QuinStreet Privacy Notice
Last Updated: December 16, 2019
CloudControlMedia is a wholly-owned, independently operated subsidiary of QuinStreet, Inc. QuinStreet, Inc. owns and operates each website that displays this Privacy Notice (each, a “Site”). QuinStreet is a publicly-traded company (Nasdaq: QNST; http://www.quinstreet.com) that operates in a variety of industry categories.
Your privacy is important to us. We created this Privacy Notice to explain how we collect, use, and share the information that we collect from and about you.
Choices and Access
Information for California Consumers
Information for European Consumers
Changes to This Privacy Notice
Data You Provide: We collect data that you provide to us when you interact with the Site or sites owned by third-parties with whom we have contractual relationships, including sites you visit prior to coming to this Site (“Media Partners”). In most cases when you come to the Site we will automatically gather or receive technical data about your prior journey, device and how you interact with our Site (“Technical Data”). Technical Data may include browser type, referrer URL, date and time of your visit, IP address, MAC address, device type, screen resolution, and OS version. Technical Data also includes “Cookie and Similar Data” described below.
We gather additional data if you elect to engage with the Site or certain sites owned by our Media Partners. This includes contact information you elect to provide (e.g., name, address, email address, telephone number) about yourself or third parties to us and our Media Partners. (For example, if you elect to click on one of our advertisements on a Media Partner’s site that Media Partner may pass your contact information to us). We refer to the information you elect to provide as “Provided Attributes.” In addition to contact information, Provided Attributes include age, gender, occupation, and education level. The Provided Attributes we collect are based upon the product and services you are inquiring about.
Third Party Data: In some cases, we may augment the Technical Data and any Provided Attributes with Third Party Data. “Third Party Data” includes information from third parties such as credit reporting agencies. (We will only obtain credit reporting information with your consent, and will not retain any Social Security number you provide). Third Party Data may also include information intended to validate the data you provide (e.g., phone number, Vehicle Identification Number, outstanding loan amount). Finally, Third Party Data may include instances where you authorize us to use social media account information to log into or connect to this Site. We may combine the Technical Data, Provided Attributes and Third Party Data.
Cookie and Similar Data: When you use this Site, we may recognize you or your device through use of a “cookie” or other tracking technology. These technologies act as unique identifiers and allow us to tailor this Site to your specified interests and track your activity on this Site. This information may be added to your user profile and used to deliver offers and advertisements that we believe are relevant to your interests.
We use the data we collect from and about you through this Site primarily to connect you with Advertising Partners who can provide you with information about the products and services you are seeking. We generally do this using Technical Data and Provided Attributes, but in certain cases (e.g. lending products) we may also use Third Party Data.
For example, we may have an auto insurance Partner who is only licensed in certain states. We may use Technical Data or Provided Attributes to determine if you are a resident of one of those states. We refer to Advertising Partner requirements generally as “segmentation” and the alignment of consumer data and segments as “matching.”
We may also use the data we collect from and about you to (i) respond to your requests (e.g., receive white papers, email, phone calls or texts); (ii) to keep you informed of our products and services (and those of our Partners); (iii) to allow you to send message through this Site; (iv) to improve our Sites and business; (v) to fulfill any purchase you make; and (vi) to use your data in an aggregated, non-specific format for analytic and demographic purposes. We use Technical Data to monitor this Site’s performance, analyze traffic patterns and usage, ensure that this Site and any transactions function properly, and gather demographic information about our user base as a whole. We may use automated decision-making in segmentation and matching.
In addition to the primary Data Use described above (i.e., sharing your data with Advertising Partners and third parties for the purpose of providing you with information about the products and services you are seeking), we may share your data as follows: (i) with other QuinStreet businesses; (ii) with service providers who assist us in compliance and verification activities (e.g., credit agencies), or provide services such as payment processing, IT, and data analysis; (iii) if you choose to send a message through, or contribute to public areas of, this Site (e.g., message boards, blogs); and (iv) with a third party in the event of a sale or transfer of all or part of our business.
