Last updated: February 7, 2023
California consumers can find specific disclosures, including “Notice at Collection” details, by clicking here.
- Information Collected or Received from You
- How We Use Personal Information
- Information that We Share with Third Parties
- California Privacy Rights
- Nevada Privacy Rights
- Your Choices
- The Security of Your Information
- Data Transfers
- Retention of Your Information
- Our Policy Toward Children
- Contact Us
2. Information Collected or Received from You
When you use the Services, we may collect Personal Information and other information from you as further described below.
Albert Account Information
If you create an Albert Account, we’ll collect certain information that can be used to identify you, such as your name, email address, postal address and phone number. For compliance purposes, and in order to provide the Services to you, we may also collect your social security number, date of birth, and annual income.
Bank Account Information
We may collect Personal Information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
For compliance purposes and in order to provide the Services to you, we may obtain information from you or a third party, including the financial institution providing your Bank Account, to help us to verify your identity or Bank Account details. For example, we may ask you to provide a copy of your government-issued photo ID, a copy of a utility bill or bank statement, or such other documentation that contains Personal Information.
In order to determine your eligibility to access certain Services, we’ll need to collect Bank Account information and other Personal Information as required by United States Federal law such as citizenship, employment and residence information, and social security number.
Genius Protect Subscription
If you subscribe to our Genius Protect service, we may collect additional identifiers and credit-related information, such as your government-issued identification number, medical identification number, credit history, and/or credit/debit card information, in order to provide the Services to you. If you choose to use the Full-Service Identity Restoration feature, we, or our service providers acting on our behalf, may ask you to provide us a limited power of attorney so we can act on your behalf to investigate alerts, dispute fraudulent events, and return you to a pre-theft status.
Your Communications with Us
We may collect Personal Information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or referral program, request customer or technical support, apply for a job, or otherwise communicate with us.
We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.
We and others who use our Services may collect Personal Information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services (referred to herein as “User Content”) will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
Sweepstakes or Contests
We may collect Personal Information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
Conferences, Trade Shows, and Other Events
We may collect Personal Information from individuals when we attend conferences, trade shows, and other events.
Business Development and Strategic Partnerships
We may collect Personal Information from individuals and third parties to assess and pursue potential business opportunities.
We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications, as described in the relevant privacy notice posted with the job opening.
Information Collected Using Cookies and other Web Technologies
Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information in order to help improve our Services and provide you with a more convenient and customized experience.
“Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
See “Your Choices” below to understand your choices regarding these Technologies.
Information Related to Use of the Services
Our servers automatically record certain information about how our users (each, a “User”) use our Services (we refer to this information as “Log Data”). Log Data may include information such as a User’s Internet Protocol (IP) address, user settings, browser type, operating system, device identifiers, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences.
We may use third party data collection tools to provide us with analytics data regarding Users’ interactions with our Services, including:
- Mixpanel. You may opt-out of Mixpanel’s automatic retention of data collected while using the Services by visiting https://mixpanel.com/optout/. To track opt-outs, Mixpanel uses a persistent opt-out cookie placed on your device.
- Facebook. For more information, please visit Facebook’s Data Policy. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address while logged into your Facebook account: https://www.facebook.com/settings?tab=ads
Information Sent by or Collected From Your Mobile Device
We collect certain information that your mobile device sends when you use our Services. For example, we may collect a device identifier, user settings and the operating system of your device, as well as information about your use of our Services. With your consent we may access, collect, and store the names, phone numbers, and email addresses associated with your phone contacts.
When you use our App, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.
Social Media Platforms
To verify your identity, and if you consent, we may engage third party vendors that collect facial geometry information from a selfie you submit to determine whether it matches your photo from a government-issued form of identification. We do not directly collect or store any biometric information entered through our Services, but we may receive information associated with your identity verification. We do not receive or store your facial geometry and only receive a verification from our vendor of whether the selfie and government identification photos match.
Information Collected from Other Sources
We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings. When you give your consent to obtain your credit score or when you sign up for the Protect service, we may also obtain your credit history from consumer reporting agencies.
3. How We Use Personal Information
Our primary goal in collecting Personal Information is to provide you a secure, smooth, and customized experience. We use your Personal Information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
Provide Our Services
We use your information to fulfill our contract with you and provide you with our Services, such as:
- Managing your information and accounts;
- Providing access to certain areas, functionalities, and features of our Services;
- Answering requests for customer or technical support;
- Communicating with you about your account, activities on our Services, and policy changes;
- Processing your financial information and other payment methods for products or Services purchased;
- Processing applications if you apply for a job we post on our Services; and
- Allowing you to register for events.
We use your information for various administrative purposes, such as:
- Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measuring interest and engagement in our Services;
- Short-term, transient use, such as contextual customization of ads;
- Improving, upgrading or enhancing our Services;
- Developing new products and Services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities, including requests to exercise your rights under this policy or access our Services;
- Debugging to identify and repair errors with our Services;
- Auditing relating to interactions, transactions and other compliance activities;
- Enforcing our agreements and policies; and
- Complying with our legal obligations.
Marketing and Advertising our Products and Services
In accordance with applicable law, we may use your Personal Information, including your credit history when you request your credit score or enroll in the Protect service, to tailor and provide you with content and advertisements, including offers for additional Services (collectively, the “Albert Content”). We may provide you with such Albert Content as permitted by applicable law.
Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking. Under certain privacy laws, these advertising activities may be considered a “sharing” of personal information for “cross-context behavioral advertising” and/or “targeted advertising.”
Data obtained through the short code program will not be shared with any third parties for their marketing purposes.
If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.
