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Privacy Policy
Website Privacy Notice
Last updated August 2022
This privacy notice describes how Acclaris (the "Company", "we", "us", or "our") handles personal information collected through this website and other websites we control that link to this privacy notice (the "Websites"), as well as related to our products and services. Acclaris is an affiliate of Willis Towers Watson which operates worldwide through subsidiary and affiliate companies. A list of the Willis Towers Watson group companies (collectively, "Willis Towers Watson," "we," "us," or "our") can be viewed here. Both Willis Towers Watson and Acclaris are committed to privacy and to transparency in our information practices.
Overview of Our Collection and Use of Personal Information
This overview is intended to summarize key information about our information practices, which are further explained below. (Go directly to full privacy policy.) While the actual information we collect and our use of such personal information varies depending upon the nature of our relationship and interactions, the section below provides a general overview of the categories of personal information we collect and the purposes for which we use such information.
Categories of personal information we collect
Name, contact information and other identifiers : identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.
Customer records: paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, current employment, employment history, social security number, passport number, driver's license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial or payment information, medical information, or health insurance information.
Protected classifications: characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.
Biometric information: physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, faceprint, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. (to the extent permitted and subject to applicable laws)
Usage data: internet or other electronic network activity Information including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an Internet website, application, or advertisement.
Geolocation data: precise geographic location information about a particular individual or device.
Audio, video and other electronic data: audio, electronic, or similar information such as call recordings.
Profiles and inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
Individual rights. Please see the Individual Rights and Choices section below for a description of the choices we provide and the rights you have regarding your personal information. If you are a California resident, please be sure to review the section Additional Information for California Residents below for important information about the categories of personal information we collect and disclose and your rights under California privacy laws.
- Scope
- the use of our websites and associated services that link to this privacy notice, including www.viabenefitsaccounts.com and other websites controlled by Us (the "Websites")
- our former, current and prospective clients
- individuals who communicate with us
- individuals who use our products and services ("Services") and individuals whose personal information we receive in providing the Services
- Cross-border Transfer
- Personal Information Collected
- your name, postal address, email address, phone number, occupation and other contact information
- information regarding your interactions with us and related to your use of our Websites and Services
- interests you have in relation to our Services or our practice areas;
- information you may voluntarily submit to us by completing any form on our Websites
- information about your usage of our Websites and Services
- from any form you may complete and submit through our Websites, for example information collected from the "Contact Us" page of our Websites;
- from the content of surveys that you may complete;
- from 'cookies' and other similar tools deployed on parts of our Websites that can only be accessed by authenticated users who are logged into the Website (for further information regarding cookies used on our Websites, please see Section 6 below)
- when you provide information as a client in connection with us providing professional services to you
- from other sources, such as public databases, joint marketing partners, vendors supporting out operations, including the functioning of our Websites and from other third parties.
- Name, contact information and other identifiers: identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, or other similar identifiers.
- Customer records: paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, social security number, tax ID, insurance policy number, bank account number, debit card number, or any other financial or payment information, medical information, or health insurance information.
- Protected classifications: characteristics of protected classifications under California or federal law such as sex, age, disability, and citizenship status.
- Commercial Information: including products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
- Usage data: internet or other electronic network activity Information including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an application or advertisement.
- Geolocation data: precise geographic location information about a particular individual or device.
- Biometric information: physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including fingerprint, and voice recordings, keystroke patterns or rhythms. (to the extent permitted and subject to applicable laws).
- Audio, video and other electronic data: audio, electronic, or similar information such as, call recordings.
- Profiles and inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
- Purposes and Legal Bases for Processing Personal Information
- Providing support and services: including to provide our Services, operate our Websites, applications and online services; to communicate with you about your access to and use of our Services; to respond to your inquiries; to provide troubleshooting, fulfill your orders and requests, process your payments and provide technical support; and for other customer service and support purposes.
