Last Updated: June 19, 2020

UMB is committed to respecting your privacy. We adopted this Privacy Policy to make it easy for you to understand how we collect, use, disclose and store your User Data, which includes Personal Information, in connection with your access to and use of the Service, which includes our Website and Mobile Application. Please read our Terms and Conditions and this Privacy Policy carefully prior to visiting, registering to use or using the Service and/or otherwise submitting information to UMB. If you do not agree with all of the terms and conditions set forth in our Terms and Conditions and this Privacy Policy, you are not authorized to use the Service, and your sole remedy is to stop accessing and using the Service.

Capitalized terms not defined in this Privacy Policy will have the meaning ascribed to such terms in our Terms and Conditions. The Terms and Conditions are hereby incorporated into and made a part of this Privacy Policy.


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.

Benefit-Related Information

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

To generate de-identified and aggregated information and provide functionality for and improve the Service, as well as to comply with our Terms and Conditions, we use cookies, web beacons, and other tracking technologies to automatically collect certain information, including Personal Information.  Information we automatically collect includes, without limitation, internet protocol (IP) addresses, internet browser type, characteristics of your device and software, domain names of your internet service provider, your precise or approximate geographic location as determined by the device you are using, a record of your usage of the Service, the time of your usage, and the domains from which you visit the Service.  

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.  

Non-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.



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 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.  

Non-Personal Information

Because Non-Personal Information cannot be used to personally identify you, you agree we may use such information for any lawful purpose.


UMB does not sell or otherwise share for compensation any Personal Information with third parties. However, in addition to complying with specific share requests by you, set forth below are categories of instances where we may share some or all of your User Data, including Personal Information, with third parties without further notice to you (and you hereby expressly authorize UMB to share your User Data under such circumstances, provided we do so in a manner consistent with this Privacy Policy):

  • Affiliated Companies. We disclose User Data to our subsidiaries and other affiliated companies for the sole purpose of providing and improving the Service.  Our subsidiaries and affiliates are bound to maintain the User Data they may receive from UMB in accordance with this Privacy Policy.
  • 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.
  • Business Transfers. From time to time, we may buy, sell, or reorganize businesses or assets. In the event of an acquisition, sale, merger, reorganization, dissolution, or similar event, User Data may be part of the transferred assets.  You acknowledge and agree that any successor to or acquirer of UMB (or its assets) will continue to have the right to use your User Data and other information in accordance with the terms of this Privacy Policy. In the event the privacy policy of any successor to or acquirer of UMB will apply to your User Data, we will notify you before your User Data is transferred and becomes subject to a different privacy policy.
  • 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.


Subject to this Privacy Policy, and unless you otherwise provide us with specific instructions, we will only store your Personal Information for as long as is necessary to fulfill our Terms and Conditions with you and provide you with the Service, or as otherwise required by law. We have implemented and we routinely update and maintain appropriate administrative, physical, and technical security measures to help protect your User Data from unauthorized access. Some of the safeguards we use to protect your User Data are firewalls and data encryption, information access controls, controlled access to our facilities, and 24/7 monitoring of our systems databases. Specifically, Account passwords are stored as 35-byte hashes using a salted MD5 encryption algorithm. This salted encryption requires both the “salt” keyword and an MD5 decrypter to access the encrypted data. You acknowledge that your acceptance of this Privacy Policy and access to and use of the Service are voluntary and undertaken with full knowledge and awareness that such activities necessarily entail risks, including security breaches, unavailability, loss or corruption of data, and other inherent risks associated with computer software, communications via the Internet, electronic communications and Processing. You should take special care in deciding what information you send or otherwise make available to us, and you should always back up any User Data or Content you send or otherwise make available to us. Except as otherwise required by applicable law, UMB shall not be liable for the storage or loss of any of your User Data or Content.


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.


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 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.


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 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.


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, and we will delete that information from our databases.


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, and we will promptly remove you from ALL correspondence.


Occasionally, at our discretion, we may provide through our Service links to other websites not operated or controlled by us. These third party websites are subject to separate and independent privacy policies. We have no responsibility or liability for the content and activities of these linked websites.  Inclusion of these links to third party websites through our Service does not imply that we endorse or have reviewed the third party websites. Nonetheless, we seek to protect the integrity of our Service and welcome any feedback about these third party websites.  This Privacy Policy also does not apply to information submitted to third parties, regardless if you link to such third party through the Service. Information you provide to or is collected by third parties, which may include location data, contact information and personal information, is governed by the terms and conditions and privacy policies of such third parties, and we encourage you to learn about such terms and conditions and privacy policies prior to accessing third party websites and/or content and disclosing information to such third parties.


This Privacy Policy shall not apply to, and UMB shall not be responsible for, any unsolicited information you provide to us or another. This includes, but is not limited to, information posted to any public areas of the Service, such as bulletin boards, any ideas for new products or modifications to existing products, claim or demand letters, Digital Millennium Copyright Act notices, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, distribute, and exploit such Unsolicited Information without limitation or attribution.  However, if any of your Personal Information is included in any Unsolicited Information we will only Process that Personal Information in compliance with this Privacy Policy and applicable law.


We may amend this Privacy Policy at any time and in our sole discretion. You should review this Privacy Policy for amendments each time you visit or use the Service. For your convenience, we post on the Service the last date this Privacy Policy was updated. If our Privacy Policy is amended, the amended Privacy Policy will take effect immediately for all visitors and users of the Service. Your continued use of the Service following an amendment will evidence your acceptance of the amended Privacy Policy.