- Information we collect
- How we use and share your information
- Access to your information
- Choice and OPT out
- Important disclosures, practices and contact information
Effective Date: 1/01/2014
Information we collect
We may collect different types of information, including, but not limited to, personal information, financial information, demographic information, log, Device (hereinafter defined) and aggregate data. Sometimes we collect combinations of all these types of information. In each case, when using the TruGreen Applications, it is indicated on the TruGreen Applications whether any personal or demographic data must be provided for you to access and use the TruGreen Applications and/or purchase the requested Product or Service.
Connecting With The TruGreen Applications And Information Provided By You
When You Register or Otherwise Contact Us. When you provide us with information in connection with a particular activity or otherwise sign up for or order our Products and Services or provide your contact information, including an email address or telephone number in connection with that activity, product or service, you agree that this action constitutes a purchase or inquiry establishing a business relationship with us. You expressly consent to our communicating with you about TruGreen using the information you provided to us. You also attest that you have the legal authority over any telephone number you provide to us and can provide us with the authorization to contact you. This means we may contact you, in person or by recorded message, by e-mail, telephone and/or mobile telephone number (including use of automated dialing equipment), text (SMS) message, or any other means of communication that your wireless or other telecommunications device may be capable of receiving.
Financial Information. Financial information is information that you provide to us, including your debit or credit card number and related billing information (collectively, the “Billing Information”). We require such financial information in order to process payment for the purchase of a Product or Service that you have requested. By submitting your financial information, you consent to our providing it to those Authorized Third Party Service Providers (as later defined) as necessary to support and process your transactions as well as your credit card issuer/banking institution for their purposes.
We ask that you do not enter financial information into your profile, except in the fields provided for that information.
Facebook. You may be given the option to link your Facebook account so that you can comment on the TruGreen Applications and/or our Products and Services, or take advantage of other features of the TruGreen Applications. When you comment on the TruGreen Applications using your Facebook username and password and clicking “allow” on the Facebook permission authorization screen, we will automatically import whatever information that you allow to be imported from your Facebook profile based upon your privacy settings at Facebook, such as your location, your interests, etc. (collectively, “Permitted Facebook Profile Content”) and you give us permission to capture, store, use and display your Permitted Facebook Profile Content, including syncing access to such Permitted Facebook Profile Content when you are not using TruGreen Applications and we may share that information with other users. The authentication of your Facebook login credentials are conducted solely through Facebook.
Information Collected Through Technology
In addition to any Personal Information or other information that you choose to submit to us, we and our third-party service providers may use a variety of technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs. As you use our TruGreen Applications, your browser and devices communicate with servers operated by us, our business partners and our Product and Service providers to coordinate and record the activity and fill your requests for our Products and Services and information (“Usage Information”). We collect many different types of information from cookies and other technologies. For example, we may collect information from the devices you use to access our TruGreen Applications, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. In addition, we collect your IP address or other unique identifier (“Device Identifier”) for your computer or other device used to access the TruGreen Applications (any, a “Device”). A Device Identifier is a number that is automatically assigned to the device used to access the TruGreen Applications, and our computers identify your Device by its Device Identifier. We may also collect information about the website you were visiting before you came to our TruGreen Applications and the website you visit after you leave our TruGreen Applications, if this information is supplied to us by your browser. We may use this Usage Information for a variety of purposes, including to enhance or otherwise improve the TruGreen Applications.
The information from cookies and related technology is stored in web server logs and also in web cookies kept on your Device(s), which are then transmitted back to our Site by your Device(s). These servers are operated and the cookies managed by us, our business partners or our service providers. For example, when you visit TruGreen Applications, we and our service providers may place cookies on your Device(s). Cookies allow us to recognize you when you return, and may track and target your interests in order to provide a customized experience. They also help us detect certain kinds of fraud. A “cookie” is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the AHS Applications. Some cookies contain serial numbers that allow us to connect your activity with TruGreen Applications with other information we store about you in your profile or as related to your interactions with TruGreen Applications.
Some cookies are temporary, whereas others may be configured to last longer. “Session” cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases Session cookies once you exit your browser. “Persistent” cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use Persistent cookies for a number of purposes, such as retrieving certain information you have previously provided. “Flash” cookies, known as local shared objects, are data files placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device to personalize your visit. Our third-party service providers also may use Flash cookies to collect and store information. Flash cookies are different from standard browser cookies because of the amount of, type of, and how data is stored. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our web pages. You can choose to have your computer warn you each time a Persistent or Session cookie is being sent, or you can choose to turn off such cookies through your browser settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. However, cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies, please click www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. If you choose to disable cookies on your Device, some features of the TruGreen Applications may not function properly. For instance, if cookies are disabled, you will not be able to log into the Site and therefore you will experience an anonymous user experience.