We may also disclose the data we collect from and about you to (i) comply with legal processes; (ii) to respond to lawful requests from authorities (including public and government authorities outside your country of residence, and including to meet national security or law enforcement requirements); (iii) to enforce our Terms of Service and this Privacy Notice; (iv) to protect our business, rights, privacy, safety, or property or that of others; and (v) as necessary under applicable law (including laws outside your country of residence).
We have taken certain physical, technical, and administrative steps to protect the data we collect form and about Site users. We use commercially reasonable efforts to encrypt sensitive data such as credit card number and personal health data. We use certain reasonable security measures to help protect your personal information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us. You use the Site and provide us with your data at your own risk. If we share data as detailed in this Privacy Notice with a third party we will use all reasonable efforts to ensure that they keep the information secure and only use the information consistent with the terms of this Privacy Notice.
We do not knowingly collect, use, or share the personal data of children under the age of 13 and this Site is not directed to individuals under 13. If we are made aware that we have collected personal data from an individual under age 13 we will delete this information as soon as possible.
Choice and Access
Residents of certain countries, including European Union member states (and the United Kingdom), may have additional rights listed under “Information for European Consumers” below.
Marketing Emails: To stop receiving marketing emails from us, please click here and follow the instructions to unsubscribe. Even if you unsubscribe, we may still send administrative (i.e., non-marketing) messages. To unsubscribe from a third party’s communications, contact that third party directly or follow the instructions to unsubscribe in the applicable marketing email.
Phone Calls and Texts: To opt out of receiving telephone calls or texts from us, please click here and follow the instructions to be placed on our Do Not Call list.
Please note that we will not be able to remove your data from third parties’ databases, and you will need to contact them directly and/or use any available opt-out mechanisms.
In general, we will retain your data for as long as is needed to connect you with Advertising Partners who can provide you with information about the products and services you are seeking, which is typically 30-180 days. We will typically retain an archived copy of your data for six years as required or permitted by law for legal and compliance purposes.
Information for California Consumers
The California Consumer Privacy Act (“CCPA”) affords certain rights and protections to California residents. This section is intended to further describe (i) the categories and sources of data that QuinStreet collects, sells or shares; (ii) the purpose for collection; (iii) the types of third parties to whom QuinStreet discloses that information; and (iv) details about how California residents can exercise their rights under the CCPA.
Categories of Data QuinStreet Collects. QuinStreet collects the following CCPA categories of data: (i) identifiers, such as a name, email address, telephone number, postal address, unique personal identifier, online identifier, IP address, account name, Social Security number, driver’s license number; (ii) personal identifiers under Cal. Civ. Code § 1798.80(e), such as insurance policy number, education, employment status, bank account information, credit card or debit card number, financial information, medical information, health insurance information; (iii) protected classification characteristics under California law, such as age, marital status, medical condition, gender, veteran or military status; (iv) commercial information, such as products or services obtained, or considered, or other purchasing or consuming histories or tendencies; (v) internet activity, such as browsing history and search history information; (vi) geolocation data; (vii) professional or employment information, such as consumer-reported current or past job history; (viii) inferences drawn from some of the information above (e.g., email open rates and time).
QuinStreet generally collects the above data as Technical Data or Provided Attributes. For example, QuinStreet does not create user profiles to determine the gender, marital status or employment status of consumers. QuinStreet receives each of those categories of data only as self-reported data from the consumer.
QuinStreet: QuinStreet collects Technical Data and Provided Attributes from consumers who land on or engage with our Sites, our call centers or other QuinStreet owned-properties (e.g., in response to emails from or on behalf of QuinStreet).
Partners and Third Parties: Consumers who visit websites owned by our Media Partners may be redirected to our Sites. In some cases, we may gather data directly from Media Partner websites, or Media Partners or other third parties may post data to our Sites or otherwise transfer data to us. This may occur via display ads, click listings, inquiry forms or telephonic transfers from Media Partner call centers. Our Advertising Partners may also provide us with data.
