Curinos Online Privacy Notice
Last Updated August 2025
1. Overview
Curinos LLC, Curinos Limited, Curinos International Limited, and Curinos, Inc. and its subsidiaries (collectively “Curinos”) prepared this Online Privacy Statement (“Privacy Notice”) to explain how Curinos collects, uses, discloses, and protects Personal Information (defined below) across our brands and in different contexts using ethical and responsible practices that respect your privacy, and as required by law.
This Online Privacy Statement (this “Privacy Statement”) applies to Personal Information collected on our websites, mobile applications, or cloud-based services and communication platforms with a link to this Privacy Statement (collectively, the “Site”). It covers how Curinos collects, uses, shares, and otherwise processes Personal Information as of the date that this Privacy Statement is posted. It does not apply to any other information collected by us through any other means. “Personal Information,” means information that identifies or can identify you personally, including any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or its equivalent.
2. Collection of Information
For public areas of our Site, we generally collect and process only Personal Information you voluntarily provide to us. For some secure areas of our Site, however, Curinos may require you to provide Personal Information, including your login credentials. Curinos may also collect your Personal Information to perform services on our Site, enhance the services offered to you, maintain and improve the Site, to secure our Site, comply with legal obligations, and inform you about other services and products that may be available through Curinos, our affiliated companies, and our marketing partners. If you choose not to provide us with the Personal Information that is legitimately required, Curinos may be unable to provide you with the information or services you have requested. Public areas of our Sites ask for Personal Information from you when you engage in the following activities:
- Sign up for newsletters or general information about our products and services
- Submit comments, reviews, or other user generated content
- Apply for a job
- Request customer or technical support
Personal Information may include any or all of the following:
- Name;
- Postal or billing address;
- E-mail address;
- Telephone or mobile number;
- Location via IP address
- Device being used (for our mobile site)
- Previous login history with our Site; and
- Other relevant data, including any information you provide when contacting us.
Even if you do not send us any Personal Information, Curinos may collect certain non-personal information about how you use our Site. This non-personal information cannot reasonably identify you, and is used for statistical purposes.
3. Information Collected Through Technology
Curinos may also obtain information in other ways through technology. Some of this information may be linked to you personally. Curinos processes this information to help our Sites function correctly, and better understand the needs of our customers.
Device Information. Depending on the permissions you’ve granted and other factors, Curinos may receive information about your location and your mobile device, including a unique identifier for your device. Examples of the device information Curinos collects include:
- Attributes such as the operating system, hardware version, device settings, battery and signal strength, and device identifiers.
- Certain device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals are gathered if you enabled the functionality within your product configuration.
- Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.
- Gathering of IP addresses is used for our enhanced security.
Most mobile devices allow you to turn off location services, and Curinos encourages you to contact your device manufacturer for detailed instructions on how to do that.
4. Information Collected Through Partners
As a part of its business, Curinos collects certain information (i.e., pseudonymized data) from its partners containing an identifier Curinos cannot reverse. Partner data can be classified as follows:
- Client Partners – Reporting and Analysis – This pseudonymized data is primarily used in analysis for Client Partners, and that data is generally aggregated to averages at consumer segments. Curinos has no way of personally identifying this data received from Client Partners, nor does it sell or share consumer information to third parties.
- Third Party Data Providers – This pseudonymized data is provided by third parties for analysis reporting, market assessment, and developing pseudonymized marketing audiences. In some cases, Client Partner data is enhanced with Third Party Data at the direction of the Client Partner to inform marketing audience development. Reporting and analysis is provided in aggregate, and never in a way that is personally identifiable to an individual. Marketing audiences, at the direction of Client Partners, are provided pseudonymously by Curinos back to Third Parties at the direction of Client Partners for re-identification for marketing campaigns. Ownership and authorization to use such pseudonymized data is based on warranties provided by Third Party Data Providers Curinos uses under contract.
