Privacy Policy - CNO Financial

Privacy Notice

Website Owner

This Website is owned and operated by:

BI WORLDWIDE, with headquarters located at
7630 E. Bush Lake Road
Minneapolis, MN 55439

- and/or –

BI Worldwide Ltd, with headquarters located at
1 Vantage Court
Newport Pagnell, Buckinghamshire MK16 9EZ.

Throughout the remainder of this Privacy Notice, the names “BI WORLDWIDE” and “BI Worldwide Ltd” shall be defined as “BIW”.

Why personal information about You will be collected

You (defined in this Privacy Notice as “You” or “Your”) have been invited to participate in a Program (defined in this Privacy Notice as “the Program”) sponsored by one of BIW’s customers (defined in this Privacy Notice as “Sponsor”). If you chose to participate in the Program and it enables You to earn certain branded award points (defined in this Privacy Notice as “Award Points”), then BIW has a legitimate interest in the collection of Your personal information for the purpose of enabling You to redeem Your Award Points via this website (defined in this Privacy Notice as “the Website”) for merchandise or services, and to enable delivery of those to You.

Personal information about You that will be collected

BIW may have received personal information about You from the Sponsor of the Program that may be combined with additional personal information that is collected from You by BIW via the Website when you redeem Award Points for merchandise and/or services.

BIW will collect and use personal information that You provide to BIW directly through the Website, as applicable, when You:

complete forms, or communicate with BIW in person, by phone, e-mail, fax, on-line or chat
place an order to redeem Award Points using the Website

The following types of personal information may be collected and processed by the Website:

[
participant ID
first name
last name/surname
personal street address
business street address
personal phone number
business phone number
personal email address
business email address
video/photos
social security number
national id number
credit card
bank account details
gender
ethnicity
nationality
race
device IP address
]

Collection, processing, and storage of personal information are required to operate and administer the Website.

BIW will not share Your personal information processed by the Website with any third party companies for any company’s marketing purposes.
BIW will not sell Your personal information processed by the Website to any third parties.

You have the choice to not provide the personal information necessary to redeem Award Points for merchandise or services.If You choose not to provide the personal information requested, You will not be able to complete Your order, or receive any merchandise or service via the Website.

Personal information is saved for the length of time that is required for BIW to operate and administer the Website, and/or for as long as required by law for financial reporting purposes.

How personal information about You will be used

BIW respects the privacy of Your personal information and will not share Your personal information with third parties except as necessary to operate the Program and related purposes.

Your personal information will only be used for the intended purpose(s) for which it was collected, or for closely related purposes in conjunction with the Website.

Your personal information will be used by BIW only as required to:

allow You to redeem Award Points for merchandise and/or services
allow Your order(s) to be delivered to You
notify You about changes to the Website or related services
analyze and improve the Website
keep track of Your Award Points so you can redeem them using the Website
process credit card or bank payments

When it is necessary to share personal information from the Website with a third party, Your personal information will be properly protected, only the minimum personal information required will be shared, and it will be shared only on a need-to-know basis.

Your personal information may be shared:

with the Sponsor of the Program and with BIW to administer the Program
with BIW’s suppliers to enable delivery of Your order(s)
with another business if Sponsor or BIW is involved in a takeover or merger with that business
if Sponsor or BIW is under a legal duty to disclose Your information (for example, as required by law enforcement or a court order)
if Sponsor or a third party (including BIW) must enforce a contract
if Sponsor or a third party (including BIW) must protect the rights, property, or safety of You or anyone else
with providers of analytics services as described in the next paragraph

BIW will collect the following types of information and use analytics services to help make improvements to the Website, or to troubleshoot problems:

personal information – the IP address assigned to the device You use to access the Website (an IP address is a unique number assigned to your device when you use the internet, analytics including age, gender, interests, language, location, and any phone number You use to call BIW’s customer service number
technical information – browser type and version, time zone setting, browser plug-in types and versions, operating system and version, and device type, device, screen resolution.
performance information – information about Your use of the Website, including the date and time You connect, the pages of the Website You view, products from our catalog You viewed or searched, how long it took to display each page You viewed, errors, and the length of time You spent on certain pages

Your personal information is securely stored within the USA and/or The United Kingdom, or securely through 3rd parties such as Google.

Your personal information for purposes of order or delivery (name, address, e-mail, personal phone number, credit card information, bank account information, national ID number) will be securely transferred to the country or region where you reside as required to permit delivery of Program communications, or merchandise and/or services You ordered.

If it is necessary to transfer Your personal information outside of the country in which it is stored, BIW takes steps to make sure adequate levels of privacy protection in line with applicable data protection laws are in place. These privacy protection measures are contractually required of all parties involved in the transfer.

