Curinos Supplemental Privacy Notice
For California and Other US Residents
Last Updated August 2025
- Overview
Curinos, Inc. and its subsidiaries (collectively “Curinos”) prepared this US Supplemental Privacy Notice (“Supplemental Notice”) to supplement the practices described in Curinos’ Online Privacy Notice, and it applies only to information collected about individuals covered by California’s Consumer Privacy Act (“CCPA”) and other similar privacy laws in the United States (collectively, “US State Privacy Laws”). This Supplemental Notice is parallel in scope to Curinos’ Online Privacy Notice and should be read in conjunction with that notice. Some portions of this Supplemental Notice apply only to consumers of particular states. In those instances, Curinos has indicated that such language applies only to those consumers. Any terms defined in the CCPA or other State Privacy Laws have the same meaning when used in this Supplemental Notice.
As used in this Supplemental Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household or device. Personal Information includes, but is not limited to, the categories of Personal Information identified below if such information identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual or household. Personal Information does not include:
- Publicly available information from government records
- De-identified or aggregated consumer information, including pseudonymized data Curinos receives from third parties
- Other information exempted from the State Privacy Laws’ scope, such as:
- Personal Information governed by certain sector-specific privacy laws, including the Gramm-Leach-Bliley Act (“GLBA”), the Fair Credit Reporting Act (“FCRA”), or the California Financial Information Privacy Act (“FIPA”).
- Health or medical information governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA).
CCPA and other State Privacy Laws grant residents certain rights regarding the Personal Information that businesses have about them. These include (a) the right to know about Personal Information categories the business collected about you in the prior 12 months, the source of such information, the purpose for collecting the information and the specific information collected about you; (b) the right to request access or deletion of your Personal Information, (c) the right to request correction of your Personal Information as well as (e) the right to direct a business to stop selling your Personal Information. While Curinos does not sell Personal Information to third parties for monetary consideration, the CCPA and other laws broadly defines “sale” and “sharing” in such a way that certain data collected on Curinos’ Site by third parties for interest-based advertising purposes may have been considered a “sale” or “sharing” under the CCPA. The categories of third parties to whom Personal Information is disclosed include advertisers and marketing partners and data analytics providers. The categories of information Curinos may share with such parties may include device information and identifiers, such as IP address, and unique advertising identifiers and cookies; usage information, such as browsing history; location information, such as city; and inference data. California residents can turn on the Global Privacy Control (“GPC”) to opt out of the “sale” or sharing of their Personal Information for each participating browser system that they use.
- Categories of Personal Information Collected and Business Purposes for Processing
Curinos collect the following categories of Personal Information for the purposes described below, as permitted by applicable law. These categories are defined by California law and represent the Personal Information that Curinos may have collected about California residents, and how it may have been shared, over the past 12 months. The business purposes for processing such information are provided below the chart. The inclusion of a category in the list below indicates only that Curinos may collect this information for certain individuals for some activities within the scope of the identified business purpose. It does not necessarily mean that Curinos collects all the information listed in a particular category for all individuals.
Curinos has shared information in each category with its affiliates and service providers for its business purposes within the last 12 months. Curinos may also receive requests for information from regulatory authorities, its auditors, and/or legal advisors. If requested from such parties, Curinos would share your Personal Information as appropriate:
Personal Information Collected Directly from Employees and Prospective Employees
CATEGORY OF PERSONAL INFORMATION | TYPES OF INFORMATION COLLECTED |
Personal Identifiers | Real name, alias, date of birth, residential address, postal address, telephone number, unique personal identifiers including online identifiers, internet protocol (IP) address, email address, Social Security number, driver’s license or state identification card number, passport number, visa information, written signature, insurance policy number, or other similar identifiers. |
Demographic Identifiers | Demographic information protected under federal law, CCPA or other State Privacy Law, including age, sex, gender, sexual orientation, racial or ethnic origin, national origin, citizenship, residency, or immigration status, marital status, health and physical or mental disability status, or military/veteran status. |
Employment Information | Employment history, occupation, position, professional licensures, salary information, professional or employment-related information, including written signatures, and other information collected from a resume or application. |
Education | Education history, including educational institutions attended, degree(s) and/or certification(s) earned, and other information collected from a resume or application. |
Financial Information | Financial information including bank account number, source of funds for the contract or policy, source of wealth, assets, or other financial information. |
Medical or Health Information | Medical information, including any information in possession or derived from a healthcare provider, healthcare service plan, pharmaceutical company, or contractor regarding an individual’s medical history, mental or physical condition, or treatment. Health insurance information including an individual’s insurance policy number or subscriber identification number, any unique identifier used by a health insurer to identify the individual, transaction information, or any information in the individual’s application and claims history. |
Internet or other Electronic Network Activity | Online identifiers, internet protocol (“IP”) address, and information regarding an individual’s interaction with our website including page visits, browsing or search history, including when browsing anonymously, or an individual’s device interaction with an internet website application or advertisement as described in our Online Privacy Policy. |
Profile Information | Inferences drawn from any of the information listed above, including creating a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
Audio/Visual Information | On-site cameras for security, video, photos, and audio recordings such as a recording of a customer service call. |
- Purposes for Which Curinos Collects Personal Information
Curinos, and its Service Providers, collect and process the Personal Information (excluding Sensitive Personal Information) described in this Supplemental Notice to:
- Operate, manage, and maintain its business
- Secure your account/ policy with us
- Respond to your inquiries and to fulfill your requests
- Use generative artificial intelligence models, including third-party external consumer data and information sources, in compliance with applicable laws and financial industry regulations, to augment our products and practices
- Maintain quality assurance, including recording audio calls or voice messaging systems
- Determine if a product or service may be suitable for you
- Support or respond to your inquiries
- Prevent fraud or other unlawful activities
- Determine the effectiveness of promotional campaigns, so that Curinos can adapt its campaigns to the needs and interests of its users
- Personalize, advertise, and market its products and services
- Comply with law, legal process, and internal policies
- Maintain records
- Exercise and defend legal claims
- Test or perform analysis, including data analytics and insights to improve its products
- Otherwise accomplish its business purposes and objectives
Curinos also collects the below categories of Sensitive Personal Information as defined under CCPA directly from Employees and Prospective Employees.