5. How Curinos Uses and Shares Your Personal Information
Whatever the purpose may be – whether to share with service providers, consultants, government authorities, or other external entities – Curinos only processes and shares your Personal Information to the extent reasonably necessary to fulfill your requests and meet our legitimate business and legal objectives. Curinos does not share your Personal Information with unaffiliated third parties solely for their own direct marketing purposes. Curinos does not sell your Personal Information. When Curinos discloses Personal Information to external entities to perform support services for it, Curinos will establish by contract that they may access your Personal Information only for the purposes of performing those support services. Curinos may also use what it knows about you to potentially offer you other products and services in the future. Curinos may combine your online information with information collected from offline or online sources, or information it already has. Curinos may also use and disclose certain Personal Information to our affiliated companies and others for any purpose allowed by law.
Curinos will use your information to provide certain services and to comply with regulatory or legal requirements imposed on it in each jurisdiction in which it operates. Curinos may monitor or record any communications with one of our employees, including meetings, Teams communications, and telephone calls. Curinos may use these recordings to check instructions provided to it, to assess and improve services to clients, and for training and quality purposes. The information may also be used to invite you to events and inform you about other Curinos products that may be of interest to you or your organization, and may be shared with partner companies that provide marketing services to us at our request and under our direction. The requirements for the regulation of financial institutions could change in the future and while this notice will be regularly reviewed, Curinos may need to process your data for additional purposes not listed but necessary to give effect to the business relationship.
Business Activities. Curinos generally processes and may disclose your Personal Information to others to:
- Verify your identity or for other fraud prevention measures and reporting obligations;
- Monitor inbound calls for training and quality enhancement purposes
- Perform certain transactions initiated by you
- Respond to your questions about our products or services
- Perform Site analytics
- Engage in automated decision-making, including profiling
- Send you communications about a program or service, ads and promotions, electronic newsletters, or other marketing activities
- Comply with applicable law, obey judicial orders, cooperate with law enforcement authorities, or prevent any suspected illegal activities
- Help us run our business
- For any other everyday business purposes, such as product development and Site administration
6. Legal Grounds for the Collection, Use, Sharing, and Other Processing of Information
Certain jurisdictions require the identification of the legal grounds for the collection, use, sharing, and other processing of Personal Information. Curinos relies on the following legal grounds for the collection, use, sharing, and processing of Personal Information as described in this Privacy Notice:
- Necessary to provide information or otherwise carry out the performance of a contract with you as an individual;
- Curinos’ legitimate interests, including:
- Performance of the contract with you or a Client Partner;
- Customer relationship management and other forms of marketing and analytics;
- Fraud prevention, misuse of company IT systems, or money laundering;
- Physical, IT, and network perimeter security;
- Internal investigations; and
- Intended mergers and acquisitions.
- Compliance with legal obligations and/or defense against legal claims, including those in the areas of data protection, tax, and corporate compliance laws.
- Protection of the vital interests of any individual;
- Performance of a task carried out in the public interest or in the exercise of official authority vested in us; and
- Consent, as permitted by applicable law.
Authorized Service Providers. Curinos uses other companies and individuals to perform certain functions on its behalf. Curinos may disclose certain Personal Information to these companies and other individuals performing services in the United States or other locations where it conducts business.
Sale of the Businesses. If Curinos sells all or part of its business, Personal Information may be transferred to the purchaser in connection with that transaction. Curinos will use reasonable efforts to include contractual provisions that require the purchaser to treat your Personal Information consistently with the terms of this Privacy Notice.
Other Disclosures. Curinos may otherwise disclose Personal Information as permitted or required by law, when Curinos believes in good faith it is necessary for safety purposes, required for legal reporting, or to protect its legal rights or enforce this Site’s terms and conditions or any applicable rules, or to protect the rights of others. Curinos may disclose Personal Information to its auditors, legal advisors, or to respond to a subpoena. Curinos may also aggregate information that we gather about you (e.g., traffic patterns) and provide these statistics to others in aggregate form.
