Privacy Policy

Effective Date: August 30, 2023

Last Updated: August 30, 2023

This Privacy Policy, which is part of our Terms of Use, describes how Holdings, LLC (“we,” “us,” or “our”) collects, uses, and discloses Personal Information (as defined below) in connection with your use of the services provided by us (the “Services”) and use of our website (“Site”).

We may change this policy from time to time and will disclose that we have a revised policy by updating the Last Updated date at the top of the policy. If we make material changes, and if we have your email address, we will also notify you by email. Please check this page when you access the services to stay informed about our information practices and the choices available to you.

  1. What Information We Collect
    1. Information: When you create an account with us, we collect information that you directly provide to us that personally identifies, relates to, describes, is reasonably capable of being associated with you, or could be linked, directly or indirectly, with a particular consumer or household (“Personal Information”), including:
      1. Identifiers and contact information such as such as name, postal address, phone number, email address, social security number (we only provide social security numbers to finance partners with your consent), or other similar identifiers;
      2. Other demographic information, such as date of birth;
      3. Commercial information, such as information about products or services purchased, obtained, or considered, or other purchasing or consuming histories and corresponding account numbers;
      4. Internet and network information such as browsing/search history, approximate geolocation, browser type, device type and settings, and information regarding an individual’s interaction with an internet website, application, or advertisement;
      5. Audiovisual information such as pictures, call recordings, and video footage; and
      6. Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (e.g., topical interests, engagement value).
    2. Usage Data: We do not collect, use, or disclose Personal Information when you use our websites. Keep in mind, however, that we automatically collect information in connection with the actions you take on our websites, including collecting the type of web browser you use, the type of device you use, your operating system, your internet provider, the pages you view, your referring and exit pages, the date and time of your visit, the number of clicks to, from, and within our websites, and the duration of your visit (“Usage Data”). We commit to maintaining and using this de-identified Usage Data without attempting to re-identify any such Usage Data. Because Usage Data is not reasonably capable of being individually associated with you, it is therefore not Personal Information. Remember, however, that:
      1. You will still receive cookies that are essential for the website to function;
      2. You will still see advertising, but it will not be targeted and may not be relevant to you; and
      3. Our data practices differ when you create an account with us.
    3. Sensitive Personal Information: We do not collect information that would be considered sensitive under any state’s laws, such as information relating to a known child, precise geolocation data, data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status.
  2. How We Collect Information
    1. Information You Provide Us: We collect Personal Information you provide directly to us. For example, we collect information when you:
      1. Create an account;
      2. Write a review;
      3. Respond to a survey;
      4. Fill out a form;
      5. Participate in a contest or promotion;
      6. Communicate with us via third-party social media sites;
      7. Request customer support;
      8. Interact with us via chat;
      9. Interact with us via telephone; or
      10. Participate in any interactive features of the Services or otherwise communicate with us.
    2. Information We Collect from Other Sources: If you create or log into your account through a social media site, we may have access to certain information from that site, such as your name, user ID, account information, information that you have made public, and friend lists, according to the social media site’s data practices and your privacy settings on that social media site. We may also collect demographic information about you from third parties, including data brokers, credit bureaus, mailing list providers, and publicly available sources.
  3. Why We Collect Information
    1. Our Purpose: We use Personal Information to provide, maintain, and improve the Services. We may also use the information we collect to:
      1. Communicate with you about products, services, offers, and events offered by us and others, and provide news and information we think will be of interest to you;
      2. Monitor and analyze trends, usage, and activities in connection with our Services;
      3. Send you technical notices, updates, security alerts and support, and administrative messages;
      4. Respond to your comments, questions, and customer service requests;
      5. Detect, investigate, and prevent security incidents, malicious, deceptive, or fraudulent transactions and other illegal activities, and protect our rights and property and that of others;
      6. Personalize and improve the Services and provide advertisements, content, or features that match user profiles or interests;
      7. Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
      8. Debug to identify and repair errors that impair site functionality;
      9. Ensure the right of another consumer to exercise their right of free speech or exercise another right provided by law;
      10. Comply with the law and our legal obligations; and
      11. Carry-out any other purpose described to you at the time the information was collected.
    2. Targeted Advertising and Profiling: We do not use your Personal Information for targeted advertising (i.e., advertisement selected based on personal data obtained over time and across nonaffiliated websites). We do not use your Personal Information for profiling (i.e., automated processing to evaluate, analyze, or predict personal aspects related to a person’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements).