CATEGORY OF SENSITIVE PERSONAL INFORMATION | TYPES OF SENSITIVE PERSONAL INFORMATION COLLECTED |
Sensitive Personal Information / Not publicly available | Social Security number, driver’s license number, state identification card number or passport number, written signature, policy number(s), health and physical or mental disability status, racial or ethnic origin, national origin, citizenship or immigration status, sexual orientation, or physical characteristics or description. |
In addition, Curinos may use and disclose any Personal Information, including Sensitive Personal Information, that Curinos collects as necessary or appropriate to:
- Comply with laws and regulations, including applicable tax, customer due diligence (including identity verification), health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws.
- Monitor, investigate, and enforce compliance with potential breaches of Curinos’ policies and procedures and legal and regulatory requirements.
- Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons.
- Detect, investigate, and help protect against malicious, deceptive, fraudulent, or illegal activity.
- Exercise or defend its legal rights, including employees, Directors, Officers, affiliates, customers, contractors, and agents.
- Sources from Which Curinos Collects Personal Information
Curinos may collect Personal Information directly from you, as well as from its affiliates, business partners, joint marketing partners, public databases, providers of demographic data, publications, professional organizations, social media platforms, third party information providers, affiliates with whom you have a business relationship, Service Providers with which Curinos has a contractual relationship and to which you have provided your personal information, cookies and other tracking technologies, and Service Providers and Third Parties when they share the information with Curinos. Curinos also collects Personal Information, in certain instances, from data brokers and other information sources, as well as other public databases.
- Disclosure of Personal Information
Unless specifically stated, Curinos has not sold or shared Personal Information about California consumers with third parties for their own use in the past twelve months. Curinos may, however, disclose Personal Information to third parties (e.g., Service Providers) for business purposes. When Curinos discloses Personal Information for a business purpose, Curinos enters into a contract that describes the purpose and requires the recipient to ensure the information is confidential, and not to use it for any purpose other than performance of the contract. For purposes of the CCPA, a “sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. Curinos has no actual knowledge that Curinos sells or shares Personal Information of California consumers under 16 years of age. Curinos may share your Personal Information as allowed by law for the business purposes described in this Supplemental Notice with the following parties:
CATEGORY | DESCRIPTION |
Corporate Affiliates | Curinos may share your information with its corporate affiliates and with their respective officers, directors, employees, accountants, attorneys, and agents. |
Acquisitions and Similar Transactions | If Curinos is sold or part of its assets are merged with another company, your personal data may be transferred as part of the merger or sale. |
Disclosures with Your Consent | Curinos may ask if you would like it to share your information with other unaffiliated third parties not described elsewhere in this Policy. Curinos will only disclose your information in this context with your consent. |
Legal Obligations and Rights (Subpoenas, Court Orders, and Warrants); Regulatory Authorities | Curinos may disclose information to comply with the law, including disclosure to relevant industry regulatory bodies, or in response to subpoenas, warrants, court orders, or other legal process. |
Service Providers | Curinos may share your Personal Information or aggregated information with third party Service Providers for purposes such as providing operational or support services on Curinos’ behalf including servicing a contract, providing policy benefits, or to prevent, detect, and investigate deceptive, fraudulent, or illegal acts. Service Providers may include vendors providing software, platforms, or tools (including generative AI tools) to perform operational or business functions and augment Curinos’ practices. Service Providers may provide website tracking technologies such as cookies, tags, or pixels that use anonymous browsing information or Personal Information as described in Curinos’ Online Privacy Notice. |
Professional Advisors (Auditors and Legal Advisors) | Curinos may share your information with our professional advisors, including attorneys, auditors, and accountants, to provide services on its behalf. |
De-identified or Aggregated Data | Curinos may disclose aggregated information or de-identified information about our users that does not identify any specific individual. |
Other | Where required or permitted by law. |
- Data Retention
Depending on the product or service, Curinos will retain your Personal Information only for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by a law that applies to Curinos. Curinos keep records containing Personal Information in accordance with applicable state and federal rules that apply to it. Curinos considers the following criteria when determining how long to retain Personal Information: why Curinos collected the Personal Information; the nature of the Personal Information; the sensitivity of the Personal Information; our legal obligations related to the Personal Information; and the risks associated with retaining the Personal Information. Curinos aims to retain Personal Information only for as long as necessary for the purposes it was collected for, including defending or advancing legal claims, and to comply with legal obligations. Curinos may need to keep some Personal Information for longer than other information to comply with applicable laws and regulations, including litigation.