Pixel tags and web beacons are tiny graphic images placed on the AHS Applications or in our emails that allow us to determine whether you have performed specific actions. When you access the AHS Applications or open email messages, the pixel tags and web beacons generate a notice of that action to us, or our service providers. These tools allow us to measure response to our communications and improve the AHS Applications and promotions.
We also use embedded scripts which are programming codes designed to collect information about your interactions with the TruGreen Applications, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the TruGreen Applications, and is deactivated or deleted thereafter.
We use HTML5, another form of collection, in our apps for the iPhone or iPad (and any other Apple iOS device). HTML5 is another form of collection, tracking and storage that does not rely on traditional browser cookies. Like Flash cookies, HTML5 cookies can be used to track users across website but are not stored in browsers’ cookie files. To our knowledge there is currently no known way for a user of a mobile device to remove HTML5 tracking and storage.
In many cases, the information we collect using cookies and other tools is used in non-identifiable ways, without any reference to Personal Information. For example, we use information we collect about TruGreen Application users to optimize our Products and Services and understand traffic and usage patterns. In other cases, we associate the information we collect using cookies and related technologies with Personal Information. Whenever we associate Usage Information or a Device Identifier with your Personal Information, we will treat it as Personal Information.
Information You Provide About a Third Party
If you send someone else a communication from the TruGreen Applications, such as sending an invitation to a friend, the information you provide (names, e-mail addresses, etc.) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. If that person becomes a customer or registers with us, his/her information will be treated in the same manner as all other customers or registered users. Please be aware that when you use any send-to-a-friend functionality on the TruGreen Applications, your e-mail address may be included in the communication sent to your friend.
Information We Collect From Third Parties
We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as information to validate or update your address or other demographic and lifestyle information. We use this information to help us maintain the accuracy of the information we collect, to target our communications so that we can inform you of products, our Products and Services and offers that may be of interest, and for internal business analysis or other business purposes.
Third Party Analytic Technologies
How we use and share your information
We use your information, subject to applicable laws, in the following ways:
- to allow you to register and create an account and profile;
- to share your information with our franchisees, where we consider appropriate;
- to deliver, provide or process payment for a product or service you have requested;
- to enable you to provide us with feedback, to contact us and for us to contact you;
- to administer promotions you enter such as a contest or sweepstakes;
- to allow your participation in our Communications Services (where available on the TruGreen Applications);
- to allow your participation in any surveys;
- to send you maintenance communications to alert you to changes and updates in our TruGreen Applications’ policies, Products and/or Services that may affect you;
- to send you communications of interest that you have requested, such as emails or text messages about TruGreen, our Products and Services, targeted marketing, and promotional offers;
- to customize, measure and improve our Products and Services, content, and advertising, including generating internal reports about the use of our TruGreen Applications;
- to personalize your overall experience with the TruGreen Applications;
- for purposes disclosed at the time you provide your information; and
Transactional Communications. We may send you notices from time to time relating to your account or your orders. These may include order confirmations, invoices, renewals or customer service notifications. We may also send you service-related announcements when it is necessary to do so; for instance, if our Service(s) is/are temporarily suspended for maintenance, or the delivery of a Product is delayed or there is some service issue with something you may have ordered. You may not opt-out of receiving these communications, which are not promotional in nature.
Authorized Third Party Service Providers. We may use third party service providers (“Authorized Third Party Service Providers”) to help us operate our business and the TruGreen Applications or administer activities on our behalf. We may share your information with these third parties.
Electronic Promotional Offers. We may send you promotional emails regarding special offers about our Products and Services or on behalf of third party marketing partners who we think can offer services and products of interest to you. If you do not want to receive emails from us regarding special promotions or offers, or from any third party, you may opt-out as provided in the CHOICE AND OPT OUT section below.
Sharing Information With Third Parties. Subject in all cases to applicable law, we may send you offers through direct mail, email or other means that we feel might be of interest to you and/or sell, share or rent your name, mailing address, email address and certain other information, such as what you ordered, with reputable companies that provide marketing offers. If you do not want us to send you offers or share your Personal Information with other companies, you may opt-out as provided in the CHOICE AND OPT OUT section below.
Telemarketing. If you have given us your telephone number, when making an inquiry or registering with us or when ordering Products or Services from us, we may use the telephone number you provided to reach out to you to follow up on your order, including follow-up regarding renewals and marketing. If you would prefer not to receive marketing phone calls from us, you may opt-out as provided in the CHOICE AND OPT OUT section below.
Third Party Tracking and Advertising. We may allow third-party companies to serve ads and/or collect certain anonymous information when you visit the TruGreen Applications. These companies may use non-personally identifiable information (i.e. click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the TruGreen Applications and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use a cookie or third party web beacon to collect this information. If you would like more information about advertisers’ use of tracking technologies and about your option not to accept the cookies used to track your activities, you can go to www.networkadvertising.org.