Third parties with whom Your personal information may be shared

Your personal information is not shared with any third parties unless it is required to administer the Website or to provide and/or deliver merchandise or services that You order.

Your rights if You are a citizen of the European Economic Area (EU) or the United Kingdom (UK)

BIW respects Your rights as defined within the General Data Protection Regulation (GDPR) to access and control Your personal information which include:

1) Right to information – This right provides You with the ability to ask BIW what personal information about You is being processed and the rationale for such processing.

2) Right to access – This request provides You with the right to see or view Your own personal information that is being processed, as well as to request copies of Your personal information.

3) Right to rectification – This right provides You with the ability to ask for modifications to Your personal information if You believe that Your personal information is not up to date or accurate.

4) Right to withdraw consent – This right provides You with the ability to withdraw previously given consent for processing of Your personal information for a specific purpose. Your request would then require BIW to stop the processing of Your personal information that was based on the consent provided earlier.

5) Right to object – This right provides You with the ability to object to the processing of Your personal information. Normally, this would be the same as the right to withdraw consent, if consent was appropriately requested and no processing other than legitimate purposes is being conducted. However, a specific scenario would be when You ask that Your personal information not be processed for certain purposes while a legal dispute is ongoing in court.

6) Right to object to automated processing – This right provides You with the ability to object to a decision based solely on automated processing. Using this right, You may ask that Your input (for instance, a questionnaire You completed) to be reviewed manually, because You believe that automated processing of Your responses may not consider Your unique situation.

7) Right to be forgotten – Also known as right to erasure, this right provides You with the ability to ask for the deletion of Your personal information. This will generally apply to situations where You no longer participate in the Program. It is important to note that this is not an absolute right, and also must take into consideration BIW’s rights and legal responsibilities.

8) Right for data portability – This right provides You with the ability to ask for transfer of Your personal information. As part of such request, You may ask for Your personal data to be provided directly to You, or transferred to another data controller or data processor other than Sponsor or BI Worldwide. When doing so, Your personal information must be provided or transferred in a machine-readable electronic format.

Who to contact to exercise Your rights if you are a citizen of the European Economic Area (EU) or the United Kingdom (UK)

Under the GDPR BIW is defined as an independent “Data Controller” of Your personal information provided via this Website.

If You have any questions or concerns related to how Your personal information is used by the Website, You should contact BIW directly by sending an email with your name and contact information to BIW’s Data Privacy Team: privacy.office@biworldwide.com

If You are not happy with the response you receive from BIW’s Data Privacy Team, or You believe that protection of Your personal information or privacy rights have been infringed, You should contact Your European Union, United Kingdom, or other state or country’s Data Protection Authority (DPA) or if you are a citizen of Switzerland, the Swiss Federal Data Protection and Information Commissioner, as applicable.You can search for Your country’s DPA by entering the name of your country combined with the words “data protection authority” or “privacy office” into an Internet search page such as www.google.com.

Your rights if you are a resident of the state of California under the CCPA

BIW respects Your rights as defined within The California Consumer Privacy Act (CCPA).

The California Consumer privacy Act of 2018 (CCPA) was written with the goal to assure the right of every California resident (Consumer) to control certain uses of their personal information by giving them an effective way to control their personal information, by ensuring the following rights:

The right to know what personal information is being collected about them.
The right to know whether their personal information is being sold or disclosed (and to whom).
The right to say ‘no” to the sale of their personal information.
The right to access their personal information.
The right to equal service and price, even if they exercise their privacy rights.

Under the CCPA, Consumers have the right to request that a company in possession of their personal information disclose to the Consumer the following:

The categories of personal information the company has collected about the Consumer.
The categories of sources from which the Consumer’s personal information is collected.
The company’s reason, or purpose, for collecting or selling the Consumer’s personal information.
The categories of third parties with whom the company shares the Consumer’s personal information.
The specific pieces of the Consumer’s personal information the company has collected or shared with a third party.

Under the CCPA, Consumers also have the right to request that a company in possession of their personal information delete the personal information pertaining to the Consumer.

This includes deletion of any copies of the Consumer’s personal information that have been sold or disclosed to any third parties.

Who to contact to exercise Your rights if you are a resident of the state of California

Please be aware that BIW is required to respond to a consumer request only once during any calendar year, that not all information sharing is covered by the California Privacy Rights requirements, and only information sharing that is covered will be included in BIW’s response.

To make such a request You can either:

email BIW’s Data Privacy Team: privacy.office@biworldwide.com, or
call BIW via the following Toll-Free number:1-888-550-1570

In your request, please attest to the fact that You are a California resident and provide Your current California residential address.