Service Providers: QuinStreet engages service providers to perform a variety of functions (e.g., verifying consumer consent, validating email addresses or phone numbers).
Authorization: We require all parties from whom we receive data, whether they are Partners, Service Providers or other third parties, to represent and warrant to us that they have appropriately obtained the data provided to us and have the authority to share the data with us.
Purpose for Data Collection. As described above in “Data Use,” QuinStreet primarily uses the data it collects to connect consumers with Advertising Partners who can provide information about the products and services those consumers are seeking.
Categories of Third Parties with Whom QuinStreet Discloses Personal Data. In addition to the sharing for the primary use described in “Data Sharing,” we may share your data with other QuinStreet businesses, service providers, and third party websites.
Categories of Data Sold. As described above in “Data Use” and “Data Sharing,” QuinStreet may transfer Technical Data, Provided Attributes and Third Party Data to Advertising Partners who can provide the consumer with information about the products and services they are seeking. We may receive a fee for the transfer of that data or when the consumer purchases a product or service.
CCPA Rights. The CCPA affords certain rights and protections to California residents including: (i) the right to request that we delete any “personal information” that we have collected from you (“Right to Delete”); (ii) the right to request that we disclose the categories and/or specific pieces of personal information collected and sold (“Right to Know”); and (iii) the right to direct us not to sell their “personal information” (“Right to Opt-Out”). “Personal information” is defined under the CCPA as “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.”
California residents who would like to submit a Request to Know, Delete, or Opt-Out should follow the links below. You may also submit a Request to Know by calling our toll-free number (844)-872-7854. Upon submission, you will be asked to verify your email address. If we are able to verify your Request to Know or Delete, (e.g., that you are a California resident and that we have or have sold, as the case may be, your “personal information”), we will respond within 45 days of your submission (or such additional time period as the law allows us).
Information for European Consumers
Our Site and business are operated in the United States. If you are located outside of the United States any data you provide will be transferred to and processed in the United States. For residents of the European Union (and the United Kingdom), QuinStreet, Inc., is the data controller for your data collected under this Privacy Notice. We process your data pursuant to your consent, where legally required to do so, or where we have a legitimate interest, such as using your data for fraud prevention, analytics or to improve our Sites and business, and for our marketing purposes.
In addition, you have the following rights with respect to the data collected from and about you on this Site: (i) the right to request access to such data; (ii) the right to request the correction, erasure, and restriction of processing of such data; (iii) in some instances, the right to object to the processing of such data; (iv) in some instances, the right to request that QuinStreet export, in a structured, commonly used, and machine readable format, and transmit to another controller, such personal data; (v) the right to withdraw, at any time, any consent to the processing of such personal data.
To exercise these rights please use the “Contact Us” mechanism provided below.
Changes to this Privacy Notice
We may amend this Privacy Notice from time to time. When we do, we will post an updated version of the Privacy Notice and revise the “LAST UPDATED” date at the top. We will provide appropriate notice to you if we change the Privacy Notice in any material way. Using this Site after any changes are made means you accept those changes and the revised Privacy Notice.
For purposes of this Privacy Notice, “you” or “your” means the person(s) using this Site or the products or services offered through this Site. “QuinStreet,” “us,” or “we” includes (but is not limited to) QuinStreet, Inc., QuinStreet Media, Inc., QuinStreet Insurance Agency, Inc., QuinStreet Properties, Inc. and QuinStreet PL, Inc. QuinStreet, Inc. is the party responsible for this Privacy Notice and compliance with it.
You have the right to submit feedback about this Privacy Notice, or the practices described in it, to the applicable supervisory authority in your jurisdiction of residence. For U.S. residents this includes the Federal Trade Commission and your state Attorney General. For Non-U.S. residents this includes the Data Protection Authority in your country of residence.
If you have any questions about this Privacy Notice please submit an inquiry at the Contact Us page, here, and select “Other Consumer Issues” or by mail at:
Privacy Notice Questions
c/o QuinStreet, Inc. [Legal Department]
950 Tower Lane, 6th Floor
Foster City, CA 94404