Last Updated: June 19, 2020
INFORMATION WE COLLECT
Information Provided at Registration
To register for an Account, you must provide your full name, zip code, e-mail address, and mobile phone number and create a unique password for your Account. This User Data is necessary for us to provide Members with the Service, including to provide Benefits based on general geolocation, and to comply with our Terms and Conditions of Use.
Members may browse and view Benefit Providers and Benefits through each Member’s Dashboard. Regardless of membership or association with any Benefit Provider, Members may select and add Benefits Providers and Benefits to their saved list on their Member Dashboards. UMB records these selections so that we can provide you with your saved list each time you log into your Member Dashboard. UMB will never request any of your usernames, passwords, or membership numbers for Benefit Provider and/or Benefit accounts.
Information Collected Automatically
A cookie is a small text file that is stored on a computer for record-keeping purposes. We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. We use session cookies to make it easier for you to navigate the Service and persistent cookies to save your lists and preferences in your Member Dashboard. You can remove persistent cookies by following the directions provided in your Internet browser’s help file. You may disable cookies on your web browser, however, this may cause certain features of the Service to be disabled or not function properly.
Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a computer hard drive, web beacons are embedded invisibly on web pages. UMB and our third party advertising partners use web beacons in conjunction with usage analytics software to help us identify effective content and to otherwise better manage content of the Service. We do not associate any information gathered by web beacons to your Personal Information.
We collect and create de-identified and aggregated information and other non-Personal Information, which does not identify an individual personally (“Non-Personal Information”). You agree that UMB owns, without restriction, all Non-Personal Information and that you have no rights in or to any Non-Personal Information.
USE OF INFORMATION
We use User Data, including Personal Information, to:
- Provide access to and use of the Service or requested content and/or information;
- Enhance functionality of the Service;
- Create a single sign-on for access to Accounts;
- Save preferences and Benefit lists on Member Dashboards;
- Send alerts regarding selected Benefit Providers or Benefits;
- Send notifications based on geographic location;
- Respond to User inquiries;
- Solicit User feedback;
- Provide technical administration and customer support;
- Help us understand who is visiting and using the Service to better serve our Users;
- Enforce our Terms and Conditions;
- Verify User identity and protect against or identify fraudulent transactions;
- Send important notices, such as communications about changes to our terms, conditions, and policies; and
- Contact Users about offers and new services that may be of interest to such Users.
We may also Process User Data for one or more of the following reasons:
- a legitimate business interest, such as providing the Service and providing you with access to and use of the Service;
- performing obligations pursuant to our Terms and Conditions or to take steps at your request prior to entering into our Terms and Conditions;
- compliance with a legal obligation;
- protect the vital interests of any User or other person or entity; and/or
- other specific purposes for which we have obtained consent to Process User Data.
Newsletter and Opt-Out from Communications
If you opt-in to subscribe to our newsletter, we will use your name and e-mail address to send the newsletter to you. You may opt-out of receiving newsletters, offers, and other communications from UMB by clicking on the unsubscribe link set forth in an e-mail from us or by sending an e-mail to email@example.com. Please note that opting-out of receiving future contact from UMB may cause you to lose some or all of the benefits of using the Service or being a Member.
Benefit Provider Partnership and Network Advertising
From time to time, we may partner with Benefit Providers and other third parties for marketing efforts and participate in or use advertising networks, such as third party advertising servers, advertising agencies, technology vendors and research firms. We may use these partnerships and advertising networks for marketing, advertising, and promotional purposes, as well as to serve advertisements to you. UMB does not sell or share any Personal Information for marketing or advertising purposes. Only de-identified and aggregated data and other Non-Personal Information are shared for such purposes.
Because Non-Personal Information cannot be used to personally identify you, you agree we may use such information for any lawful purpose.
DISCLOSURE OF INFORMATION
- Agents, Consultants, and Service Providers. UMB, like many businesses, engages third parties to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, performing analytics, transmitting information, hosting data, and storing information. When we engage a third party to perform a function of this nature, we only provide them with the User Data necessary to perform their specific function. Such third parties are contractually bound to only Process the limited User Data we provide them to perform their specific function at our direction.
- Customer Testimonials. UMB may post customer testimonials on the Website or Mobile Application, which may contain Personal Information. However, we will obtain your consent prior to posting such a testimonial from you.
- Joint Offerings. From time to time, UMB may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly-offered product or service from us, UMB may share information collected in connection with your purchase or expression of interest with our joint promotion partner(s). UMB does not control the use of the information we share with our business partners, and their use of the information will be in accordance with their privacy policies. If you do not wish for your information to be shared in this manner, your sole remedy is to opt not to purchase, or specifically express an interest in, a jointly-offered product or service.
