Background & Purpose

LifeLock, Inc. ("LifeLock", "we", "our" or "us"), its affiliates, and subsidiaries, is a national provider of proactive identity theft protection services for consumers and consumer risk management services for enterprises. LifeLock, Inc., protects its members by monitoring identity-related events, such as new account openings and credit-related applications.



Policy & Procedure

Applicability

This policy applies to LifeLock, Inc.’s Identity App.



Policy

Version 2.0

Effective September 28, 2016

LifeLock, Inc. ("LifeLock", "we", "our" or "us") takes your privacy seriously. This Identity App Privacy Policy (referred to as the "Privacy Policy" herein) describes the information LifeLock collects when you sign up for, use, or otherwise interact with the LifeLock Identity application (our "Identity App") and the identity management services we offer through that application (“Services”). This Privacy Policy also describes how LifeLock uses and shares the information we collect and the choices we offer.

If you elect to use our Identity App and Services you must agree to our Identity App Service Terms and Conditions and this Privacy Policy. By checking the “I agree” box when you download and register for the Identity App, you agree and affirmatively consent to the collection and sharing of your information, including your personal information, as described in this Privacy Policy.

Other contractual terms may apply to you depending on the other LifeLock services that you access or use. Current versions of these and other legal documents may be found online at https://www.lifelock.com/legal/. 

IF YOU DO NOT AGREE TO OUR PRACTICES AS DESCRIBED IN THIS POLICY, DO NOT USE THE IDENTITY APP OR SERVICES.

Changes to This Privacy Policy

WE MAY MODIFY OUR POLICY FROM TIME TO TIME. WE WILL POST THOSE MODIFICATIONS HERE PRIOR TO THE MODIFICATIONS BECOMING EFFECTIVE. WE WILL ATTEMPT TO NOTIFY YOU OF MATERIAL MODIFICATIONS TO THIS PRIVACY POLICY, INCLUDING SENDING YOU A COPY OF THE UPDATED POLICY BY EMAIL IF WE HAVE YOUR EMAIL ADDRESS ON FILE, PRIOR TO THE CHANGE BECOMING EFFECTIVE. YOUR CONTINUED USE OF THE SITE OR OUR SERVICES AFTER ANY SUCH MODIFICATION MEANS THAT YOU ACCEPT THE MODIFIED POLICY.

Information the App Collects and Sends to Third Parties

The Identity App and Services facilitate your ability to manage and assert your identity in connection with third-party entities, websites, and services, which are featured in  the Identity App (collectively, “Third Parties”).

The Identity App allows you to store information on your device such as login credentials for third party services, mailing and billing addresses, credit card information, documents/credentials, email address and phone number within the Identity App. The Identity App may also, at your direction and if available for your email service provider, access, search and scan your stored email and its contents to gather some of this information automatically and import it into the Identity App installed on your device.

Other than your email, phone number and name, information entered by you ultimately stores on your phone and is not stored persistently on any LifeLock servers.

We may store your email, phone number and name for use in analytics and marketing and might use 3rd party service providers as part of conducting analysis and marketing activities.

Please note that should you choose to use the email scanning portion of the service, the information gathered and imported through this scanning process happens not on the phone but rather via our server. After the email scan completes on the server, information is transmitted to the Identity App for use on your phone and is deleted from our server.

This information is stored locally on your mobile device and in accordance with any backup or cloud storage that you utilize. We do not store your personal information on our servers other than the email address, name and phone number you provide to sign up for the service.

The Identity App, at your direction, will transmit this information to Third Parties to facilitate your ability to manage and assert your identity in connection with those Third Parties.

Please be aware that in using the Identity App and Services you are providing your personal information to these Third Parties. The Third Parties may have different privacy policies and terms and conditions and/or business practices than we do. Your use, access, or interaction with Third Parties is governed by those Third Parties’ privacy policies and terms and conditions even if the Identity App is facilitating your use, access, or interaction with those Third Parties.

Information We Collect

We may collect information, both personal and general, about you from a variety of sources, including information we gather from you directly when you register for and/or use the Identity App and Services.

Personal Information means information, or a combination of pieces of information, that reasonably could allow us to identify you. Personal Information includes things like your name, address, date of birth, social security or driver's license number. General Information refers to information about your use of the Identity App and Services that is gathered automatically. General Information does not identify you individually, but helps us better understand how our Identity App and Services are used.

