WE DO NOT SELL OR RENT ANY OF THE DATA OR INFORMATION COLLECTED WHEN YOU VISIT OUR SITE OR USE OUR APPLICATIONS. ANY DATA THAT WE DO PROVIDE TO THIRD PARTIES WE DO SO ONLY WITH YOUR EXPRESS CONSENT AND SOLELY IN ORDER TO ASSIST YOU AND/OR YOUR ATTORNEY IN PREPARING YOUR LEGAL DOCUMENTS AND COMMUNICATE WITH YOUR RETIREMENT PLANS AND AS SPECIFICALLY SET FORTH IN THIS DOCUMENT. IF YOU ARE AN ATTORNEY WE STORE AND PERMIT YOU TO ACCESS YOUR CLIENT’S INFORMATION FOR PURPOSES OF YOUR PROVIDING LEGAL SERVICES FOR YOUR CLIENT(S).
The Center does not disclose any nonpublic personal information about you to third parties except as described in this document or as otherwise required by law.
So, What Information Do We Collect?
When you visit our Site or use our Applications you may provide us with two types of information: (a) personal information you knowingly choose to disclose that is collected on an individual basis (i.e. the stuff that identifies you specifically); and (b) aggregated Site and Application use information collected when you and others visit our Sites and use our Applications.
So far so good, right?
Personal Information – What It Is and What We Collect from You
So, exactly what Personal Information do we collect about you and other consumers? In short, it varies depending on the type of interaction you have with us. Almost every interaction with us is going to provide us with some information about you. It is probably shocking to you to find out how much data you provide to websites like ours at any given time, but here is a non-exhaustive list of the types of interactions you might have with us and during those interactions you share personal information about yourself with us:
While this section includes all of the information that we may collect about you we rarely collect all of these types of information about any single person. That doesn’t mean that it doesn’t happen, but it is truly rare.
The Center potentially collects the following categories of information about you, some of which may be collected or maintained in a manner such that it can be considered Personal Information:
Identifiers such as real names, nicknames, postal addresses, online identifiers, Internet Protocol addresses (“IP addresses”), email addresses, retirement account numbers, Social Security numbers, driver’s license numbers and other government identification numbers.
Other types of information such as physical characteristics or descriptions of you, telephone number, retirement policy number, employment, financial information including bank account, credit card, and debit card numbers, and court related information. It also includes additional information provided to the Center directly by you, such as when you complete a questionnaire, answer a survey, input data into our intake site or receive a consultation. This category includes information identified as Personal Information in California Civil Code Section 1798.80(e) that is not otherwise categorized.
Characteristics protected under some laws such as age, national origin, citizenship, marital status, medical information, sex, sexual orientation, and veteran or military status.
Commercial information such as products or services purchased, obtained, or considered from the Center or our partners, participating attorney, and other purchasing or consuming histories or tendencies.
Internet Related information such as browsing history, search history, information about the device you are using to access our Site or Applications, and information regarding your interaction with the Center or our partners’ websites, applications, or advertisements. We may also collect information from visitors to our Sites such as browser settings, operating systems, referring/exit pages, and clickstream data. When we send you an email, the Center may also collect information, including about how you interact with that email.
Geolocation information such as where you reside or are otherwise located.
Audio and visual information such as audio or video call information. The Center may make audio recordings of calls with you. We may also make visual recordings of you when you visit our physical locations or when you agree that we may take you photograph or record your interactions with us.
Professional and employment-related information such as information about your professional status and affiliations, employment history, employment status, and retirement plan information.
At this point, you are probably saying “Holy crap! That is a lot of Personal Information!!!” You are right. However, the Personal Information we collect, in all cases, relates to the information we need from you, or your attorney needs from you, in order to use our products and services and necessary to prepare legal documents to obtain a division of your retirement benefits by a court of law and your retirement plan(s).
Sources of Information About You.
Employers: We may collect information about you from your employer about your retirement benefits, policy information and your employment dates of hire and pay information.
Professionals (including Participating Attorneys and other Professionals): We may collect information about you from the independent Attorney professionals with whom you may schedule a consultation with through, when available, our Attorney Portal or other product and service offerings. An example of the type of information that we may receive from these Attorney professionals includes the fact that a consultation has occurred, that you have retained the Attorney to assist you, and the Attorney’s use of our products and services to complete the division of your retirement plan benefits as part of a divorce or dissolution or other legal proceeding. While we cannot control what information the Participating Attorneys share with us, the Center does not intend to collect any information from attorneys where the collection would result in a waiver of the attorney-client privilege.
Business Partners and Affiliates: We may also collect information about you from our business partners and affiliates. An example of the type of information that we may receive from business partners and affiliates is information about the products and services you purchased from them after you indicated an interest in an offer that the Center presented to you.
Publicly/Commercially Available Information: We may collect information related to you from publicly available sources of information, including government records and commercially available sources of consumer information.
Our Use of the Information We Collect About You.
Now that we have disclosed to you about the vast amount of Personal Information we collect about you, this section describes the specific uses of the information we have collected from you and other consumers. Our goal is to keep your Personal Information private and not disclose your information (or any consumer information) except for the uses described below.
