Supplemental Privacy Policy

Supplemental Privacy Policy for Residents of Certain U.S. States

Last Updated 01/01/2026

This Supplemental Privacy Policy for Residents of Certain U.S. States (“Supplemental Policy”) explains how Verdegard Administrators, LLC and its affiliates (collectively “Verdegard,” “our,” “we,” or “us”) collect, use, disclose, and protect personal information about residents of U.S. states with comprehensive state privacy laws that apply to Verdegard (collectively, “U.S. Privacy Laws”). Some portions of this Supplemental Policy apply only to residents of particular states. In those instances, we have indicated that such language applies only to those residents.

Please note that this Supplemental Policy does not apply to personal information we collect about consumers that is exempt from the U.S. Privacy Laws, including personal information that is subject to the Health Insurance Portability and Accountability Act (“HIPAA”), the Gramm-Leach-Bliley Act (“GLBA”), or that is otherwise exempt from the U.S. Privacy Laws. This Supplemental Policy also does not apply to individuals with whom we interact in an employment-related context. For our disclosures applicable to California residents with whom we interact in an employment-related capacity, please see our [Employee/Applicant Privacy Policy]. This Supplemental Policy also does not apply to individuals with whom we interact in a business-related capacity who are not residents of California.

If you have a disability and need to access this policy in an alternative format, please contact us using the contact information provided at the end of this Supplemental Policy.

Definitions

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
“Sell,” “Sale,” or “Sold” means renting, releasing, or transferring an individual’s personal information to a third party for money or other valuable consideration.
“Share,” “Shared,” or “Sharing” means transferring an individual’s personal information to a third party for cross-context behavioral advertising or targeted advertising purposes, whether or not for money or other valuable consideration.
“Third Party” means any non-affiliated person that is not a vendor.
“Vendor” means a service provider, contractor, or processor that collects, stores, or otherwise handles data for us and is bound by contractual obligations to use your personal information only as directed by us.

You may be familiar with different terms that are used to describe materially similar concepts in this section by the U.S. Privacy Laws in your state of residence. You can treat them as the same for the purpose of our Supplemental Policy. For example, we intend the term “personal information” here to have the same definition as “personal data” used in specific U.S. Privacy Laws.

Personal Information We Collect

We, and our vendors, collect, and have collected in the past 12 months, the following categories of personal information about you:

Contact details, such as name, account name, email address, postal address, and telephone number.
Audio/electronic recordings, such as recordings of customer service calls.
Geolocation data, such as device location.
Internet or other network information, such as internet protocol address, browser type, browser version, and other unique identifiers, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, and the content you have accessed.
Professional or employment-related We do not collect sensitive personal information that is subject to the U.S. Privacy Laws., such as work history and current employment.
Inferences drawn from any of the information listed above to create a profile about you reflecting your preferences, characteristics, behavior, and attitudes.

We do not collect sensitive personal information that is subject to the U.S. Privacy Laws.

Purposes for Processing & Disclosing Personal Information

We, and our vendors, collect, process, and disclose the personal information described in this Supplemental Policy to:

Operate our Services, including to provide website features and functionality.
Provide you the information and services you request when you use the Services.
Customize your experience when you use our Services. For example, we may provide you with content based on your interests, requests, and location.
Improve our products or services, develop new products and services, perform quality control activities, and conduct data analytics.
Provide account management and customer service.
Tell you about our products or services that may be of interest to you.
Send service-related and marketing-related notices about our Services to you, which may include sending emails or text messages at the mobile device number you give us.
Detect and respond to fraud, violations of our Terms of Use, violations of law, or other misuse of the Services.
Perform accounting, audit, and other internal functions, such as internal investigations.
Comply with law, legal process, and internal policies.
Maintain records.
Exercise and defend legal claims.
Otherwise accomplish our business purposes and objectives.

When permitted by applicable law, we may also combine the information you provide us with other information obtained or held by us, and use that combined information for any of the above purposes.