- Analyzing and improving our business: including to better understand how users access and use our Services and Websites, to evaluate and improve our Websites, Services and business operations, and to develop new features, offerings and services; to conduct surveys and other evaluations (such as customer satisfaction surveys); and for other research and analytical purposes.
- Personalizing content and experiences: including to tailor content we send or display on our websites and other Services; to offer location customization and personalized help and instructions; and to otherwise personalize your experiences
- Advertising, marketing and promotional purposes: including to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to send you newsletters, offers or other information we think may interest you; to contact you about our Services or information we think may interest you; and to administer promotions and contests.
- Securing and protecting our business: including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct
- Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties.
- Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.
- Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or law enforcement requests.
- Disclosure of Personal Information
- to third party service providers such as entities providing customer service, email delivery, auditing, hosting our website and other services
- to third parties involved with events that you register for, to facilitate your participation in those events
- if we are obliged to disclose your personal information under applicable law or regulation, which may include laws outside your country of residence
- in order to enforce or apply our Website terms of use, or to protect the rights, privacy, safety or property of Willis Towers Watson, our clients, affiliates or other parties
- subject to applicable laws, to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence
- in connection with the planning, due diligence and implementation of commercial transactions, including a reorganization, merger, sale of all or a portion of our assets, a joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) - in such cases, your personal information will be transferred to the acquiring entity
- in accordance with the separate terms and conditions of use that may apply to you or with your implicit consent.
- Name, contact information and other identifiers
- Customer records
- Protected classifications
- Commercial Information
- Usage data
- Geolocation data
- Biometric information
- Audio, video and other electronic data
- Profiles and inferences
- Cookies and Tracking
- Interest-based Advertising
- Canada: www.youradchoices.ca
- U.S.: www.aboutads.info
- Security
- Individual Rights and Choices
- By contacting us at 1-800-275-9849 (toll free)
- By emailing us at privacy@viabenefits.com
- Retention Period
- Children and Minors
- Changes to our Privacy Notice
- Contact and Comments
- Additional Information for California Residents
This privacy notice describes, generally, how Acclaris handles and processes personal information related to:
Our collection, use and disclosure and processing of personal information about individuals will vary depending upon the circumstances. This privacy notice is intended to describe our overall privacy and data protection practices. In some cases, different or additional notices about our data collection and processing practices may be provided and apply to our processing of certain personal information.
Personal information. In this privacy notice, our use of the term "personal information" includes other similar terms under applicable privacy laws - such as "personal data" and "personally identifiable information". In general, personal information includes any information that identifies, relates to, describes, or is reasonably capable of being associated, linked, or linkable with a particular individual.
Not covered by this notice. This privacy notice does not apply to job applicants and candidates who apply for employment with us through or to our employees and non-employee workers whose personal information is subject to different privacy notices which are provided to such individuals in the context of their employment or working relationship with Acclaris or a Willis Towers Watson group entity.
Websites and specific web pages linked from www.viabenefitsaccounts.com may be subject to separate terms of use (including separate privacy notices). The inclusion of a link to a third-party website does not imply endorsement of the linked site or service by us or our affiliates. These third-party websites will be governed by different terms of use (including privacy notices) and you are solely responsible for viewing and using each such website in accordance with the applicable terms of use. Willis Towers Watson is not responsible for how your personal information is handled by such third-party websites .
The data that we collect from you may be transferred to, accessed, processed or stored in, and subject to requests from law enforcement in, jurisdictions outside of your home jurisdiction, including the United States, the European Union and other jurisdictions, in which we or our service providers operate. Some of these jurisdictions, including the United States, may not provide equivalent levels of data protection as your home jurisdiction. We have established safeguards to protect personal information that is transferred to other countries, including appropriate contractual protections. For more information on the appropriate safeguards in place, please contact us using the details below.
We collect personal information directly from individuals, automatically related to the use of the Services and Websites, and in some cases, from third parties (such as platform providers, payment processors, and operators of certain third-party services that we use). Generally, we collect your personal information on a voluntary basis. However, if you decline to provide certain personal information that is marked mandatory, you may not be able to access certain services or we may be unable to fully respond to your inquiry.