You should expect that the recipients identified above are located inside or outside the European Economic Area (“EEA”), or the United Kingdom. Recipients outside the EEA might be located in countries that do not offer an adequate level of protection from an EEA data protection law perspective. Curinos will take all necessary measures to ensure that transfers out of the EEA or UK are adequately protected as required by applicable data protection law. With respect to transfers to countries not providing an adequate level of data protection, Curinos may base the transfer on appropriate safeguards, such as the EU’s or the UK’s standard contractual clauses, Data Privacy Framework, approved codes of conduct together with binding and enforceable commitments on the recipient, or approved certification mechanisms together with binding and enforceable commitments on the recipient. You can request a copy of the appropriate safeguards by contacting Curinos as set out below.
Any access to your Personal Information is restricted to those individuals who have a need to receive or access this data in order to fulfill their job responsibilities. Curinos may also disclose your Personal Information as required or permitted by applicable law to governmental authorities, courts, external advisors, and similar third parties.
7. Your Rights Concerning Your Personal Information
Certain jurisdictions maintain local data protection regulations that confer specific data protection rights on individuals. Curinos will address those rights as required by applicable laws. If you wish to exercise any of these rights, please contact Curinos as specified below. If you have declared your consent regarding certain types of processing activities, you can withdraw this consent at any time with future effect. This withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. To the extent you’ve provided your consent and wish to withdraw it, you can contact Curinos as stated below.
Pursuant to applicable data protection law you may also have the right to: (1) request access to Personal Information; (2) request rectification of your Personal Information; (3) request erasure of your Personal Information; (4) request restriction of processing of your Personal Information; (5) request data portability of your Personal Information; and/or (6) object to the processing of your Personal Information. Please note that these rights might be limited under the applicable national or local data protection law.
- Right of access: You may have the right to obtain from Curinos confirmation as to whether Personal Information concerning you is processed, and, to request access to the Personal Information. The access to information includes, among other things, the purposes of the processing of Personal Information, the categories of Personal Information concerned, and the recipients or categories of recipients to whom the Personal Information have been or will be disclosed. This is not, however, an absolute right, and the interests of other individuals may restrict your right of access.
- Right to rectification: You may have the right to obtain from Curinos the rectification of inaccurate Personal Information about you. Depending on the purposes of the processing, you may have the right to have incomplete Personal Information completed, including by means of providing a supplementary statement.
- Right to erasure: Under certain circumstances, you may have the right to obtain from Curinos the erasure of Personal Information concerning you, and Curinos may be obligated to erase that Personal Information, as long as it is not required for legal or regulatory purposes.
- Right to restriction of processing: Under certain circumstances, you may have the right to obtain from Curinos restrictions on processing of your Personal Information. In that case, your data will be marked and may only be processed for certain limited purposes. As Curinos processes and uses your Personal Information primarily for purposes of carrying out the contract for services and in furtherance of our business relationship, Curinos has a legitimate interest for the processing which may override your restriction request, unless the restriction request relates to marketing activities.
- Right to data portability: Under certain circumstances, you may have the right to receive the Personal Information about you, which you have provided to Curinos, in a structured, commonly used and machine-readable format, and you may have the right to transmit that data to another entity without hindrance from Curinos.
- Right to object: Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Information by Curinos, and Curinos can be required to cease future processing of your Personal Information.
You also have the right to lodge a complaint with a competent data protection supervisory authority. To exercise your rights, please contact us as set out below.
8. Cookies and Other Tracking Technologies
In accordance with applicable law, Curinos uses and allows third parties to use essential and non-essential cookies, online tracking tools, web beacons, and similar technologies (collectively, “cookies”) on our Site. Curinos processes this information to help its Site function correctly, and better understand the needs of its customers.
Cookies on this Site generally fall into the following categories:
- Strictly Necessary Cookies: These are required for the operation of the Site. They include, for example, cookies that enable you to log into secure areas. These cookies are session cookies which are erased when you close your browser.
- Analytical/Performance Cookies: These allow Curinos to recognize and count the number of users of its Site and see how those users navigate through the Site. This helps to improve how the Site works, for example, by ensuring that users can find what they are looking for easily. These cookies are session cookies which are erased when you close your browser.