If, in the future, we want to use your information for a purpose that is inconsistent with the specific uses in this section – we are going to ask your permission and seek your consent for the expanded or new use of that information unless we are required by law to provide such expanded or new use. In that case, we are going to provide you notice of the legal requirement and give you an opportunity to object.
Here is how we use information we collect about you:
We use your information to provide you our products and services. We may also use information to respond to inquiries from potential customers who are interested in learning more about our products and services. For example, producing and delivering documents purchased by you, administering our Site and Applications, and displaying content based on your preferences.
We collect information to maintain appropriate Site and Application security and prevent fraud over computer networks and our physical locations.
We collect information to meet our legal obligations to assist you in preparing the legal documents for filing with the court, for attorney review, for submission to your retirement plans, or responding to subpoenas for information.
We collect information to use in improving our existing products and services and in developing new products and services.
We collect information for use in performing Site, Application, and Marketing analytics. For example, the Center uses information to analyze how people visiting our Site or using our Applications or are visiting the Attorney Portal or interacting with the various features on our Site. We use this information to make improvements to the various features as well as to gain some insight as to what prospective users for our products and services might like or dislike. Hopefully, we are smart enough to use this information to identify various customer preference, characteristics, attitudes and behaviors.
We collect information to optimize our operations. For example we may use the information to maintain our Site and Applications, for training purposes, to assist in connecting customers to attorneys either through, when available, the Attorney Portal or be email contact and telephone, to promote our products and services and to use in connection with our relationships with service providers and business partners.
We collect information to provide to our business partners or to individuals who have either expressed interest in hearing from a business partner or who have purchased a product or service that involves one of our business partners. For example, we receive and provide information to and from several divorce website partners to provide services related to division of retirement benefits for their customers.
We collect information for use in various types of financial reporting and other similar internal uses. For example, we may use information in connection with internal budgets and projections and calculation of compensation.
In addition to the purposes listed above, we may also use de-identified or aggregate data that is not capable of being linked to any individual consumer for additional purposes not listed above.
Who We Share Information With.
We may share information about you with business partners and Participating Attorneys who assist us with completing the business purposes outlined in Section D above. These business partners and Participating Attorneys are not authorized to use the information we share with them for any other purpose other than providing services to the Center or to you.
We may share your information with the independent Participating Attorneys that can be accessed through, when available, the Attorney Portal or via telephonic or email contact with them and with other professionals retained to provide valuation information or other professional services related to the division of retirement benefits.
We may share information with business partners and affiliates in limited circumstances. These include:
We may share information about you with government entities in order to fulfill the products and services purchased by you. Certain Personal Information becomes public record when documents are filed with the federal or state government, or with a court.
We may publicly share information about you, such as by displaying the information on our Site or having the information published in publicly available media, in a very limited number of cases:
We may disclose consumer information as required by law, such as in response to a subpoena, a lawful request by a public authority, including to meet national security or law enforcement requirements, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a legal request.
In addition to the circumstances listed above, we may also share de-identified or aggregate data that is not capable of being linked to any individual consumer with additional entities not listed above.
You Can Control The Information We May Have About You.
This section is important because this is the section where you can control the information we may have about you including your right to request our disclosure of that information to you. Here is how you do that:
Upon a verified request, and subject to the privacy interests of others and technical limitations, we will provide you with information about whether we hold any information related to you. In our sole discretion, unless otherwise required by law, we may in some instances correct or delete information upon a verified request. In certain circumstances we may be required by law to retain your Personal Information, or may need to retain your Personal Information in order to continue providing a product or service to you or another customer.
If you would like to submit a request about your data, you may do so by contacting us at firstname.lastname@example.org requesting the Privacy Team. After you submit the request, you will be asked to verify your email address and will also be asked to provide additional information in order for us to verify your identity.
Authorized User Access to Product and Service Information. We will give you, or anyone listed as an authorized contact for your account, information about your order of Products and Services from Us. This may include information about the nature and status of your order, information you provided to process your order, payment information, and contact information. If you want someone to have access to your order, you must list them as an authorized contact or they may not obtain information. You can confirm who is listed as an authorized contact for your account, add new authorized contacts, or remove authorized contacts. We may send a confirmation email to your authorized contact(s), alerting them that they have been added as an authorized contact. For some products, we may provide information about your order to other individuals named in the order, such as the administrator of the retirement plan.
Opting Out of Promotional Email Communications. We send promotional emails and newsletters from time to time to consumers who have provided us with their email address or whose email addresses we have obtained through other sources. You can opt-out of promotional communications by using the “Unsubscribe” link and following the unsubscribe instructions in an email you receive from us or by contacting us at email@example.com. We may also send service-related or transactional communications, which are not promotional. Generally, you may not opt-out of these communications. If you do not wish to receive service-related communications, you may terminate your account by contacting us at firstname.lastname@example.org.
Opting Out of the Center’s Marketing and Promotional Calls. If you wish to be placed on our internal “Do Not Call,” list you can tell us either while speaking to us on the phone or by emailing us at email@example.com.