Feedback. All comments, feedback or materials submitted by you to us, including feedback, testimonials, images, reviews, questions, comments, suggestions or ideas (collectively, “Feedback”), shall be received and treated by us on a non-confidential and unrestricted basis. TruGreen will be free to use, display, perform, distribute, copy, adapt, and promote, in any medium now known or later developed, without compensation to you, the Feedback along with all ideas, concepts, know-how, techniques or methodologies contained in such Feedback, for any purpose whatsoever, including without limitation, developing, marketing and selling our Products and Services incorporating such Feedback. You agree that in submitting Feedback, it will not violate any right of any third party, including any confidentiality, copyright, trademark, privacy or other personal or intellectual property or proprietary rights, and will not cause injury to any person or entity. You further agree that no Feedback you submit will be or contain libelous or otherwise unlawful, threatening, abusive or obscene material, or contain viruses, commercial solicitations, or any form of “spam”.
Sale or Transfer of Business or Assets. In the event that we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, personally identifiable information (including all Personal Information) of our customers and visitors to our TruGreen Applications may be one of the assets sold or merged in connection with that transaction. In addition, information about our customers and registered users may also be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support or funding.
Access to your information
Choice and OPT out
To opt-out of marketing communications or to request to be added to our Do Not Call List, and/or our Do Not Mail List, you may use one of these convenient methods:
Electronic Promotional Offers. If you do not want to receive emails from us or from any third party regarding special promotions or offers, you may (i) click the unsubscribe link here or in the footer of any email; (ii) email us email@example.com with “Unsubscribe Promotional Offers” in the subject line; (iii) call customer care at 1800TRUGREEN (1-800-878-4733); or (iv) mail us at the address set forth below.
Direct Mail Promotional Offers. If you do not want us to send you any promotional offers through direct mail or sell, rent or share your Personal Information with other companies so that they can send you direct mail offers about their products and services, you may: (i) email us at firstname.lastname@example.org with “Do Not Mail” in the subject line; (ii) call customer care at 1800TRUGREEN (1-800-878-4733); or (iii) mail us at the address set forth below.
Telemarketing. If you do not want to receive marketing phone calls from us, you may: (i) email us at email@example.com with “Do Not Call” in the subject line; (ii) call customer care at 1800TRUGREEN (1-800-878-4733); (iii) ask to be placed on our Do Not Call list when you receive a call from us; or (iv) mail us at the address set forth below.
Mailing Address. In all cases, you may write us at:
- Kevin E. Mann, General Counsel
- 1790 Kirby Pkwy Suite 300
- Memphis, TN 38138
Please note that even if you opt out of receiving promotional direct mail offers, we may continue to send you service notifications by direct mail that are related to your account(s) and our Products and Services you have requested or in which you are currently enrolled.
Please note also that changes may not be effective immediately. In each event, you must clearly indicate the information that you wish to have changed or clearly indicate that you wish to have your personally identifiable information (including Personal Information) removed from our database. We will endeavor to comply with your request as soon as reasonably possible. Note that despite any request for removal of or change to personally identifiable information (including Personal Information), we may need to retain certain information for recordkeeping purposes and there may also be residual information that will remain within our databases and other records, which will not be removed or changed. Finally, we are not responsible for informing third parties (including without limitation our third party service providers or strategic partners) with whom we have already shared your personally identifiable information (including Personal Information) of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities.
Important disclosures, practices and contact information
Security. We maintain physical, electronic and procedural safeguards to protect the confidentiality and security of information transmitted to us. To guard your information delivered to us electronically, the TruGreen Applications use Secure Sockets Layer (SSL). SSL encrypts your credit card number, name and address so only we are able to decode your information. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your contact information, to the extent permitted by law, we do not guarantee or warrant the security of any information you transmit to or from the TruGreen Applications, and you do so at your own risk.
We urge you to keep any password that you establish with us in a safe place and not to divulge it to anyone. Also remember to log off your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place.
Additional Privacy Notice for California Residents
Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our website has collected the following categories of personal information from its consumers within the last twelve (12) months:
A real name, Internet Protocol address, email address, or other similar identifiers.
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||YES|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete on our website.
- Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers.
We may use, or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our website. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message.
We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message through our website or write us at our address listed on our webpage.
Children’s Privacy. The TruGreen Applications are generally intended for general adult audiences and are not directed or intended for children under 13 years of age but TruGreen does have some webpages accessible from our TruGreen Applications which are intended for parents and educators to use with children under 13 years of age, such as mybotanicplanet.com. No personally identifiable information is collected from these webpages. We do not knowingly collect Personal Information from individuals under 13 years of age on any of the TruGreen Applications. If you are under 13 years of age, you should not register or provide Personal Information on the TruGreen Applications. If we later obtain actual knowledge that a user who has provided Personal Information is under 13 years of age, we will take steps to remove that user’s Personal Information from our systems.
- Kevin E. Mann, General Counsel
- 1790 Kirby Pkwy Suite 300
- Memphis, TN 38138