Trajector Detailed US Privacy Notice

Information for US Residents 

Information for US Residents

We collect Personal Data from US residents and comply with the consumer privacy laws of California, Colorado, Connecticut, Utah, and Virginia (“US Privacy Laws”). This Detailed US Privacy Notice applies to US residents (“users,” “you,” or “your”).

For the purposes of this Detailed US Privacy Notice, “Personal Data” means information that is linked or reasonably linkable to a particular individual or household. However, the following categories of information are not Personal Data:

  • Publicly available information;
  • Deidentified or aggregated data; or
  • Information otherwise excluded from the scope of US Privacy Laws.

This Privacy Notice provides the following information to US residents:

  • Categories of Personal Data we collect;
  • Purposes for which we use Personal Data;
  • Categories of Personal Data we disclose to third parties;
  • Categories of third parties to which we disclose Personal Data; and
  • How US residents can exercise their rights under US Privacy Laws:
    • The rights to access, correct, or delete Personal Data;
    • The right to obtain a portable copy of Personal Data;
    • The right to limit the use of sensitive Personal Data in certain circumstances;
    • The rights to opt out of targeted advertising, sales of Personal Data, or profiling; and
    • The right to appeal our decisions about your requests.

Categories of Non-Sensitive Personal Data

The table below outlines the non-sensitive categories of Personal Data Trajector collects about US residents and whether and how they are disclosed to third parties.

We collect Non-Sensitive Personal Data from the following sources:

  • Directly from our users
  • From our affiliates (“affiliates” are businesses that share common ownership with Trajector)
  • From our business partners (“business partners” are companies that we have a pre-existing commercial relationship with)
  • From our advertising partners
Category of Personal Data:

Identifiers

Examples
Identifiers may contain the following: name, address, social security number, driver’s license number, email address, telephone number, date of birth
Purpose(s) for Collection
Providing medical consulting services, providing representation before the Social Security Administration, and conducting internal research and development to improve these services.
Targeted Advertising
We do not engage in targeted advertising or disclose this information for targeted advertising purposes
Sale
This information may be sold to Affiliates and Business Partners. We sell Identifiers in order to serve our customers when they direct us to provide the data to an affiliate or business partner which offers services that might benefit the customer.
Other Disclosures
This information may be disclosed to Processors, Affiliates, and Business Partners. We disclose Identifiers to provide the contracted services including representation before the Social Security Administration, to enable our processors to provide customer service on our behalf, to debug our products and identify errors that may impair functionality, to conduct research and development to improve our existing services, and to enable our affiliates and business partners to provide customer service to consenting clients.
Retention Period
We typically retain client data for a period of six years to protect our clients’ interests and to comply with state or federal regulations or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services.

 

Category of Personal Data:

Personal Characteristics

Examples
Personal Characteristics may contain the following: age, gender, height, weight
Purpose(s) for Collection
Providing medical consulting services, providing representation before the Social Security Administration, and conducting internal research and development to improve these services.
Targeted Advertising
We do not engage in targeted advertising or disclose this information for targeted advertising purposes
Sale
This information may be sold to Affiliates and Business Partners. We sell Personal Characteristics in order to serve our customers when they direct us to provide the data to an affiliate or business partner which offers services that might benefit the customer.
Other Disclosures
This information may be disclosed to Processors, Affiliates, and Business Partners. We disclose Personal Characteristics to provide the contracted services including representation before the Social Security Administration, to enable our processors to provide customer service on our behalf, to debug our products and identify errors that may impair functionality, to conduct research and development to improve our existing services, and to enable our affiliates and business partners to provide customer service to consenting clients.
Retention Period
We typically retain client data for a period of six years to protect our clients’ interests and to comply with state or federal regulations or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services.