- Functional Cookies: These improve the functional performance of the Site and make it easier for you to use. For example, cookies are used to remember that you have previously visited the Site and asked to remain logged into it. These cookies are session cookies which are erased when you close your browser.
Controlling Tracking Tools. Your browser may give you the ability to control cookies. How you do so, however, depends on your browser and the type of cookie. Certain browsers or browser plugins can be set to reject all browser cookies. If you configure your computer to block all cookies, you may disrupt certain web page features, and limit the functionality Curinos can provide when you visit or use its Site. (e.g., Curinos will not be able to provide you with searches that you have asked us to save). You can change your cookie settings at any time.
Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These browser features are still not uniform, so Curinos is not currently set up to respond to those signals.
Data protection laws in your jurisdiction may treat cookie use differently or provide you an additional right to opt-out of such cookie use. If you are a visitor to this Site, and have any concerns about collection, or use of cookie information, contact us directly.
9. Security
Curinos implements a variety of technical, physical, and administrative security measures to secure the confidentiality of your Personal Information and to protect it from loss, misuse, alteration, and destruction. Those measures include a variety of practices to keep Personal Information safe and prevent unauthorized access to, or use, or disclosure of it. Electronic data and databases are stored on secure computer systems with control over access to information using both physical and electronic means. Curinos personnel receive data protection training and there is a set of detailed security and data protection policies which personnel are required to follow when handling Personal Information. But the safety and security of your information also depends on you. And while Curinos strives to protect your Personal Information, it cannot guarantee or warrant the security of any information you transmit to it, or to or from our Services. You transmit all such information at your own risk. Curinos is not responsible for circumvention of any privacy settings or security measures contained on the Site.
10. Data Retention
Depending on the product or service, Curinos will retain your Personal Information only for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by a law that applies to it.
11. How Curinos protects international transfers of Personal Information?
Curinos is based in the United States, but has operations and servers located in the United Kingdom, Canada, Australia, and other jurisdictions. If you are located in a jurisdiction that does not consider these countries to provide an adequate level of protection as does your home country, cross-border transfer of your information is necessary for the conclusion or performance of a transaction that you requested, and for the establishment, exercise, and defense of legal claims. To the extent permitted by local law, your use of this Site or provision of any Personal Information constitutes ̶ where legally permitted ̶ your consent to the cross-border transfer of Personal Information and other activities identified in this Privacy Notice.
12. Minors
This Site is not intended or directed to individuals under the age of 16, and Curinos does not knowingly collect any Personal Information from minors, or knowingly track the use of this Site by children. If you believe Curinos has impermissibly collected Personal Information from someone under the age of 16, please contact it directly.
13. How to update your Personal Information, file a complaint, ask questions, or send us comments about this Privacy Notice
If you have any questions or concerns about this Privacy Notice or wish to correct or update your Personal Information, or alert us about a concern, or unsubscribe from any updates you have requested, write to Curinos at privacy_support@curinos.com.
While Curinos will accept and review your inquiry, it can only process requests in situations where it has your Personal Information, since other pseudonymized data cannot be reversed by Curinos. In these cases, Curinos suggests you refer to:
- Your financial institution to exercise your rights.
- For data sourced by Third Party Data Providers Curinos works with, you may also exercise your rights by contacting:
- Acxiom (Third Party Data Provider): https://www.acxiom.com/optout/
- Direct Mail Association Global Opt-Out: https://www.dmachoice.org/register.php.
14. Changes or Updates to this Privacy Notice
Curinos may amend this Privacy Notice at any time. If Curinos makes any material change in how it collects, uses, discloses, or otherwise processes Personal Information, it will post an updated Privacy Notice on this Site. Any changes to this Privacy Notice will be effective immediately upon posting of the updated Privacy Notice or as otherwise required by applicable law.
15. Contact Information
If you have any questions or comments about this Privacy Notice, the ways in which Curinos collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under state privacy laws, please contact:
Curinos, Inc.
