer be reasonably linked, directly or indirectly, with an identifiable person. We may use and disclose de-identified information for any purpose since it is no longer Personal Information. We will not re-identify de-identified information.

Testimonials

If you provide a testimonial, we may post it publicly on the Site or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.

Service Providers

We may establish a relationship with other businesses to provide services to us which may include corporate affiliates ("Service Providers"), including, but not limited for:

• Payment processing;
• Facilitating marketing and non-marketing communications;
• Marketing design and development;
• Business analytics (both marketing and non-marketing related);
• IT and network administration such as data storage and management, website hosting, and data security;
• Professional services such as legal and accounting;
• Obtaining legal records;
• Collection of accounts; and
• Day-to-day business operations such as courier services, facilities management, and document destruction.

We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.

In the past twelve months we have disclosed each category of Personal Information we collect (listed above) with one or more Service Providers.

Third-Party Disclosures

We may sell or share your Personal Information with other companies who do not provide services to us ("Third Parties"). When we use the word "share" in this Privacy Policy, we mean sharing solely for targeted or cross-context behavioral advertising purposes. In the past twelve months we have sold and shared Personal Information as follows:

We do not knowingly sell or share Personal Information of individuals under the age of 16 to Third Parties.

Additionally, we may disclose Personal Information to Third Parties for a business purpose that does not constitute a sale or sharing of that Personal Information.

For example, we cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas, and national security or law enforcement requests), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.

We may also disclose Personal Information and Usage Data to businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.

In the past twelve months, we have disclosed the following categories of Personal Information to Third Parties for a business purpose that is not a sale or sharing of Personal Information:

If you direct us to disclose your Personal Information to a Third Party, we may, in our sole discretion and in accordance with applicable law, follow your instruction.

Security

We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Site or Services, you do so at your own risk.

Our Websites

Please be aware that third-party websites accessible through the Site or recommended through our Services may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information.

Personal Information Retention

We retain your Personal Information in accordance with our record retention policies which are informed by our legal, regulatory, tax, and/or accounting obligations as well as business needs. The term for which we retain each element of your Personal Information may be longer or shorter than the term we retain other elements, and the term for which we retain your Personal Information may differ from the term for which we retain other people's Personal Information depending on your relationship with us.

Children's Privacy

The Site and Services are not intended for children under the age of 16 and we do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records.

Additional Consumer Rights

If you are a resident of California, Colorado, Connecticut, Utah, or Virginia you have additional rights to access and control your Personal Information Exemptions may apply. We are unable to act upon a request submitted to us relating to Personal Information we process on behalf of a Client unless directed to do so by the Client. If you submit a request related to Personal Information we process on behalf of a Client, we will inform you of the identity of the applicable Client so that you may submit your request directly to them.

Right to Know

You have the right to request twice per 12-month period that we disclose to you certain information about our collection, use, disclosure, and sale of your Personal Information over the past 12 months, including: (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose(s) for which we collected your Personal Information; (iv) the categories of Third Parties with whom we shared your Personal Information; (v) the categories of Third Parties to whom we sold your Personal Information; and (vi) our business or commercial purposes for selling/sharing Personal Information.

We are not permitted to provide access to specific pieces of Personal Information if the Personal Information is sensitive or creates a high risk of potential harm from disclosure to an unauthorized person such as financial information, social security numbers, and driver's license numbers. We will not provide specific pieces of Personal Information unless you expressly request them.

Right to Deletion

You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, or comply with legal obligations.

Right to Correct

You have the right to request that we correct inaccurate Personal Information we maintain about you. After you request to correct inaccurate Personal Information, we will provide instructions explaining how to provide us with optional documentation to support your request. If you provide documentation, we will consider it.

We may decline to correct your Personal Information if we determine based on the totality of the circumstances that your Personal Information on file is more likely than not accurate. We may also decline to correct your Personal Information if we determine that your request is fraudulent or abusive. If your request to correct your Personal Information is denied, you may request that we note in our records and notify any Service Providers and Third Parties to whom we disclosed your allegedly inaccurate Personal Information that its accuracy has been disputed.

We may decide to delete your allegedly inaccurate Personal Information instead of correcting it.

Right to Opt-Out of the Sale or Sharing of Personal Information

You have the right to request that we do not sell or share your Personal Information to others. Please note that opting out of the sale or sharing of Personal Information will not impact any sale or sharing of your Personal Information that may have occurred prior to the date of your opt-out request.