 

Category of Personal Data:

Commercial Data

Examples
Commercial Data may contain the following: statements from clients regarding ownership of assets and income
Purpose(s) for Collection
Providing medical consulting services and providing representation before the Social Security Administration
Targeted Advertising
We do not engage in targeted advertising or disclose this information for targeted advertising purposes
Sale
This information may be sold to Affiliates and Business Partners. We sell Commercial Data in order to serve our customers when they direct us to provide the data to an affiliate or business partner which offers services that might benefit the customer.
Other Disclosures
This information may be disclosed to Processors, Affiliates, and Business Partners. We disclose Commercial Data to provide the contracted services including representation before the Social Security Administration, to enable our processors to provide customer service on our behalf, to debug our products and identify errors that may impair functionality, to conduct research and development to improve our existing services, and to enable our affiliates and business partners to provide customer service to consenting clients.
Retention Period
We typically retain client data for a period of six years to protect our clients’ interests and to comply with state or federal regulations or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services.

 

Category of Personal Data:

Internet/Electronic Activity

Examples
Internet/Electronic Activity may contain the following: cookie ID, device ID
Purpose(s) for Collection
To optimize marketing
Targeted Advertising
We do not engage in targeted advertising or disclose this information for targeted advertising purposes
Sale
This information is not sold to third parties
Other Disclosures
This information is not otherwise disclosed to third parties
Retention Period
We typically retain client data for a period of six years to protect our clients’ interests and to comply with state or federal regulations or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services.

 

Category of Personal Data:

Imprecise Geolocational Data

Examples
Imprecise Geolocational Data may contain the following: IP address
Purpose(s) for Collection
To optimize marketing and comply with relevant state laws
Targeted Advertising
We do not engage in targeted advertising or disclose this information for targeted advertising purposes
Sale
This information is not sold to third parties
Other Disclosures
This information is not otherwise disclosed to third parties
Retention Period
We typically retain client data for a period of six years to protect our clients’ interests and to comply with state or federal regulations or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services.

 

Category of Personal Data:

Professional Data

Examples
Professional Data may contain the following: statements from clients as to employment history, statements as to income
Purpose(s) for Collection
Providing medical consulting services, providing representation before the Social Security Administration, and conducting internal research and development to improve these services.
Targeted Advertising
We do not engage in targeted advertising or disclose this information for targeted advertising purposes
Sale
This information may be sold to Affiliates and Business Partners. We sell Professional Data in order to serve our customers when they direct us to provide the data to an affiliate or business partner which offers services that might benefit the customer.
Other Disclosures
This information may be disclosed to Processors, Affiliates, and Business Partners. We disclose Professional Data to provide the contracted services including representation before the Social Security Administration, to enable our processors to provide customer service on our behalf, to debug our products and identify errors that may impair functionality, to conduct research and development to improve our existing services, and to enable our affiliates and business partners to provide customer service to consenting clients.
Retention Period
We typically retain client data for a period of six years to protect our clients’ interests and to comply with state or federal regulations or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services.

 

Category of Personal Data:

Educational Data

Examples
Educational Data may contain the following: client statements as to educational history
Purpose(s) for Collection
Providing medical consulting services and providing representation before the Social Security Administration
Targeted Advertising
We do not engage in targeted advertising or disclose this information for targeted advertising purposes
Sale
This information may be sold to Affiliates and Business Partners. We sell Educational Data in order to serve our customers when they direct us to provide the data to an affiliate or business partner which offers services that might benefit the customer.
Other Disclosures
This information may be disclosed to Processors, Affiliates, and Business Partners. We disclose Educational Data to provide the contracted services including representation before the Social Security Administration, to enable our processors to provide customer service on our behalf, to debug our products and identify errors that may impair functionality, to conduct research and development to improve our existing services, and to enable our affiliates and business partners to provide customer service to consenting clients.
Retention Period
We typically retain client data for a period of six years to protect our clients’ interests and to comply with state or federal regulations or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services.

Categories of Sensitive Personal Data

The table below outlines the categories of Sensitive Personal Data Trajector collects about US residents and whether they are disclosed to third parties. Trajector obtains affirmative consent from US residents to process Sensitive Personal Data to the extent required by US Privacy Laws.