The personal information that we collect and process will vary depending upon the circumstances. For example, the personal information we may collect includes:
We may also collect additional personal information in providing our Services, operating our business, and interacting with individuals in the course of our business, which may at times include "sensitive" information, such as health records. In these instances, we will provide specific data processing information to you regarding how we may process that data and what rights you may have regarding such processing.
Categories of sources of personal information we collect. We may collect personal information directly from you, as well as automatically related to your use of our Websites and other services, as well as from third parties. For example, we collect personal information:
Categories of personal information we collect. While the personal information we collect varies - as explained above - depending upon the nature of the services provided or used and our interactions with individuals, we may collect the following categories of personal information (subject to applicable legal requirements and restrictions):
While the purposes for which we may process personal information will vary depending upon the circumstances, in general we use personal information for the purposes set forth below.
Aggregate and de-identified information. We may de-identify personal information and create anonymous and aggregated data sets and reports in order to assess, improve and develop our business, products and services, prepare benchmarking reports on our industry and for other research, marketing and analytics purposes. Aggregated or de-identified information does not personally identify you or any other user (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).
We disclose the personal information we collect as set forth in this section.
A. Purposes for Which We Disclose Personal Information
Acclaris may disclose your personal information to any Willis Towers Watson group company for the uses and purposes set out above, including for marketing the products and services offered by other businesses across the Willis Towers Watson group (subject to applicable laws). We may also disclose your personal information for the following reasons:
We request those external service providers to implement and apply security safeguards to ensure the privacy and security of your personal information. These third parties have agreed to confidentiality restrictions and to use of any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us.
Aggregate and de-identified information. We may share aggregate or de-identified information, which does not identify and is not linked or linkable to a particular individual, with third parties for research, marketing, analytics and other purposes.
B. Categories of Personal Information Disclosed.
Certain privacy laws (such as the CCPA) require that we disclose the categories of Personal Information that we have disclosed for a business purpose as well as the categories that we have "sold" (as that term is defined under the CCPA or other applicable laws). Please review the descriptions of the categories of personal information under the Personal Information Collected section above, for further descriptions of each category of personal information.
Disclosed for a business purpose. In general, we may disclose the following categories of personal information in support of our business purposes identified above:
Categories of personal information sold. We do not sell Personal Information .
C. Categories Third Parties to whom Personal Information is Disclosed.
As set out above we may disclose Personal Information to other Willis Towers Watson Group Companies, our clients, service providers that support our operations, and cookies providers. Examples of service providers may include companies who assist in fulfilling our contracts and providing customer assistance. For instance, a service provider may be utilized to perform mailings. We also may disclose Personal Information to cookies providers that facilitate the operation of our Websites, by supporting the Websites functionality or providing analytics related to the use of the Websites.
Our Websites may use first party and third-party cookies, pixel tags, plugins and other tools to gather device, usage and browsing information when users visit our Websites or use our online services. For instance, when you visit our Websites, our server may record your IP address (and associated location information) and other information such as the type of your internet browser, your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and the pages you view and links you click on our Websites, as well as date and time stamps associates with your activities on our Websites.
We use the information for security purposes, to facilitate navigation, to personalize and improve your experience while using the Websites, to improve and measure our advertising campaigns and to better reach users with relevant advertising both on our Websites and on third party websites. We also gather statistical information about use of the Websites in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. Our Cookie Notice contains further information about our use of cookies. You can manage how your preferences regarding cookies set by this Website, using our cookie preference manager available in the footer of the linked page.
Cookies. Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of websites, such as time spent on the websites, pages visited, language preferences, and other anonymous traffic data. You can control the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. However, if you select such a setting, this may affect the functioning of our Websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access or log on to our Websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org. For more information about the use of cookies on our Websites and your choices regarding the placement of cookies, please see our Cookie Notice.
Mix Panel: Our Websites use Mix Panel, which uses cookies and similar technologies to collect and analyze information about use of the Websites and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Mix Panel's practices by going to www.mixpanel.com/.
Pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Websites to, among other things,track the actions of users of the Websites (including email recipients),measure the success of our marketing campaigns and compile statistics about usage of the Websites and response rates. We and our service providers also use pixel tags in HTML emails to our customers, to help us track email response rates,identify when our emails are viewed, and track whether our emails are forwarded.
Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version and internet browser type and version. This information is gathered automatically and stored in log files.
Third Party Analytics Tools. Our Websites use automated devices and applications operated by third parties (e.g., Google Analytics), which use cookies and similar technologies to collect and analyze information about use of the Websites and report on activities and trends. Please see our Cookie Notice for more information.
Do-Not-Track signals. Please note that our Websites do not recognize or respond to any signal which your browser might transmit through the so-called "Do Not Track" feature your browser might have. If you wish to disable cookies on our Websites, you should not rely on any "Do Not Track" feature your browser might have. For more information about do-not-track signals, please click here.
On some of our websites, we may work with third-party ad networks, analytics companies, measurement services and others ("third-party ad companies") to display advertising on our Websites and to manage our advertising on third-party sites, mobile apps and online services. We and these third-party ad companies may use cookies, pixels tags and other tools to collect information on our Websites (and on third-party sites and services), such as browsing history, IP address, device ID, cookie and advertising IDs, and other identifiers, general location information and, with your consent, your device's geolocation information; we and these third-party ad companies use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.
You can manage how your preferences regarding third party ad company cookies set by this Website, using our cookie preference manager available in the footer of the linked page.
Please see our Cookie Notice for information about the third parties we may work with to display targeted ads on third-party sites and to measure the success of our marketing and campaigns. You may also obtain more information about targeted or "interest-based advertising" and opt-out of many ad networks at the industry websites below:
We have implemented technical and organizational security measures to protect the personal information we collect. Despite this, the security of the transmission of information via the Internet cannot always be guaranteed and you acknowledge this in your access and use of our Websites. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the "Contact & Comments" section below.
Marketing. You may opt out from receiving marketing-related communications from us on a going-forward basis by contacting us or by using the unsubscribe mechanism contained in each email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.
Individual Rights. Individual rights regarding Personal Information vary depending on which laws apply to you. Some of these rights might be subject to exemptions or limitations under applicable laws. We encourage you to contact us should you have any questions on the specific rights available to you. Please see Additional Information for California Residents for details specific to California residents.
Subject to our obligations under the law, you may request that we confirm processing of or to review, make amendments to, or delete your Personal Information, or otherwise exercise your data privacy rights over Personal Information applicable to you.
In accordance with legal and other permissible considerations, we will make reasonable efforts to honor your request promptly or inform you if we require further information in order to fulfil your request. You may submit a request to us related to your Personal Information in one of the following ways:
Additional information for California residents. Willis Towers Watson is committed to respecting the privacy rights of individuals under all privacy laws applicable to us. If you are a California resident, you have certain rights under California privacy laws regarding your personal information as set forth below in the Additional Information for California Residents section.
We will retain your personal information for the period necessary to fulfill the purposes outlined in this privacy notice unless a longer retention period is required or permitted by law. We may retain personal information for longer where required by our regulatory obligations or professional indemnity obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others. With respect to the data and files we handle as a processor, we retain this personal information in accordance with our clients' instructions.
The Websites and Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from minors under the age of 16. The sole exception to the forgoing is that our services may include collection of dependent information as required by the main account holder's elections, and it is possible such dependents could be under the age of 16.
From time to time, we may change our Privacy Notice. The effective date set forth at the top indicates the last time this Privacy Notice was revised. Checking this effective date allows you to determine whether there have been changes since the last time you reviewed the notice. We will notify you of changes to this privacy notice by posting the revised privacy notice on our Websites.
If you have any questions or comments regarding this privacy notice, please contact our Privacy Team, at 800 North Glebe Road, Arlington, VA 22203 or at privacy@willistowerswatson.com.