485 Lexington Avenue
20th Floor
New York, NY 10017
Email: privacy_support@curinos.com
16. US Privacy Addendum
If you reside in the United States, this U.S. Privacy Addendum supplements the information above for California and certain other U.S. states.
California Privacy Policy
Curinos Supplemental Privacy Notice
For California and Other US Residents
Last Updated August 2025
- Overview
Curinos, Inc. and its subsidiaries (collectively “Curinos”) prepared this US Supplemental Privacy Notice (“Supplemental Notice”) to supplement the practices described in Curinos’ Online Privacy Notice, and it applies only to information collected about individuals covered by California’s Consumer Privacy Act (“CCPA”) and other similar privacy laws in the United States (collectively, “US State Privacy Laws”). This Supplemental Notice is parallel in scope to Curinos’ Online Privacy Notice and should be read in conjunction with that notice. Some portions of this Supplemental Notice apply only to consumers of particular states. In those instances, Curinos has indicated that such language applies only to those consumers. Any terms defined in the CCPA or other State Privacy Laws have the same meaning when used in this Supplemental Notice.
As used in this Supplemental Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household or device. Personal Information includes, but is not limited to, the categories of Personal Information identified below if such information identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual or household. Personal Information does not include:
- Publicly available information from government records
- De-identified or aggregated consumer information, including pseudonymized data Curinos receives from third parties
- Other information exempted from the State Privacy Laws’ scope, such as:
- Personal Information governed by certain sector-specific privacy laws, including the Gramm-Leach-Bliley Act (“GLBA”), the Fair Credit Reporting Act (“FCRA”), or the California Financial Information Privacy Act (“FIPA”).
- Health or medical information governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA).
CCPA and other State Privacy Laws grant residents certain rights regarding the Personal Information that businesses have about them. These include (a) the right to know about Personal Information categories the business collected about you in the prior 12 months, the source of such information, the purpose for collecting the information and the specific information collected about you; (b) the right to request access or deletion of your Personal Information, (c) the right to request correction of your Personal Information as well as (e) the right to direct a business to stop selling your Personal Information. While Curinos does not sell Personal Information to third parties for monetary consideration, the CCPA and other laws broadly defines “sale” and “sharing” in such a way that certain data collected on Curinos’ Site by third parties for interest-based advertising purposes may have been considered a “sale” or “sharing” under the CCPA. The categories of third parties to whom Personal Information is disclosed include advertisers and marketing partners and data analytics providers. The categories of information Curinos may share with such parties may include device information and identifiers, such as IP address, and unique advertising identifiers and cookies; usage information, such as browsing history; location information, such as city; and inference data. California residents can turn on the Global Privacy Control (“GPC”) to opt out of the “sale” or sharing of their Personal Information for each participating browser system that they use.
- Categories of Personal Information Collected and Business Purposes for Processing
Curinos collect the following categories of Personal Information for the purposes described below, as permitted by applicable law. These categories are defined by California law and represent the Personal Information that Curinos may have collected about California residents, and how it may have been shared, over the past 12 months. The business purposes for processing such information are provided below the chart. The inclusion of a category in the list below indicates only that Curinos may collect this information for certain individuals for some activities within the scope of the identified business purpose. It does not necessarily mean that Curinos collects all the information listed in a particular category for all individuals.
