Last Updated: 12 January 2024

 This California Notice of Collection contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to that law. If you are a California resident, CCPA may apply to our Services as they relate to business products featured on our Site. This California Notice of Collection should be read in conjunction with the 3 Way Privacy Policy and 3 Way Terms of Use, which are incorporated herein by reference.

1. Personal Information We Collect, Disclose for a Business Purpose, and Sell

We collect the categories of personal information about California consumers identified in the table below and use and disclose to third parties this information for business or commercial purposes. In addition, as is common practice among companies that operate online, we allow certain third parties, including non-affiliated business clients, partners, advertising networks, analytics providers, and other advertising providers, to directly collect information about your online activities on the Site and across your browsers and devices using cookies, web beacons, mobile advertising identifiers and other technologies. These third parties may use this information to display online advertisements tailored to your interests and preferences across your browsers and devices, to conduct ad campaign measurement and Site analytics, to detect, prevent and report fraud, or to carry out their own business and commercial purposes. The collection of information by some of these third parties may constitute a “sale” of personal information, as defined under the CCPA.

For more information about these practices, please review Section 3 entitled “Cookies and Similar Technologies” and Section 10 “Your Privacy Rights and Choices” of the 3 Way Privacy Notice [Insert US Privacy Notice Link]. Or, for more information about how to opt out of personal information sharing that constitutes a sale under the CCPA, please refer to the “Your Rights Regarding Personal Information” section below.

Category	Examples		Collected or shared for a business purposes listed below
A. Identifiers	Real name, alias, postal address, email address.		Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Identifiers listed in the preceding category A and subsequent category I, and signature, social security number, telephone number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, or any other financial information, medical information, health information.		Yes
C. Protected classification characteristics under California or federal law.	Age, marital status, medical condition, gender, veteran or military status.		Yes
D. Commercial Information	Products or services purchased, consumer history		Yes
F. Internet or other similar network activity.	Browsing and search history, usage of, and information regarding your use of our applications or website. This information may be used to create anonymous data to help us better understand customer preferences and needs.		Yes
G. Geolocation data.	City and state location of your device, which may include GPS-based, WiFi based, or cell-based location information. You can disable collection of location information by our app at any time in your mobile device settings.		Yes
H. Sensory data.	Audio recordings of calls when you call our customer service, and Internet and electronic network activity, as described above. You are notified at the beginning of a call whether the call is being recorded.		Yes
I. Professional or employment-related information.	Resume and employment application information.		Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)).	Where applicable, education information related to eligibility for employment opportunities.		Yes
K. Inferences drawn from other personal information.	Inferences drawn from (1) the information we collect when you visit our website, use our app, or interact with our tools, widgets or plug-ins, (2) information we collect from reimbursement claims, and (3) information about user preferences and behavior that we collect on our website and mobile app to create a profile about a user reflecting the user’s preferences, characteristics, predispositions, behavior, and abilities.		Yes
L. Sensitive personal information.	Identifiers listed in the preceding category B and precise geolocation, racial and ethnic origin (when hired for a position), the contents of communications where 3 Way is not an intended recipient.		Yes

All personal information listed in the table above may be shared or sold for specific business purposes specific below in Section 3 to those categories of sources also set forth below in Section 2.

2. Categories of Sources

We collect this personal information directly from you.  We may collect your personal information from registered data brokers.  We may also collect personal information about you (for example, information regarding how you interact with our Services) using automated tools as described elsewhere in this California Notice of Collection.

3. Why We Collect, Use, and Share California Information (Business Purposes)

We use and share the personal information we collect for various purposes, including marketing, fraud prevention, legal compliance, and improving our services. We disclose this information to clients, service providers, partners, and others. Additionally, third parties may collect data regarding your online behaviour and use it for personalized advertising and ad campaign measurement.

4. Your Rights Regarding Personal Information

California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

1. For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties.
2. The right to know the categories and specific pieces of personal information we collect, use, disclose and, if applicable, sell about you; the categories of sources from which we collected your personal information; our purposes for collecting or, if applicable, selling your personal information; the categories of your personal information that we have disclosed for a business purpose or, if applicable, sold; and the categories of third parties to whom we have disclosed for a business purpose or, if applicable, sold personal information.
3. The right to request that we delete the personal information we have collected from you.
4. The right to data portability, meaning you have the right to obtain and reuse personal data covered by the CCPA for your own purposes.
5. The right to limit the use of your sensitive personal information to specifically permitted purposes.
6. The right to correct inaccurate personal information we have on you.
7. The right to opt out of our sale(s) or sharing of your personal information.
8. The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

5. Our Retention of Your Personal Information

Unless you specifically ask us to delete your personal information, we retain your personal information as long as it is necessary to comply with our data retention requirements and provide you with the Services you have requested and successfully run our business. However, even if you request a deletion, we may be required to maintain your information for as long as necessary to:

• comply with our legal or regulatory compliance needs (e.g. maintaining records of transactions you have made with us);
• to exercise, establish or defend legal claims; and/or
• to protect against fraudulent or abusive activity on our Services.

This means we may keep different information for different periods. If your account is canceled because you’ve not used it in a long time, we may delete this information straight away.

There may be occasions where we are unable to fully delete, anonymize, or de-identify your information due to technical, legal, regulatory compliance or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate your personal information from any further processing until such time as we are able to delete, anonymize, or de-identify it.

6. How to Exercise Your California Consumer Rights

To Exercise Your Right to Request, Know or Delete

To exercise your California consumer rights to request, know or delete, please submit your CCPA request by sending e-mail to: compliance@supercompare.com.

To Opt Out of Sales or Sharing of Personal Information

To the extent that the third-party information collection on the Site constitutes the sale or sharing of personal information, we provide you with instructions for how you can exercise your right to opt out of certain cookie-related collection and use practices.

On our Site, you can make choices regarding the use of cookies and similar technologies through a cookie banner management tool. On our Site, you can:

1. Visit privacyrights.info to opt out from sales of this type of personal information by third-party businesses that participate in the DAA’s CCPA Opt-Out Tool, and
2. Visit myaccount.google.com/data-and-personalization, scroll down to the “Ad personalization” section, click “Go to ad settings” and toggle “Ad personalization” to OFF, and
3. Follow the instructions in the “Your Ad Choice” section in the 3 Way Privacy Policy to opt out of interest-based advertising and other cookie-related information collection and processing.

To exercise any other CCPA rights, please contact us by using of one of the methods listed above in Section 6 of this California Notice of Collection; when sending us an email, please include “CCPA Request” in the subject line and the relevant right identified in body of your request.

7. Verification Process and Required Information

 

Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide information that we have on record for identity verification purposes. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.