We also use your information for other purposes as requested by you or as permitted by applicable law.
- Consent. We may use Personal Information for other purposes that are clearly disclosed to you at the time you provide Personal Information or with your consent.
- Automated Decision Making. We may engage in automated decision making, including profiling. Albert’s processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as described below.
- De-identified and Aggregated Information. We may use Personal Information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, information about the device from which you access our Services, or other analyses we create.
- Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information to your friends about Albert through our referral program. Our referral program, if you choose to participate, may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. The contact information we collect and store with your consent for the individual you choose in relation to your participation in our referral program will be accessed from your phone contacts. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).
5. California Privacy Rights
Notice at Collection and Use of Personal Information
This Supplemental California Privacy Notice only applies to our processing of Personal Information that is subject to the California Consumer Privacy Act of 2018 (as amended) (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Albert has collected about them, whether Albert disclosed that personal information for a business purpose (e.g., to a service provider), whether Albert “sold” that personal information, and whether Albert “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:
|Category of Personal Information Collected by Albert||Category of Third Parties Information is Disclosed to for a Business Purpose||Category of Personal Information That is Shared|
Protected classification characteristics under California or federal law
Internet or other electronic network activity
Interaction with internet websites, mobile applications, or advertisements
Rough location of person or mobile device derived from Internet Protocol address
Professional or employment-related information
Current or past job history
Inferences drawn from other Personal Information to create a profile about a consumer
|Category of Sensitive Personal Information Collected by Albert||Category of Third Parties Information is Disclosed to for a Business Purpose||Category of Personal Information That is Shared|
Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some Personal Information included in this category may overlap with other categories.
The categories of sources from which we collect Personal Information and our business and commercial purposes for using and disclosing Personal Information are set forth in “Information Collected or Received from You”, “How We Use Personal Information” and “Information that We Share with Third Parties” above, respectively. We will retain personal information in accordance with the time periods set forth in “Retention of Your Information.”
“Sales” and “Sharing” Personal Information under the CCPA
We may “share” your Personal Information, as that term is defined in the CCPA, with advertising networks in order to advertise our services that may be of interest to you.
For purposes of the CCPA, Albert does not “sell” Personal Information.
California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below.
To protect your privacy, we will take the following steps to verify your identity before fulfilling your requests submitted under the CCPA. When you make a request and as part of the verification process, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
Disclosure Regarding Use of Sensitive Personal Information
Albert only uses and discloses sensitive personal information for the following purposes:
- To perform the Services reasonably expected by an average consumer who requests such Services.
- To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
- To resist malicious, deceptive, fraudulent, or illegal actions directed at Albert and to prosecute those responsible for those actions.
- For short-term, transient use.
- To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by Albert, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Albert.
- For purposes that do not infer characteristics about individuals.
Refer-a-Friend and Similar Incentive Programs
As described above in How We Use Personal Information (“Share Content with Friends or Colleagues”), we may offer referral programs or other incentivized data collection programs. For example, we may offer incentives to you such as discounts or promotional items in connection with these programs, wherein with your consent you provide your Personal Information in exchange for a reward, or provide Personal Information regarding your friends or colleagues (such as their name, phone number, email address, etc.) and may receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.) These programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of your data to us depends on how you ultimately use our Services, whereas the value of the referred party’s data to us depends on whether the referred party ultimately becomes a customer and uses our Services. Said value will be reflected in the incentive offered in connection with each program.
Right for minors to remove posted content
Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting us as set forth in Contact Us below or logging into their account and removing the content or information using our self-service tools.
6. Nevada Privacy Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you would like to request that we do not sell your Personal Information going forward, or for any questions, please contact us as set forth in Contact Us below with the subject line “Nevada Do Not Sell Request” and provide us with your name and the email address associated with your account.
7. Your Choices
We offer you choices regarding the collection, use and sharing of your Personal Information. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all of the features of the Services.
Communications and Opt-Out
Cookies and Interest-Based Advertising
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative and the Digital Advertising Alliance.
Please note you must separately opt out in each browser and on each device.
Your Privacy Rights
In accordance with applicable law, you may have the right to:
- Access Personal Information about you, including: (i) confirming whether we are processing your Personal Information; (ii) obtaining access to or a copy of your Personal Information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of Personal Information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the “right of data portability”);
- Request Correction of your Personal Information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your Personal Information;
- Request Deletion of your Personal Information;
- Request Restriction of or Object to our processing of your Personal Information;
- Request to Opt-Out of certain processing activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in profiling in furtherance of certain decisions that produce legal or similarly significant effects concerning you;
- Withdraw your Consent to our processing of your Personal Information; and
- Object to our processing of your personal data in Automated Individual Decision-Making;
- Appeal our decision to decline to process your request.
To exercise any of the rights described above, please submit a request to us by either:
- Visiting Albert Privacy Right Request; or
- Contacting us by e-mailing Albert at firstname.lastname@example.org.
Responding to Do Not Track Signals
Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.
8. The Security of Your Information
We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your Personal Information) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by text, mail or by sending an email to you.
9. Data Transfers
Your Personal Information may be transferred to and maintained on computers located outside of your state or the United States, where the privacy laws may not be as protective as those in your jurisdiction. Please note our Services are currently designed for individuals based in the United States. If you’re located outside the United States while accessing the Services and choose to provide your Personal Information to us, we may transfer your Personal Information to the United States and process it there.
10. Retention of Your Information
11. Our Policy Toward Children
Our Services are not directed to children under 13 and we do not knowingly collect Personal Information from children under 13. If we learn that we have collected Personal Information of a child under 13 we will take steps to delete such information from our files as soon as possible.
13. Contact Us