Curinos has shared information in each category with its affiliates and service providers for its business purposes within the last 12 months. Curinos may also receive requests for information from regulatory authorities, its auditors, and/or legal advisors. If requested from such parties, Curinos would share your Personal Information as appropriate:
Personal Information Collected Directly from Employees and Prospective Employees
| CATEGORY OF PERSONAL INFORMATION | TYPES OF INFORMATION COLLECTED |
|---|---|
| Personal Identifiers | Real name, alias, date of birth, residential address, postal address, telephone number, unique personal identifiers including online identifiers, internet protocol (IP) address, email address, Social Security number, driver’s license or state identification card number, passport number, visa information, written signature, insurance policy number, or other similar identifiers. |
| Demographic Identifiers | Demographic information protected under federal law, CCPA or other State Privacy Law, including age, sex, gender, sexual orientation, racial or ethnic origin, national origin, citizenship, residency, or immigration status, marital status, health and physical or mental disability status, or military/veteran status. |
| Employment Information | Employment history, occupation, position, professional licensures, salary information, professional or employment-related information, including written signatures, and other information collected from a resume or application. |
| Education | Education history, including educational institutions attended, degree(s) and/or certification(s) earned, and other information collected from a resume or application. |
| Financial Information | Financial information including bank account number, source of funds for the contract or policy, source of wealth, assets, or other financial information. |
| Medical or Health Information | Medical information, including any information in possession or derived from a healthcare provider, healthcare service plan, pharmaceutical company, or contractor regarding an individual’s medical history, mental or physical condition, or treatment. Health insurance information including an individual’s insurance policy number or subscriber identification number, any unique identifier used by a health insurer to identify the individual, transaction information, or any information in the individual’s application and claims history. |
| Internet or other Electronic Network Activity | Online identifiers, internet protocol (“IP”) address, and information regarding an individual’s interaction with our website including page visits, browsing or search history, including when browsing anonymously, or an individual’s device interaction with an internet website application or advertisement as described in our Online Privacy Policy. |
| Profile Information | Inferences drawn from any of the information listed above, including creating a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
| Audio/Visual Information | On-site cameras for security, video, photos, and audio recordings such as a recording of a customer service call. |
- Purposes for Which Curinos Collects Personal Information
Curinos, and its Service Providers, collect and process the Personal Information (excluding Sensitive Personal Information) described in this Supplemental Notice to:
- Operate, manage, and maintain its business
- Secure your account/ policy with us
- Respond to your inquiries and to fulfill your requests
- Use generative artificial intelligence models, including third-party external consumer data and information sources, in compliance with applicable laws and financial industry regulations, to augment our products and practices
- Maintain quality assurance, including recording audio calls or voice messaging systems
- Determine if a product or service may be suitable for you
- Support or respond to your inquiries
- Prevent fraud or other unlawful activities
- Determine the effectiveness of promotional campaigns, so that Curinos can adapt its campaigns to the needs and interests of its users
- Personalize, advertise, and market its products and services
- Comply with law, legal process, and internal policies
- Maintain records
- Exercise and defend legal claims
- Test or perform analysis, including data analytics and insights to improve its products
- Otherwise accomplish its business purposes and objectives
Curinos also collects the below categories of Sensitive Personal Information as defined under CCPA directly from Employees and Prospective Employees.
| CATEGORY OF SENSITIVE PERSONAL INFORMATION | TYPES OF SENSITIVE PERSONAL INFORMATION COLLECTED |
|---|---|
| Sensitive Personal Information / Not publicly available | Social Security number, driver’s license number, state identification card number or passport number, written signature, policy number(s), health and physical or mental disability status, racial or ethnic origin, national origin, citizenship or immigration status, sexual orientation, or physical characteristics or description. |
| Personal Identifiers | Real name, alias, date of birth, residential address, postal address, telephone number, unique personal identifiers including online identifiers, internet protocol (IP) address, email address, Social Security number, driver’s license or state identification card number, passport number, visa information, written signature, insurance policy number, or other similar identifiers. |
In addition, Curinos may use and disclose any Personal Information, including Sensitive Personal Information, that Curinos collects as necessary or appropriate to:
- Comply with laws and regulations, including applicable tax, customer due diligence (including identity verification), health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws.
- Monitor, investigate, and enforce compliance with potential breaches of Curinos’ policies and procedures and legal and regulatory requirements.
- Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons.
- Detect, investigate, and help protect against malicious, deceptive, fraudulent, or illegal activity.
- Exercise or defend its legal rights, including employees, Directors, Officers, affiliates, customers, contractors, and agents.