We may also aggregate and/or de-identify personal information and analyze those data for statistical or any other purposes permitted by law. When we do so, we take reasonable measures to ensure that the information cannot be associated with an individual, and we maintain and use the information in deidentified form. After it has been de-identified, the information is no longer personal information and is not subject to this Supplemental Policy.

We also do not process personal information for purposes of profiling or to engage in automated decision making in furtherance of decisions that produce legal or similarly significant effects (which means a decision that results in the provision or denial of financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, health-care services, or access to essential goods or services).

Retention of Personal Information

We retain the personal information we collect for the period reasonably necessary to provide goods and services to you and for the period reasonably necessary to support our business operational purposes listed above.

Sale, Sharing, & Targeted Advertising

We sell, share, and process for targeted advertising purposes personal information collected via cookies and other tracking technologies (collectively, “Cookies”) regarding your interactions with our Services, and we have sold and shared such personal information in the past 12 months. We may sell and share such information to third parties, such as marketing and analytics providers, for the following purposes: to market and advertise our products and services, and for data analytics, including to better understand our audiences, evaluate interest in our Services, and improve our Services. We do not otherwise “sell,” “share,” or process for “targeted advertising” purposes other types of personal information we may collect about you.

Consumers have the right to opt-out of the sale, sharing, and processing for purposes of targeted advertising of their personal information and can submit a request to opt out by clicking the green cookie icon in the bottom right of our websites, selecting “Do Not Sell or Share My Personal Information,” and then clicking “Save My Preferences.”

We do not have actual knowledge that we sell or share personal information of consumers who are under 16 years of age.

Disclosure of Personal Information

We disclose, and have disclosed in the past 12 months, the categories of personal information listed above in the following contexts:

To our vendors. We may disclose personal information we collect to our vendors who help with our business activities. We require our vendors to keep your personal information secure and use it only as we permit.
To marketing and analytics providers. We may disclose personal information we collect via our Services to third parties for marketing and analytics purposes. For more information about these disclosures and details about how to opt out, please see the “Sale, Sharing, & Targeted Advertising” section, above.
To any other third party with your prior consent. We disclose personal information with your consent if we obtain it from you in a particular context.

We may also disclose personal information in the following contexts:

As part of a business transfer. We may disclose personal information to a successor organization if, for example, we transfer the ownership or operation of all or a portion of our Services to another organization, we merge with or are acquired by another organization, or if we liquidate our assets. If such a transfer occurs, we will seek assurances that the successor organization will treat the personal information we disclose to it in accordance with this Supplemental Policy.
To comply with laws and protect our rights and the rights of others. We may disclose personal information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. Relatedly, we may disclose personal information to auditors, lawyers, or other business consultants or advisors for legal compliance-related purposes. We may also disclose personal information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our Services; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property, or safety of our users or others.

We may also disclose aggregated and/or de-identified information to our vendors and to third parties for our business operational purposes and for any other purposes permitted by applicable law.

Sources from Which We Collect Personal Information

We collect personal information about you in three ways: (1) information you provide when you interact with us; (2) information collected from other sources, such as from our vendors and from third parties, in connection with our Services; and (3) information passively collected from you when using our Services.

Directly From You. Verdegard collects personal information you provide to us when you use our websites or when you otherwise interact with us.
From Vendors & Third Parties. Verdegard also collects personal information from our vendors and from third parties who disclose personal information to us.
Via Cookies & Other Tracking Technologies. Verdegard collects personal information passively via cookies and other tracking technologies. This typically includes information about our website visitors, such as your browsing information, usage information, and device information.

Data Subject Rights

Residents who reside in states with U.S. Privacy Laws have the following rights regarding our collection and use of their personal information, subject to certain exceptions. Please read this section carefully as some rights vary by state.