  4. Disclosing Information
    1. Service Providers: We may establish a relationship with other businesses, including corporate affiliates, to provide services to us (“Service Providers”), including for:
      1. Provision of the Services;
      2. Facilitating marketing and non-marketing communications;
      3. Marketing design and development;
      4. Business analytics (both marketing and non-marketing related);
      5. Project management and collaboration;
      6. Learning management systems;
      7. IT and network administration, such as mobile application development, data storage and management, website hosting, and data security;
      8. Identity verification;
      9. Location verification;
      10. Payment processing;
      11. Professional services, such as legal and accounting;
      12. Obtaining legal records;
      13. Collection of accounts; and
      14. Other day-to-day business operations such as courier services, facilities management, and document destruction.
    2. Authorized Partners: Some brands pay us to collect reviews on their behalf, respond to their customers, and generate insights of their businesses. We refer to these brands as “Authorized Partners.” When you create an account with us and provide a review for an Authorized Partner, we may share your Personal Information, including your contact information, with such Authorized Partner. We also provide our Authorized Partner with certain Usage Data.
    3. Other Third Parties: We may disclose your Personal Information if we have a good faith belief that we are required to do so in order to comply with the law or legal process, such as in response to subpoenas, courts orders, or requests by government authorities, law enforcement authorities, courts, or regulators, including lawful requests by public authorities to meet national security or law enforcement requirements. We may also disclose your Personal Information if we believe your actions are inconsistent with our user agreements or policies, or to protect our rights, property, or safety or that of others, or if we sell, buy, merge, or partner with other companies or businesses, or sell some or all of our assets.
    4. Online Analytics and Tailored Advertising: We may allow Service Providers to provide analytics services and serve advertisements on our behalf. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services.
  5. Your Privacy Rights
    State laws may provide you with the ability to exercise certain privacy rights (your “Rights”), which you may exercise by submitting a request below. Your Rights may include the right to access and receive any Personal Information that we hold, the right to correct inaccuracies in any such Personal Information, and the right to delete such information. You may also have the right to opt out of the sale or sharing of Personal Information.
    1. Right to Know: You have the right to request twice per twelve (12) month period that we provide you with:
      1. The categories or specific pieces of Personal Information we collected about you;
      2. The categories of sources from which we collected your Personal Information;
      3. The business or commercial purpose for which we collected your Personal Information;
      4. The categories of third parties with whom we disclosed your Personal Information for a business purpose; and
      5. The categories of third parties to whom we sold your Personal Information.
      We are not permitted to provide access to specific pieces of Personal Information if the Personal Information is sensitive or creates a high risk of potential harm from disclosure to an unauthorized person.
    2. Right to Deletion: You have the right to request that we delete any Personal Information we have collected about you. We are not required to honor a deletion request if a legal exemption applies, such as if we need the information to complete a requested or reasonably anticipated service, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with our legal obligations.
    3. Right to Correction: You have the right to request that we correct inaccurate Personal Information.
    4. Right to Opt Out of the Sale of Your Personal Information: 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. You have the right to direct us to not sell your Personal Information at any time. To our knowledge, we do not sell the Personal Information of consumers under sixteen (16) years of age.
    5. Submitting A Request Regarding your Privacy Rights: To submit your request, you can contact us at 1-866-773-0221, visit the Do Not Sell My Info web form or email You may also email us to designate an authorized agent to exercise these Rights on your behalf.
    6. Authentication Process: We will send an authentication request to the email address provided and confirm the request upon receipt of your response. If you have more than one email address on record with us, you will have to initiate a separate consumer request for each email address on file.
    7. Appealing Our Determination: If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so and provide instructions for how to appeal our decision. You will have the right to appeal within a reasonable period of time after you have received our decision. Within forty-five (45) days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, we will provide you with a method for contacting the applicable Attorney General to submit a complaint.
    8. Account Cancellation: If you wish to deactivate your account, please contact us at We may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
  6. Cookies Policy

    When you visit our website, you consent to the use of cookies, and other technologies to collect and process information in accordance with this cookie policy. You may have seen a pop up asking for your consent to this policy on your first visit to our Sites. You may withdraw your consent at any time by following the instructions below.