Personal Information We Collect Directly From You

Some Personal Information is collected when you register for the Identity App or otherwise agree to provide information directly to us. Here are some of the kinds of information we may collect directly from you:

Personal Information that you store in the Identity App, such as billing or mailing address or credit card information, is not collected and stored by LifeLock except as disclosed in the above listing.

If we start collecting substantially new types of Personal Information and materially change how we handle your data, we will modify this Privacy Policy and notify you in accordance with this Privacy Policy.

General Information We Collect Through Your Use of Identity App

We, and the third parties we engage to perform analytics or advertising services, automatically collect certain General Information when you access or use Identity App, via log files and other mobile tracking technologies. If you do not want us to collect this information from you, please do not use Identity App.

These technologies are used to administer and improve our Service, including to track user engagement with Identity App, to gather usage information and statistics about how our Services are used, to permit users to log in, to store user preferences, to customize content, and for marketing and advertising purposes. Through various technologies (which may include cookies or similar programs designed to work with mobile apps) we will collect:

If we start collecting substantially new types of Personal Information and materially change how we handle your data, we will modify this Privacy Policy and notify you in accordance with this Privacy Policy.

Information We Collect From Other Sources

We may obtain information about you from third party sources, such as the companies we work with to provide service to you (i.e., our service partners), affiliates such as our subsidiary, ID Analytics and other companies that we acquire or merge with, data aggregators or public databases. We may combine this information with the information we collect from and about you. Here are examples of this kind of third party information we may collect from other sources:

How We Use Your Information

In general, we use your information to provide and improve our services, to communicate with you, for advertising, to send you offers and other promotional information, and for other related purposes. For example, we use your information, including your Personal Information for the following purposes:

How We Share Your Information

We do not share or sell your personal information to non-affiliated third parties for their own marketing or business purposes, unless you consent. We may share your information, including information that we collect directly from you, information that we collect about you from third parties, and information that we collect automatically, for the following purposes and with the following persons/entities:

The Choices You Have

Personal Information and Account Closure

You may change or correct information about yourself by logging into the Identity App and changing that information.

We retain the Personal Information you provide while your account is in existence and as needed to provide you services. If you wish to deactivate your account, you may do so by contacting us as noted in the "Contact Us" section below. We may retain your Personal Information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between parties, prevent fraud and abuse, or enforce this Privacy Policy and our Terms of Service. We also may retain Personal Information, for a limited period of time, if requested by law enforcement.

We may retain General Information for as long as is necessary to provide support-related reporting and trend analysis only. We generally delete or de-personalize closed account data, including any logs or backup information, within 30 days of account closure.

Notifications

The Identity App and Services may include the ability to receive email, push notifications and other notifications from the Services (the "Mobile Alerts"). You acknowledge and agree that we may send you notifications via text (SMS) messages, until you notify us that you no longer wish to receive these Mobile Alerts. You have the ability to change your Mobile Alert preferences in your Identity App settings to not receive such messages.

THE FREQUENCY OF MOBILE ALERTS WILL VARY BASED ON THE KINDS OF ALERTS AND OTHER NOTIFICATIONS (INCLUDING PUSH NOTIFICATIONS ON YOUR MOBILE DEVICE) YOU SIGN UP TO RECEIVE PURSUANT TO YOUR SERVICES. STANDARD TEXT MESSAGING RATES APPLY (INCLUDING WHERE APPLICABLE ROAMING CHARGES), SO PLEASE CONTACT YOUR MOBILE PHONE CARRIER FOR DETAILS AND FEES. YOU WILL BE RESPONSIBLE FOR ALL TEXT MESSAGING AND DATA PLAN FEES CHARGED BY YOUR MOBILE PHONE SERVICE. MOBILE ALERTS ARE PROVIDED AS A COURTESY TO YOU. WE DO NOT GUARANTEE THE ACTUAL, COMPLETE OR TIMELY DELIVERY OF ANY MOBILE ALERTS. WE ARE NOT RESPONSIBLE FOR, AND EXPRESSLY DISCLAIM ANY AND ALL LIABILITY RELATED TO, THE FAILURE OF ANY MOBILE ALERT TO BE ACTUALLY, ACCURATELY, FULLY OR TIMELY DELIVERED TO YOU FOR ANY REASON WHATSOEVER, INCLUDING THOSE CAUSED BY A TECHNICAL ERROR OR OTHER PROBLEM WITH OUR SYSTEMS, THOSE OF YOUR MOBILE SERVICE PROVIDER, A THIRD PARTY COMPANY OR ISSUES RELATED TO YOUR MOBILE SERVICE ACCOUNT OR MOBILE DEVICE.