- Your Privacy Rights
Exercising Privacy Rights. Consumers who live in California have certain rights with respect to the collection and use of their Personal Information. You may access these data rights by calling or e-mailing us as set out below:
Curinos, Inc.
485 Lexington Avenue
20th Floor
New York, NY 10017
Email: privacy_support@curinos.com
Agents. Consumers in some states may also authorize an agent to make data subject requests on their behalf.
Verification of Data Subject Requests. Curinos may ask you to provide information that will enable us to verify your identity to comply with your data subject request. In particular, when a consumer authorizes an agent to make a request on their behalf, Curinos may require the agent to provide proof of signed permission from the consumer to submit the request, or Curinos may require the consumer to verify their own identity to us or confirm with us that they provided the agent with permission to submit the request. In some instances, Curinos may decline to honor your request if an exception applies under applicable law.
There are circumstances in which Curinos may not be able to comply with your access, deletion, or other request, including when Curinos cannot verify your request, or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. Additionally, in certain instances, some information Curinos collects from you may be excluded from the definition of Personal Information as defined under applicable State Privacy Laws, and, as such, this information is exempt from certain rights otherwise available to you. Curinos will respond to your request consistent with applicable law.
Non-Discrimination. Curinos will not discriminate against you for exercising your data subject rights. For example, Curinos will not deny goods or services to you, or 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. To appeal our decision on your data subject requests, you may send it to:
Curinos, Inc.
485 Lexington Avenue
20th Floor
New York, NY 10017
ATTN: Privacy Appeals
Email: privacy_appeals@curinos.com
Please enclose a copy of or otherwise specifically reference the decision on your data subject request, so that Curinos may adequately address your appeal. Curinos will respond to your appeal in accordance with applicable law.
- Right to Access Your Data. You have the right to request that Curinos disclose certain information to you about our collection and use of your Personal Information for the 12-month period preceding your request. California residents may request information for the prior 24-month period. Once Curinos receives and verifies your identity, you have the right to receive:
- The categories of Personal Information Curinos collected about you.
- The categories of sources for the Personal Information Curinos collected about you.
- The business or commercial purpose for collecting, selling or sharing that Personal Information.
- The specific pieces of Personal Information Curinos collected about you, including by a service provider or contractor.
- The categories of third parties with whom Curinos shared that Personal Information.
- The specific pieces of Personal Information disclosed for a business or commercial purpose, identifying the Personal Information categories that each category of recipient obtained about you.
- Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means you have a right to request that Curinos move, copy or transmit your Personal Information stored on its servers / IT environment to another service provider’s servers / IT environment.
- Right to Correction. You have the right to request correction or changes of your Personal Information if it is found to be inaccurate or out of date.
- Right to Delete Your Data. You have the right to request that Curinos delete any of your Personal Information that Curinos collected from you and retained, subject to certain exceptions. Once Curinos receives and confirms your verifiable consumer request, Curinos will delete (and direct its service providers to delete) your Personal Information from its records, unless an exception applies.
- Right to Opt-Out of Sale or Sharing of Personal Information. Curinos currently does not sell Personal Information to third parties or share your Personal Information with third parties for cross-context behavioral advertising purposes, and, therefore, this is inapplicable to us. Curinos may disclose Personal Information about you to its affiliates and service providers as permitted by law. Please see the “Sharing Personal Information” portion of this policy for more information.
- Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to request Curinos limit the use of your sensitive Personal Information to only purposes necessary to engage with you. This sensitive Personal Information is defined in California law, and you will find a more detailed description of what type of information this entails in the charts included above. Curinos does not use your sensitive Personal Information for purposes other than those necessary to engage with you, to aid in protecting and securing your Personal Information and its systems, to verify or maintain the quality or safety of its services and systems, or as otherwise permitted under regulations or required law.
- Right to Non-Discrimination. Curinos will not discriminate against you for exercising any of your privacy rights.
- Changes to Our US Supplemental Notice.
Curinos reserves the right to amend this US Supplemental Notice at our discretion and at any time. When Curinos makes material changes to this US Supplemental Notice, Curinos will post an updated Supplemental Notice on the Site listing the effective date of such updates.
If you have any questions or comments about this US Supplemental Notice, the ways in which Curinos collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under state privacy laws, please contact:
Curinos, Inc.
485 Lexington Avenue
20th Floor
New York, NY 10017
Email: privacy_support@curinos.com