Opting Out of the Center’s SMS/Text Messages. If you wish to stop receiving SMS or text messages from us you can let us know by replying STOP to any SMS/text that you receive from us. You may also let us know by contacting us at firstname.lastname@example.org.
Our Data Retention. At minimum, we will retain your information for as long as needed to provide you services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may maintain some or all of this data in its archives even after it has been removed from the Site or Applications.
Information Processed On Behalf of Third Parties
In some instances, we may process Personal Information on behalf of third party affiliates and business partners. We acknowledge that in these instances, you have the right to access your Personal Information. Where we do not have a direct relationship with the individuals whose Personal Information it processes, individuals seeking access, or seeking to correct, amend, or delete inaccurate data, should direct their inquiry to the third party affiliate or business partner (i.e. the data controller).
How Secure Is the Personal Information We Collect?
Honestly, we do our best. We are constantly monitoring the integrity of our data privacy, follow up on known exploits, and strive to make certain that our servers and connections incorporate the latest encryption and informational security devices. We have implemented physical, electronic, and managerial procedures to safeguard and secure the information we collect. Credit card and Personal Information are transmitted by secure servers (TLS). Documents are delivered to you via UPS or similar delivery services, the United States Postal Service, or electronically, including through online storage platforms or email. Unfortunately, no data transmission is guaranteed to be 100% secure and we therefore cannot guarantee the security of information you transmit to or from our website or through the use of our services, and you provide this information at your own risk. ACCORDINGLY, WE DISCLAIM LIABILITY FOR THE THEFT, LOSS, OR INTERCEPTION OF, OR UNAUTHORIZED ACCESS OR DAMAGE TO, YOUR DATA OR COMMUNICATIONS BY USING OUR WEBSITE AND OUR SERVICES. YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND ASSUME THESE RISKS.
IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED PLEASE CONTACT US IMMEDIATELY AT CUSTOMERSERVICE@QDROCENTER.ORG.
Information for California Residents.
If you are a resident of California, this section provides information regarding your rights, and our responsibilities, regarding your Personal Information.
California Resident Rights
California law allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ Personal Information give consumers access to certain information. This includes the specific pieces and categories of Personal Information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared.
Consistent with California law, if you choose to exercise your rights, we will not charge you different prices or provide different quality of services unless those differences are related to your information.
How to Submit a Request for Access to Information or Deletion of Information
You can submit a request by emailing us at email@example.com.
After you submit the request you will be asked to verify your email address and may also be asked to provide additional information in order to verify your identity, including potentially providing a declaration under penalty of perjury. We will attempt to verify your identity by asking for information that correlates with the information that we have previously collected about you. Where this is not possible, we may request you submit additional information for verification, such as proof of residency or redacted government-issued identification. Please note that consistent with California law, we will be unable to satisfy your request until we have verified your identity.
You may also designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide us with written permission for the agent to make the request on your behalf or provide us with an executed power of attorney. You will also be required to submit your valid government issued-identification, and the authorized agent’s valid government-issued identification.
Information for EU Customers and Visitors.
If you are located in the European Union (“EU”), this section provides information regarding your rights, and our responsibilities, and additional information regarding the processing of your personal data.
Lawful Basis of Processing
We process personal data of persons in the EU only on very rare occasions as all of our retirement plans are based in the United States and in almost every instance the court having jurisdiction over the rights and responsibilities of the parties related to the retirement plan is located in the United States. Our processing of the personal date of persons located in the EU is outlined below.
Where multiple legal bases for processing are provided, the basis that relies on for any particular processing will be context dependent.
Purpose of Processing
(Described in the section D. above)
Legal Basis for Processing
Providing Products and Services
Performance of Contract, Consent, Legitimate Interest
Meeting Legal Requirements
Compliance with Legal Obligation
Consent, Legitimate Interest
Product Improvement and Development
The Center Operational Purposes
Consent, Legitimate Interest, Compliance with Legal Obligations
Sharing with Business Partners/ Participating Attorneys
Performance of Contract, Consent
Financial Reporting and Other Internal Uses
EU User Rights
If you are located in the EU, you have the following rights with respect to how we processes your personal data.
(1) You have the right to request a copy of the personal data that we have about you;
(2) You have the right to request that we correct the information about you if you believe it to be inaccurate;
(3) You have the right to request that we erase or refrain from using your personal data. This is not an absolute right and, in some circumstances, we may decline to erase or limit its usage of your data, such as when we have an on-going business relationship with you or we are legally required to retain the information. If we cannot honor your request, we will inform you of this fact as well as the reasons for our decision;
To exercise any of these rights, please submit the request by emailing us at firstname.lastname@example.org.
If you are located in the EU, you also have the right to raise any objections regarding the processing of your personal data and to raise any concerns you may have about how we are processing of your person data. You may make an objection or raise any other concerns by emailing us at email@example.com.
While we hope that we can resolve any of your privacy concerns to your satisfaction after you contact us directly, you also have the right to file a complaint regarding our handling of your personal data with the Information Commissioner’s Office, the UK’s independent Data Protection Authority. Their contact information is:
We Are Likely Going To Make Changes To This Policy in the Future.