We collect Sensitive Personal Data from the following sources:

  • Directly from our users
  • From our affiliates (“affiliates” are businesses that share common ownership with Trajector)
Category of Sensitive Personal Data:

Government ID Data

Examples
Government ID Data may contain the following: Social Security number, driver’s license
Purpose(s) for Collection
Providing medical consulting services, providing representation before the Social Security Administration, and conducting internal research and development to improve these services.
Targeted Advertising
We do not engage in targeted advertising or disclose this information for targeted advertising purposes
Sale
This information may be sold to Affiliates and Business Partners. We sell Government ID Data in order to serve our customers when they direct us to provide the data to an affiliate or business partner which offers services that might benefit the customer.
Other Disclosures
This information may be disclosed to Processors, Affiliates, and Business Partners. We disclose Government ID Data to provide the contracted services including representation before the Social Security Administration, to enable our processors to provide customer service on our behalf, to debug our products and identify errors that may impair functionality, to conduct research and development to improve our existing services, and to enable our affiliates and business partners to provide customer service to consenting clients.
Retention Period
We typically retain client data for a period of six years to protect our clients’ interests and to comply with state or federal regulations or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services.

 

Category of Sensitive Personal Data:

Sensitive Category Data

Examples
Sensitive Category Data may contain the following: race and health data
Purpose(s) for Collection
Providing medical consulting services, providing representation before the Social Security Administration, and conducting internal research and development to improve these services.
Targeted Advertising
We do not engage in targeted advertising or disclose this information for targeted advertising purposes
Sale
This information may be sold to Affiliates and Business Partners. We sell Sensitive Category Data in order to serve our customers when they direct us to provide the data to an affiliate or business partner which offers services that might benefit the customer.
Other Disclosures
This information may be disclosed to Processors, Affiliates, and Business Partners. We disclose Sensitive Category Data to provide the contracted services including representation before the Social Security Administration, to enable our processors to provide customer service on our behalf, to debug our products and identify errors that may impair functionality, to conduct research and development to improve our existing services, and to enable our affiliates and business partners to provide customer service to consenting clients.
Retention Period
We typically retain client data for a period of six years to protect our clients’ interests and to comply with state or federal regulations or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services.

 

Category of Sensitive Personal Data:

Health Data

Examples
Health Data may contain the following: diagnosis, test results, family history, and treatment
Purpose(s) for Collection
to provide the contracted services including representation before the Social Security Administration, to enable our processors to provide customer service on our behalf, to debug our products and identify errors that may impair functionality, to conduct research and development to improve our existing services, and to enable our affiliates and business partners to provide customer service to consenting clients.
Targeted Advertising
We do not engage in targeted advertising or disclose this information for targeted advertising purposes
Sale
This information may be sold to Affiliates and Business Partners. We sell Health Data in order to serve our customers when they direct us to provide the data to an affiliate or business partner which offers services that might benefit the customer.
Other Disclosures
This information may be disclosed to Processors, Affiliates, and Business Partners. We disclose Health Data to provide the contracted services including representation before the Social Security Administration, to enable our processors to provide customer service on our behalf, to debug our products and identify errors that may impair functionality, to conduct research and development to improve our existing services, and to enable our affiliates and business partners to provide customer service to consenting clients.
Retention Period
We typically retain client data for a period of six years to protect our clients’ interests and to comply with state or federal regulations or to comply with professional ethics rules; in response to a request to delete a client file we will delete all data that is not required to be preserved by law or ethics or by business necessity, such as to perform collections or other contracted services.

Use of Personal Data

We use Personal Data for the purposes described above. Personal Data may also be used or disclosed as otherwise permitted or required by applicable law.

Disclosing Personal Data

We share and/or sell Personal Data with the following categories of third parties:

  • Processors: We use processors to securely handle Personal Data on our behalf and only on our instructions. These companies may not use your Personal Data for their own purposes.
  • Affiliates: We may disclose your information to our affiliates, subsidiaries, and representatives as part of providing our services.
  • Our Analytics and Advertising Partners: We use analytics services to collect and process certain data and to provide you with relevant advertising. These services may also collect information about your use of certain other websites, apps, and online resources.
  • Our Business Partners: We may disclose relevant personal data to our business partners to provide you with exclusive offers for products and services that may interest you.