4. Sources from Which Curinos Collects Personal Information
Curinos may collect Personal Information directly from you, as well as from its affiliates, business partners, joint marketing partners, public databases, providers of demographic data, publications, professional organizations, social media platforms, third party information providers, affiliates with whom you have a business relationship, Service Providers with which Curinos has a contractual relationship and to which you have provided your personal information, cookies and other tracking technologies, and Service Providers and Third Parties when they share the information with Curinos. Curinos also collects Personal Information, in certain instances, from data brokers and other information sources, as well as other public databases.
5. Disclosure of Personal Information
Unless specifically stated, Curinos has not sold or shared Personal Information about California consumers with third parties for their own use in the past twelve months. Curinos may, however, disclose Personal Information to third parties (e.g., Service Providers) for business purposes. When Curinos discloses Personal Information for a business purpose, Curinos enters into a contract that describes the purpose and requires the recipient to ensure the information is confidential, and not to use it for any purpose other than performance of the contract. For purposes of the CCPA, a “sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. Curinos has no actual knowledge that Curinos sells or shares Personal Information of California consumers under 16 years of age. Curinos may share your Personal Information as allowed by law for the business purposes described in this Supplemental Notice with the following parties:
| CATEGORY | DESCRIPTION |
|---|---|
| Corporate Affiliates | Curinos may share your information with its corporate affiliates and with their respective officers, directors, employees, accountants, attorneys, and agents. |
| Personal Identifiers | Real name, alias, date of birth, residential address, postal address, telephone number, unique personal identifiers including online identifiers, internet protocol (IP) address, email address, Social Security number, driver’s license or state identification card number, passport number, visa information, written signature, insurance policy number, or other similar identifiers. |
| Acquisitions and Similar Transactions | If Curinos is sold or part of its assets are merged with another company, your personal data may be transferred as part of the merger or sale. |
| Disclosures with Your Consent | Curinos may ask if you would like it to share your information with other unaffiliated third parties not described elsewhere in this Policy. Curinos will only disclose your information in this context with your consent. |
| Legal Obligations and Rights (Subpoenas, Court Orders, and Warrants); Regulatory Authorities | Curinos may disclose information to comply with the law, including disclosure to relevant industry regulatory bodies, or in response to subpoenas, warrants, court orders, or other legal process. |
| Service Providers | Curinos may share your Personal Information or aggregated information with third party Service Providers for purposes such as providing operational or support services on Curinos’ behalf including servicing a contract, providing policy benefits, or to prevent, detect, and investigate deceptive, fraudulent, or illegal acts. Service Providers may include vendors providing software, platforms, or tools (including generative AI tools) to perform operational or business functions and augment Curinos’ practices. Service Providers may provide website tracking technologies such as cookies, tags, or pixels that use anonymous browsing information or Personal Information as described in Curinos’ Online Privacy Notice. |
| Professional Advisors (Auditors and Legal Advisors) | Curinos may share your information with our professional advisors, including attorneys, auditors, and accountants, to provide services on its behalf. |
| De-identified or Aggregated Data | Curinos may share your information with our professional advisors, including attorneys, auditors, and accountants, to provide services on its behalf. |
| Other | Where required or permitted by law. |
6. Data Retention
Depending on the product or service, Curinos will retain your Personal Information only for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by a law that applies to Curinos. Curinos keep records containing Personal Information in accordance with applicable state and federal rules that apply to it. Curinos considers the following criteria when determining how long to retain Personal Information: why Curinos collected the Personal Information; the nature of the Personal Information; the sensitivity of the Personal Information; our legal obligations related to the Personal Information; and the risks associated with retaining the Personal Information. Curinos aims to retain Personal Information only for as long as necessary for the purposes it was collected for, including defending or advancing legal claims, and to comply with legal obligations. Curinos may need to keep some Personal Information for longer than other information to comply with applicable laws and regulations, including litigation.
7. Your Privacy Rights
Exercising Privacy Rights. Consumers who live in California have certain rights with respect to the collection and use of their Personal Information. You may access these data rights by calling or e-mailing us as set out below:
Curinos, Inc.
485 Lexington Avenue
20th Floor
New York, NY 10017
Email: privacy_support@curinos.com
Agents. Consumers in some states may also authorize an agent to make data subject requests on their behalf.