    Information We Collect

    When you visit the Sites, our web server will temporarily record certain information from the device you use to access our Sites, the domain name or IP address of the requesting computer, the access date, the file request of the client (file name and URL), the HTTP response code and the Site from which you are visiting us, the number of bytes transferred during the connection and, if applicable, other technical information that we use and statistically evaluate for the technical implementation of the website’s use (such as delivery of the content, guaranteeing the website’s functionality and security, etc.).

    It is necessary to store and process the information referred to above for the duration of your session in order to deliver our Site content to your device. We also store some of this information in the log files of our servers. We will not combine this information with your IP address or other personal information relating to you except as disclosed below.

    We will also use the data described above to draw conclusions about your interests from your use and to adapt our Site’s offerings according to your interests (profiling) in order to make our website as user-friendly, safe and attractive as possible and thus promote the sale of Services.

    What is a Cookie?

    A browser cookie is a small piece of data that is stored on your device to help websites and mobile apps remember things about you. Other technologies, including web beacons, web storage, and identifiers associated with your device, may be used for similar purposes. In this Policy, we say “cookies” to refer to all of these technologies. Cookies allow a website to recognize a user’s device. Cookies allow you to navigate between pages efficiently, remember preferences and generally improve the user experience for you. They can also be used to tailor advertising to your interests through tracking your browsing across websites.

    Cookies are one of two variants. Session cookies are deleted automatically when you close your browser and persistent cookies remain on your device after the browser is closed (for example to remember your user preferences when you return to the website). Persistent cookies, also known as permanent cookies, are cookies that are stored on your hard drive until they expire or until you delete the cookie.

    We use the following types of cookies:

    • Essential Cookies are required to make our Site function properly and cannot be turned off in our systems. If you block these cookies, portions of our Site may not function properly.
    • Performance and Functional Cookies allow us to count visits and sources of traffic on our Website so we can measure and improve performance and functionality. They help us know which pages of our Site are most and least popular and how visitors move around the Site.
    • Targeted Advertising Cookies may be set through our Sites by our advertising partners. They may be used by advertising companies to build a profile of your interests and show you relevant advertisements on other websites.
    • Social Media Cookies allow you to share information using social media sharing buttons on social networks like Facebook, Pinterest, Instagram, or Twitter. This information may then be used by the social media network to deliver targeted advertising to you.
    We may combine information collected automatically (as described above) from your interactions with our website and your activity on third-party sites with other data (including personal information).

    Managing Cookies

    If you wish to opt out of allowing certain cookies, you may do so by changing your browser settings so that cookies from our Site cannot be set. Please note that if you delete, block, or otherwise restrict cookies, or use a different computer or Internet browser, you will need to renew your cookie management choices.

    Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

    1. (Chrome)
    2. (Firefox)
    3. (Opera)
    4. (Internet Explorer)
    5. (Safari)
    6. (Edge)
    Please note that this Cookie Policy does not apply to, and we are not responsible for, the privacy practices of third party websites which may be linked to our Sites.

    Behavioral Tracking Technologies on Our Site

    When you visit our website, we use site visit recordation technologies, to memorialize site visits, third-party cookies, beacons, tags and scripts to help collect the categories of information described above and aggregated information from your internet browser such as your behavior on our Site. You may have seen a pop up asking for your consent to the use of web session analytics and recording technologies on your first visit to our Sites.

    We as well as the third party entities use Cookies, pixels and other tracking technology (collectively, “Tracking Technology”) in connection with our Site for purposes of tracking users’ activities (such as websites visited, advertisements selected, and pages viewed) after they leave our Site. We and our third-party partners use this Tracking Technology to target applicable users with advertisements featuring our products and/or services, as well as third-party products and/or services, that may be of interest to applicable users and to collect and analyze data on visitor interactions for our website to help make the sites more useful to visitors. These technologies collect information about your interaction with the Services, including the resources that you access, pages viewed, how much time you spent on a page, and how you reached our website. We also log the details of your visits to our website and information generated in the course of using our website, such as mouse movements, scrolling, API calls, user behavior, tracking errors, links clicked, clicks, page visits, text entered, how long you spent on a page, and other details of your actions on our website.