Rights that Require Verification. You may exercise the data subject rights below by contacting us via phone at +1 (888) 811-8944 or via our contact form and submitting details regarding your request. You may also authorize an agent to make data subject requests on their behalf. In such instances, authorized agents may use the same methods as you to submit the requests on your behalf. To verify your identity and protect your personal information, we may ask the requestor to provide information that will enable us to verify your identity in order to comply with your data subject request, such as asking your agent to provide proof of signed permission from you, or asking you to confirm with us directly that you provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.
- Right To Know: You have the right to know the following details about our privacy practices at or before the point of collection. We have provided such information in this Supplemental Policy. You may also request that we provide you with information about the following aspects of how we have handled your personal information specifically in the 12 months preceding your request:
  - The categories of personal information we have collected about you;
  - The categories of sources from which we collected such personal information;
  - The business or commercial purpose for collecting, selling, or sharing personal information about you;
  - The categories of personal information about you that we disclosed and the categories of third parties to whom we disclosed such personal information;
  - The categories of personal information about you that we sold, shared, or used for targeted advertising purposes, and the categories of third parties with whom we sold or shared such personal information;
  - If we collect sensitive personal information, the categories of sensitive personal information to be collected, the purposes for which it is collected or used, and whether that information is sold or shared;
  - The length of time we intend to retain each category of personal information, or if that is not possible, the criteria used to determine that period.
- Right to Deletion: You may request that we delete any personal information about you we that we collected from or about you, depending on your state of residence.
- Right to Correction: You may request that we correct any inaccurate personal information we maintain about you.
- Right to Access Specific Pieces of Personal Information and Data Portability: You may ask to obtain the specific pieces of personal information we have collected about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the personal information to another entity without hindrance. You may not exercise this right more than two times in a calendar year.
Rights that Do Not Require Verification.
- Right To Opt-Out Out of the Sale, Sharing, & Use of Your Personal Information for Targeted Advertising: You have the right to opt-out of the sale, sharing, and use of your personal information for targeted advertising purposes. You may exercise these rights by clicking the green cookie icon in the bottom right of our websites, selecting “Do Not Sell or Share My Personal Information,” and then clicking “Save My Preferences.”
Opt-Out Preference Signals. We recognize opt-out preference signals that we are required to recognize for compliance with applicable law. Where required by U.S. Privacy Laws, we treat such opt-out preference signals as a valid request to opt-out of sale, sharing, and processing for purposes of targeted advertising, as applicable, for the browser or device through which the signal is sent and any consumer profile we have associated with that browser or device, including pseudonymous profiles. Further, if we know the identity of the consumer from the opt-out preference signal, we will also treat the opt-out preference signal as a valid request to opt out of sale and sharing for such consumer. Consumers may use opt-out preference signals by downloading or otherwise activating them for use on supported browsers and setting them to send opt-out preference signals to websites they visit. Please note, however, that our websites do not currently respond to the “Do Not Track” signal.
Non-Discrimination. We will not discriminate or otherwise retaliate against you for exercising your data subject rights. For example, we will not deny goods or services to you, 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. Residents of certain states have the right to appeal our decisions on their data subject requests. To appeal our decision on your data subject requests, you may contact us. Please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.

Other Disclosures

Residents Under Age 18. If you are under the age of 18 and a registered user of our website, you may ask us to remove content or data that you have posted to the website by contacting us. Please note that your request does not ensure complete or comprehensive removal of the content or data as, for example, some of your content or data may have been reposted by another user.
Disclosure for California Residents
- Direct Marketing. California Civil Code § 1798.83 permits California residents to annually request certain information regarding our disclosure of personal information to other entities for their direct marketing purposes in the preceding calendar year. We do not disclose personal information, as defined by California Civil Code § 1798.83, to third parties for their direct marketing purposes.
- Financial Incentives for California Residents. We do not provide financial incentives to California residents who allow us to collect, retain, sell, or share their personal information. We will describe such programs to you if and when we offer them to you.

Changes and Updates

We reserve the right to amend this Supplemental Policy in our discretion and at any time. When we do so, we will post the revised version of this Supplemental Policy on this page and provide any additional notice as required by applicable law. For your convenience, whenever this Supplemental Policy is changed, we will update the “Last Updated” date at the top of this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us.

You may also write to us at:

Verdegard Administrators, LLC
Attention: Privacy Officer
8060 S. Kyrene Road, Suite 100
Tempe, AZ 85284