We will recognize browser-based opt-out signals as required by law, specifically Global Privacy Control. If we receive an opt-out signal and are able to identify the consumer to whom the signal relates, we will treat the signal as a request to opt out of the sale or sharing of all Personal Information we have on file for the consumer and disable cookies and other tracking tools placed by Third Parties. If we receive an opt-out signal and are not able to identify the consumer to whom the signal relates, we will treat the signal as a request to opt out limited to the Personal Information we collect from the consumer during the online session during which the signal is present and to disable cookies and other tracking tools placed by Third Parties.

Right to Limit Use of Sensitive Personal Information

If you are a California resident, you have the right to request that we limit the use of your Sensitive Personal Information as defined under California law to only exempt purposes such as to provide the goods and services reasonably expected by the average consumer who requests such goods and services, to prevent fraud, and to verify or maintain the quality or safety of goods or services we provide.

If you are a Connecticut, Colorado, Utah, or Virginia resident, and you make a request to limit the user of your Sensitive Personal Information as defined under your applicable state's law, we will treat that request as a revocation of your consent for us to collect and process your Sensitive Personal Information and will delete your Sensitive Personal Information subject to any exemptions available under applicable law.

Right to Appeal

You have the right to appeal our decision to deny, in full or in part, your exercise of consumer rights by submitting a request to appeal. If we deny your appeal, we will provide you with a written explanation of the reasons for our decision. If you are not satisfied with our explanation for the denial of your appeal, you may contact your state Attorney General to submit a complaint about the appeal results.

Non-Discrimination Notice

We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.

Submitting a Consumer Rights Request

You may submit your request(s) by calling us toll-free at (888) 380-2190 or by using our online submission form

After you submit your request, we may contact you to obtain additional information necessary to verify your identity. For example, we may require you to verify certain information in our files or submit a signed declaration under penalty of perjury verifying your identity. We will not process Right to Know, Deletion, or Correction requests without verifying your identity, so please respond promptly. If you do not timely respond to our requests for information, we may deny your request.

We will process verified Right to Know, Right to Correct, and Right to Deletion requests within 45 days of receipt, subject to any applicable exemptions and extensions permitted by law up to 90 days. If you request access to specific Personal Information and that information creates a high risk of potential harm from disclosure to an unauthorized person, we will withhold that information and replace it with a category identifier. For example, if we withhold a social security number, we will inform you that we have a social security number on file. If you have an online account with us, we will provide the response to your request via the online account, otherwise, we will give you the option to choose between mail and electronic delivery. We will retain a copy of your request for at least two years as required by law.

We will process requests to opt-out of the sale or sharing of Personal Information and to limit our use of Sensitive Personal Information within 15 business days of receipt.

We will process verified Right to Appeal requests within the timeframes established by your state's privacy law, but generally within 45 days of receipt.

Authorized Agents

If you are an authorized agent submitting a request for another California resident, you must provide a written authorization from the consumer (along with proof of your identity) or a copy of a lawful power of attorney. You may provide this documentation via email at consumerprivacy@qualfon.com after submitting the request. We may contact you or the consumer on whose behalf you claim to act to verify your authorization.

Non-Discrimination Notice

We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.

California "Do Not Track" Disclosure

Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user's activity not be tracked. At this time, our Site and Services do not respond to "do not track" signals.

Additional Nevada Consumer Rights

If you are a resident of Nevada, you may have the right to direct us not to sell your Personal Information to Third Parties subject to legal exemptions. You may exercise this right by sending an email to consumerprivacy@qualfon.com with the subject line "Nevada Opt Out." Although Nevada law gives us 60 days to respond to your request, plus an additional 30 days in certain instances, we will strive to respond to your request as soon as reasonably possible. We may request additional information in order to verify your identity or locate your Personal Information prior to acting on your request.

Contact Us

If you have any questions about our privacy practices, please email us at consumerprivacy@qualfon.com or call us at (405) 740-3210. For general questions regarding our Site, Services, or this Privacy Policy, please email us at privacy@qualfon.com, call us at (405) 740-3210 or send us a letter to the following address:

Qualfon
Attn: Chief Compliance Officer
13700 Oakland Avenue
Highland Park, MI 48203