    Some of this information is collected through cookies, web beacons, and other Tracking Technologies, which may be operated by our partners who assist us in serving ads or providing other services to you.

    We may use the following Tracking Technologies across our Site:

    • We use Google Analytics, a web analysis service provided by Google, and some similar services to better understand your use of our Sites and apps. Google Analytics collects information such as how often users visit the website, what pages they visit, and what other sites they used prior to visiting. Google uses the data to track and examine the use of the Site, to prepare reports on its activities and share them with other Google services. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. Google offers an opt-out mechanism for the web available here;
    • Critero. For more information about Criteo’s policies and practices, please see Criteo’s privacy policy at;
    • Taboola. For more information about Taboola’s policies and practices, please see Taboola’s privacy policy at;
    • Facebook. For more information about Facebook’s policies and practices, please see Facebook’s privacy policy at;
    • Tiktok. For more information about Tiktok’s policies and practices, please see Tiktok’s privacy policy at;
    • Tealium Collect. For more information about Tealium’s policies and practices, please see Tealium’s privacy policy at;
    • Bouncepilot. For more information about Bouncepilot’s policies and practices, please see Bouncepilot’s privacy policy at;
    • Navistone Global Tag. For more information about Navistone’s policies and practices, please see Navistone’s privacy policy at;
    • Navistone conversion. For more information about Navistone’s policies and practices, please see Navistone’s privacy policy at;
    • Microsoft Advertising UET. For more information about Microsoft’s policies and practices, please see Microsoft’s privacy policy at ;
    • HUMAN Security. For more information about HUMAN Security’s policies and practices, please see HUMAN Security’s privacy policy at;
    • For more information about’s policies and practices, please see’s privacy policy at

    To learn more about how you can opt out of targeted advertising on the Site, please visit the “Ad Choices” website located at Users can opt-out of certain Google®-related tracking technology, and customize the Google® Display Network ads that they receive, by visiting the Google® Ads Settings at: Google® also recommends installing the Google® Analytics Opt-out Browser Add-on for your web browser, which is available here:

    If you wish to opt-out of having this information used for the purpose of serving you interest-based ads, you may opt-out by emailing us at Further, Users may be able to opt-out of this form of tracking utilizing the options made available by the Network Advertising Initiative or Digital Advertising Alliance. Please note that opting out of this tracking activity does not opt you out of being served advertising. Even where you opt out of this tracking activity, you will continue to receive generic ads.

  7. Miscellaneous
    1. Behavioral Advertising: For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit or Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.
    2. Communications by Email or Text Message: You may opt out of receiving our promotional emails by following the instructions in those emails or by contacting us as noted herein. If you opt out, we may still send you non-promotional messages, such as those about your account or our ongoing business relationship. To opt out of receiving text messages from us at any time, reply to a text from us with the word “STOP.” A confirmation message of your opt-out will be sent to your mobile number but no additional messages will be sent to you unless you opt in again.
    3. Push Notifications/Alerts: With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device or to your desktop via your browser. You can deactivate these messages at any time by changing the notification settings within your browser or on your mobile device.
    4. Nondiscrimination Notice: We will not discriminate against any consumer for exercising their Rights.
    5. California Shine the Light Law: California's Shine the Light law permits users of our Service that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their own marketing purposes. To make such a request, or to opt out of this sharing, please see the “Contact Us” section below. You may also opt out by completing the Do Not Sell My Info web form.
    6. Jurisdiction: The Services are subject to the laws of the United States and your Personal Information is processed in the United States. The Services are only intended for use by individuals in the United States.
  8. Contact Us
    If you have any questions or concerns about your Rights, this privacy policy, a Do Not Sell request, or our data privacy practices, you can reach us at, or by writing to us at:
    297 Kingsbury Grade, Suite 1025, Mailbox 4470
    Lake Tahoe, NV 89449-4470

    You may also email us to designate an authorized agent to exercise these Rights on your behalf.