Verification of Data Subject Requests. Curinos may ask you to provide information that will enable us to verify your identity to comply with your data subject request. In particular, when a consumer authorizes an agent to make a request on their behalf, Curinos may require the agent to provide proof of signed permission from the consumer to submit the request, or Curinos may require the consumer to verify their own identity to us or confirm with us that they provided the agent with permission to submit the request. In some instances, Curinos may decline to honor your request if an exception applies under applicable law.
There are circumstances in which Curinos may not be able to comply with your access, deletion, or other request, including when Curinos cannot verify your request, or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. Additionally, in certain instances, some information Curinos collects from you may be excluded from the definition of Personal Information as defined under applicable State Privacy Laws, and, as such, this information is exempt from certain rights otherwise available to you. Curinos will respond to your request consistent with applicable law.
Non-Discrimination. Curinos will not discriminate against you for exercising your data subject rights. For example, Curinos will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.
Appeals. To appeal our decision on your data subject requests, you may send it to:
Curinos, Inc.
485 Lexington Avenue
20th Floor
New York, NY 10017
ATTN: Privacy Appeals
Email: privacy_appeals@curinos.com
Please enclose a copy of or otherwise specifically reference the decision on your data subject request, so that Curinos may adequately address your appeal. Curinos will respond to your appeal in accordance with applicable law.
1. Right to Access Your Data. You have the right to request that Curinos disclose certain information to you about our collection and use of your Personal Information for the 12-month period preceding your request. California residents may request information for the prior 24-month period. Once Curinos receives and verifies your identity, you have the right to receive:
- The categories of Personal Information Curinos collected about you.
- The categories of sources for the Personal Information Curinos collected about you.
- The business or commercial purpose for collecting, selling or sharing that Personal Information.
- The specific pieces of Personal Information Curinos collected about you, including by a service provider or contractor.
- The categories of third parties with whom Curinos shared that Personal Information.
- The specific pieces of Personal Information disclosed for a business or commercial purpose, identifying the Personal Information categories that each category of recipient obtained about you.
2. Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means you have a right to request that Curinos move, copy or transmit your Personal Information stored on its servers / IT environment to another service provider’s servers / IT environment.
3. Right to Correction. You have the right to request correction or changes of your Personal Information if it is found to be inaccurate or out of date.
4. Right to Delete Your Data. You have the right to request that Curinos delete any of your Personal Information that Curinos collected from you and retained, subject to certain exceptions. Once Curinos receives and confirms your verifiable consumer request, Curinos will delete (and direct its service providers to delete) your Personal Information from its records, unless an exception applies.
5. Right to Opt-Out of Sale or Sharing of Personal Information. Curinos currently does not sell Personal Information to third parties or share your Personal Information with third parties for cross-context behavioral advertising purposes, and, therefore, this is inapplicable to us. Curinos may disclose Personal Information about you to its affiliates and service providers as permitted by law. Please see the “Sharing Personal Information” portion of this policy for more information.
6. Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to request Curinos limit the use of your sensitive Personal Information to only purposes necessary to engage with you. This sensitive Personal Information is defined in California law, and you will find a more detailed description of what type of information this entails in the charts included above. Curinos does not use your sensitive Personal Information for purposes other than those necessary to engage with you, to aid in protecting and securing your Personal Information and its systems, to verify or maintain the quality or safety of its services and systems, or as otherwise permitted under regulations or required law.
7. Right to Non-Discrimination. Curinos will not discriminate against you for exercising any of your privacy rights.
8. Changes to Our US Supplemental Notice.
Curinos reserves the right to amend this US Supplemental Notice at our discretion and at any time. When Curinos makes material changes to this US Supplemental Notice, Curinos will post an updated Supplemental Notice on the Site listing the effective date of such updates.
If you have any questions or comments about this US Supplemental Notice, the ways in which Curinos collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under state privacy laws, please contact:
Curinos, Inc.
485 Lexington Avenue
20th Floor
New York, NY 10017
Email: privacy_support@curinos.com