This section provides additional information as required by the CCPA regarding our Health Savings Account ("HSA") Administration Services which are classified as a "business" under the CCPA.
In this section, we provide information for California residents as required under California privacy laws, including the California Consumer Privacy Act ("CCPA"), which requires that we provide California residents certain specific information about how handle their personal information, whether collected online or offline. This section does not address or apply to our handling of:
- publicly available information made lawfully available by state or federal governments
- personal information that is subject to an exemption under Section 1798.145(c) - (f) of the CCPA (such as protected health information that is subject to HIPAA or the California Medical Information Act, and non-public information subject to the Gramm-Leach Bliley Act or the California Financial Information Privacy Act)
- personal information we collect about job applicants, independent contractors, or current or former full-time, part-time and temporary employees and staff, officers, directors or owners of Willis Towers Watson
- personal information about individuals when we are acting as a "service provider" for or on behalf of another company, to the extent the information relates to our transactions with such company, products or services that we receive from or provide to such company, or associated communications or transactions
Categories of personal information that we collect and disclose. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The beginning of this document sets forth above sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect and disclose to others for a business purpose. We collect these categories of personal information from the sources described in the Personal information we may collect section above, and for the purposes described in the Purposes for which we use personal information section above.
Rights of California residents. California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.
- Initial Notice: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.
- Request to Delete: California residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law. The instructions for submitting a verifiable Request to Delete are described in the "Submitting Requests" section below.
- Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected, used, disclosed, and sold about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:
- categories of personal information collected;
- categories of sources of personal information;
- business and/or commercial purposes for collecting and selling their personal information;
- categories of third parties with whom we have shared their personal information;
- categories of personal information that we have sold in the preceding 12 months, and for each category identified, the categories of third parties to which we sold that particular category of information; and
- categories of personal information disclosed for a business purpose in the preceding 12 months, and for each category identified, the categories of third parties to which we disclosed that particular category of personal information.
- Right to non-discrimination: The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents' data.
- Financial incentives: A business may offer financial incentives for the collection, sale or deletion of California residents' personal information, where the incentive is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent. We do not offer any such incentives at this time.
- By contacting us at 1-800-275-9849 (toll free)
- By submitting a Consumer request through this link
California residents may make a Request to Know up to twice every 12 months. We will respond to verifiable requests received from California residents as required by law. The instructions for submitting a verifiable Request to Know are described in the "Submitting Requests" section below.
Submitting Requests. Requests to Know, and Requests to Delete may be submitted:
We will use the following process to verify Requests to Know and Requests to Delete: We will acknowledge receipt of your Consumer Request, verify it using processes required by law, then process and respond to your request as required by law. To verify such requests, we may ask you to provide the following information: For a request to know categories of personal information which we collect, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you against information in our systems which are considered reasonably reliable for the purposes of verifying a consumer's identity. For a request to know specific pieces of personal information or for requests to delete, we will verify your identity to a high degree of certainty by matching at least three pieces of personal information provided by you to personal information maintained in our systems and also by obtaining a signed declaration under penalty of perjury that the requestor is the consumer whose personal information is the subject of the request.
An authorized agent can make a CCPA request on a California resident's behalf by providing either: (1) a power of attorney valid under California law; or (2) proof that the consumer gave the agent signed permission to submit the request. The consumer must also provide either: (1) verification of their own identity with respect to a right to know categories, right to know specific pieces of personal information, or requests to delete which are outlined above; or (2) direct confirmation that the consumer provided the authorized agent permission to submit the request.
We will respond to verifiable requests received from California residents as required by law. For more information about our privacy practices, you may contact us as set forth in the Contact and Comments section above.
| Request Type | Number of Requests Received | Number of Requests to which We Responded | Number of Requests Denied | Average Response Time (Number of Days) |
|---|---|---|---|---|
| Requests to Know | 0 | 0 | 0 | N/A |
| Requests to Delete | 0 | 0 | 0 | N/A |
| Requests to Opt-Out of the Sale of Personal Information | 0 | 0 | 0 | N/A |