- Legal Requirements. UMB may disclose your User Data if required to do so by applicable law, as we may determine in our sole discretion, or in the good faith belief that such action is necessary to (i) comply with a legal obligation; (ii) protect or defend our rights, interests or property or that of third parties; (iii) prevent, investigate or identify possible wrongdoing in connection with the Service, (iv) act in urgent circumstances to protect the personal safety of Users or the public; or (v) protect against legal liability. Unless restricted by applicable law, we will inform the applicable User of such request before sharing the User Data.
- Non-Personal Information. Because Non-Personal Information cannot be used to personally identify you, we may share such information for any lawful purpose.
STORAGE AND SECURITY
INTERNATIONAL TRANSFER AND STORAGE
If you are visiting or using the Service from outside the United States, please be aware that your information may be transferred to, stored, processed, used and/or disclosed in the United States where our servers are located and our central database is operated. To facilitate UMB’s global operations, UMB may also collect, transfer, and store your information outside of the United States. Please note that the data protection and other laws of the United States may not be as comprehensive as or otherwise differ from those of your country.
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
In some jurisdictions, you may have the right to request: what Personal Information we collect, use, disclose, or store, access to your Personal Information, rectification of inaccurate Personal Information, erasure/deletion of your Personal Information, restriction of the Processing of certain Personal Information, and/or that your Personal Information be transferred. According to the law of certain jurisdictions, you may also have the right to: object to our Processing of your Personal Information, withdraw your consent to our Processing of your Personal Information, opt-out of the sale of your Personal Information and/or not receive discriminatory treatment for the exercise of your applicable privacy rights.
Due to the inherent necessity of Personal Information for the operation of the Service, you understand and agree that the deletion of, or withdrawal of your consent for us to Process, your Personal Information may mean some features of the Service may not function properly or may not be available to you and that any such deficiency in the Service caused by such exercise of your privacy rights is not a result of discriminatory treatment for the exercise of your applicable privacy rights.
To exercise your applicable rights at any time, you can send an e-mail to firstname.lastname@example.org or write us at:
UMB International LLC
Attn: Privacy Officer
777 South Flagler Drive, Suite 500 East
West Palm Beach, Florida, 33401
We may verify the identity of any person who requests to exercise any of the above-listed rights by, as applicable, requesting such person log into the User’s Account, matching information provided by such person with information already maintained by us, or requesting additional information from such person for the sole purpose of identity verification. You may designate an authorized agent to make a request to exercise your applicable privacy rights on your behalf, in which case we will verify your identity and the identity of your authorized agent in one of the manners described above. You understand and agree that UMB, at its sole discretion, may decline to comply with, or require further identity verification of, any request for which UMB cannot adequately verify the identity of the person submitting the request.
If you have a concern about our privacy practices, please contact us using the contact information set forth above, and we will take reasonable steps to address your concern. According to the law of certain jurisdictions, you may also have the right to make a complaint at any time to a supervisory authority in the European Economic Area.
SPECIAL NOTIFICATION FOR CALIFORNIA RESIDENTS, YOUR PRIVACY RIGHTS
Individuals who are residents of California and have provided their personally identifiable information to us may request information regarding our disclosures if any, of their personally identifiable information to third parties for direct marketing purposes. Such requests must be submitted to our Privacy Officer in writing at email@example.com or:
UMB International LLC
Attn: Privacy Officer
777 South Flagler Drive, Suite 500 East
West Palm Beach, Florida, 33401
Such requests must include the reference Request for California Privacy Information in the subject line and in the body of the message and must include the e-mail address or mailing address, as applicable, for us to send our response. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted to us if not submitted pursuant to the terms set forth above.
POLICY REGARDING CHILDREN
The Service is not intended for use by children under the age of 18, and we do not knowingly solicit or collect any information, including Personal Information, from children under the age of 18. UMB does not verify the age of any of our Users. However, by using the Service, you represent to UMB that you are at least 18. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Service, please e-mail us at firstname.lastname@example.org, and we will delete that information from our databases.
CAN-SPAM ACT COMPLIANCE
We are committed to being compliant with the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (“CAN-SPAM Act”). All e-mails you receive from UMB or otherwise through the Service are intended to fully comply with the CAN-SPAM Act. If at any time you would like to unsubscribe from receiving future e-mails, you can e-mail us at email@example.com, and we will promptly remove you from ALL correspondence.
THIRD PARTY LINKS