Email Advertising

You may receive email marketing messages and materials from us or our affiliates. You may opt-out of the marketing emails by following the instructions in the email and/or by contacting us as noted in the "Contact Us" section below. If you opt-out of email marketing, please note that we may continue to contact you via email regarding your services; we also may continue to market to you through other marketing channels.

Security

The security of your Personal Information is important to us and we have put into place multi-layered technical, physical and procedural measures to help keep it safe. For example, we keep Personal Information encrypted during transit and at rest using strong encryption technology and employ proactive monitoring and other tools to protect against unauthorized access. We work with third parties on an ongoing basis to keep our practices current and undergo annual third party audits that examine our practices on security and privacy.

Despite our mutual efforts, you understand and agree that perfect security does not exist and understand that there is a certain amount of risk inherent in providing and receiving services over the internet. If you have any questions about the security of your Personal Information or the security of our Services, you can send us an email at
security@lifelock.com.

Testimonials

We display personal testimonials of customers on our website in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at privacy@lifelock.com

Children's Privacy

We believe it is important to provide added protection for children on the internet and encourage parents and guardians to work with their children to understand how to be safe online. The Identity App is not intended for the use by anyone under the age of eighteen (18). We do not want or intend to collect or request Personal Information from anyone under the age of eighteen through the Identity App.

Marketing

If you provide us with your email address or mailing address, you may receive marketing messages and materials from us or our affiliates. You have choices on what communications you want to receive from us. Marketing materials for our Services may also be included in messages you receive from our partners or service providers that offer our services as part of a special offer. If you choose not to receive marketing communications that we send, we will honor your request. However, we will continue to communicate with you as needed to provide the Services, respond to your inquiries or otherwise relay service related messages. You may still receive information about our Services through other parties using their own mailing lists.

You can stop receiving promotional email or postal communications from us by following the instructions included in each communication or by contacting us at
unsubscribe.nonmember@lifelock.com or by regular mail at Attn.: Marketing, 60 East Rio Salado Parkway, Suite 400, Tempe, AZ.

Access to and Retention of Your Information

You may access, update, and correct the Personal Information you have provided to us through the Identity App If you decide to stop using our Services, we may retain your information in accordance with this section. We will retain your information as follows:

Special Notice to California Consumers

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information to third parties for the third parties' direct marketing purposes. We may share your Personal Information with our affiliates for direct marketing, but we do not sell it to or share it with unaffiliated third parties. You may request a list of our affiliates by contacting us at LifeLock, Attn.: Marketing, 60 East Rio Salado Parkway, Suite 400, Tempe, AZ. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. Please allow up to thirty (30) days for a response.

Contact Us

If you have any questions or concerns about this Policy or about our privacy practices, please contact us at 1-800-LifeLock (543-3562), at privacy@lifelock.com, or by mail at LifeLock, 60 East Rio Salado Parkway, Suite 400, Tempe, AZ 85281, Attn.: Chief Privacy Officer.


Roles & Responsibilities

Roles & Responsibilities for maintaining policy & procedure governance include but are not limited to:



Regulatory Updates

The Legal Department, in conjunction with Enterprise Risk & Compliance, is responsible for monitoring and ensuring the applicability of this policy. This includes changes to statutes, regulations, case law, and/or other adjudication impacting this policy of the Company’s compliance program.



Enforcement & Review

Enterprise Risk & Compliance, in conjunction with the Legal Department is responsible for the enforcement and periodic review of this policy. Material deficiencies, non-compliance, or required material changes to the policy will be reported to the Board of Directors or a designated sub-committee.



References

The following, non-exhaustive list of Company documents are hereby incorporated by reference into this policy:



Contact

Questions in regards to this policy should be directed to Enterprise Risk & Compliance.