See the tables above for more details about how different categories of Personal Data are disclosed.

De-Identified Data

We may use de-identified personal data to accomplish the contracted services requested by our clients and to conduct internal research and development to improve our services. De-identified data is information that can no longer be linked to a particular individual or household. Trajector is committed to maintaining this data in de-identified form as necessary to protect client privacy. Employees are instructed not to attempt to use de-identified data to associate this data with, or infer characteristics about, a particular individual. We require any Processors of de-identified data to similarly comply with these requirements.

 

Exercising Your Personal Data Rights

US residents have the following rights under US Privacy Laws:

  • The rights to access, correct, or delete Personal Data;
  • The right to obtain a portable copy of Personal Data;
  • The right to limit the use of Sensitive Personal Data in certain circumstances;
  • The rights to opt out of targeted advertising, sales of personal data, or profiling;
  • The right not to receive discriminatory treatment for exercising your privacy rights; and
  • The right to appeal our decisions about your requests if you disagree with them.

If you are a US resident, you can submit a request to exercise your personal data rights under US Privacy Laws by visiting our online portal at ttps://www.requesteasy.com/6400-4075 or sending an email to [email protected] with the subject line “Privacy Rights Request”.

To protect your privacy, we may need to authenticate your identity before we respond to your rights request. We will verify your identity by sending an email to your email address on file with a link to click. We may ask you for additional information as part of this process, including the last four digits of your social security number. If you do not complete the verification process, we may be unable to process your request. Any information you provide to authenticate your identity will only be used to process your rights request and not for any other purpose. Please be aware that we do not accept or process rights requests submitted through other means.

We will respond to your rights request within 45 days, though in certain cases we may inform you that we will need up to another 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic. Also note that each of the rights are subject to certain exceptions.

We reserve the right to decline to process, or charge a reasonable fee for, requests from a US resident that are manifestly unfounded, excessive, or repetitive.

Notice of Right to Opt-Out of Sale/Sharing for Targeted Advertising

US privacy laws give US residents the right to direct a business that “sells” or “shares” their Personal Information to stop selling and/or sharing their Personal Information at any time. As used here, “selling” means exchanging Personal Data with a third party for money or anything of value, and “sharing” means disclosing Personal Data to a third party for use in conducting “cross-context behavioral advertising,” also referred to as “targeted advertising.” An example of targeted advertising is displaying advertisements to a person where the advertisement is selected based on Personal Data obtained from their activities over time and across non-affiliated websites or applications to predict their preferences or interests. In certain situations and as detailed above, we sell and share for targeted advertising Personal Data with third parties. You can opt out of the sale and/or sharing of your Personal Data by visiting our online portal at ttps://www.requesteasy.com/6400-4075 or sending an email to [email protected] with the subject line “Privacy Rights Request”.

Notice of Right to Limit the Use of Sensitive Personal Information

You have the right to limit some uses of Sensitive Personal Data. In general, you may direct companies not to use Sensitive Personal Data except as necessary to provide goods or services you have requested or other exempt purposes.

However, we only use Sensitive Personal Data for purposes that are exempt from this right, such as to provide you with goods or services you have requested, to detect and prevent security incidents, or verifying the quality of our goods and services. The full list of these exempt purposes are specified in California Code of Regulations, Title 11, Section 7027(m).

Children’s Data

We do not knowingly collect or use the Personal Information of children under 16. If you believe that we have collected the Personal Information of a child under 16, please contact us at [email protected].

Authorized Agent Requests

You may designate an authorized agent to make a rights request on your behalf. Your authorized agent may submit such a request by following the same method described above in the section titled Exercising Your Personal Data Rights. We may require verification of your authorized agent’s authority in addition to the information we require for verification of your identity.

Contact Us

If you have any questions or concerns regarding this Detailed US Privacy Notice, contact us at [email protected].

Last updated: February 15, 2024