Last Updated: April 2018

DisabilityOver50™ Privacy Policy

Thank you for visiting the DisabilityOver50™ website located at www.disabilityover50.com (the “Site”). The Site is an Internet property of IM Solutions, LLC (“Company,” “we,” “our” or “us”). This Disability Approval Guide™ Privacy Policy (“Privacy Policy”) covers our treatment of personal information and other information that we collect when an end-user visitor to the Site (“User,” “you” or “your”): (a) accesses or uses the Site; (b) accesses and/or views any of the: (i) links to resources and/or information pertaining to Social Security Disability benefits, workers compensation benefits and/or veterans benefits, as well as related products and/or services (“Third-Party Links”); and/or (ii) text, video and/or other information pertaining to Social Security Disability benefits, workers compensation benefits and veterans benefits, as well as related products and/or services, as made available on the Site (the “Informational Content,” and together with the Third-Party Links, the “Content”); (c) accesses links to Company’s social media pages/accounts featured on third-party social media websites, such as Facebook®, Google+®, Pinterest® and Twitter® (collectively, “Social Media Pages”); and/or (d) utilizes the various contact forms and/or contact information made available on the Site as a means to contact directly, or request to be contacted by, Company and/or certain third-party Social Security Disability benefits-related, workers compensation benefits-related and veterans benefits-related, product and/or service providers (“Third-Party Service Providers”) (collectively, the “Contact Services,” and together with the Site, Content and Social Media Pages, the “Site Offerings”).

Capitalized terms not defined herein shall have the meanings set forth in the Disability Approval Guide™ Website Terms and Conditions (“Terms and Conditions”). IF YOU DO NOT AGREE TO TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE SITE OFFERINGS.

Please be advised that Company is in no way affiliated with the United States Social Security Administration or any other governmental entity. The Site Offerings are in no way authorized, sponsored or endorsed by the United States Social Security Administration or any other governmental entity.

Your California Privacy Rights

f you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third-parties, what categories of personal information that we have shared with third-parties in the preceding year, as well as the names and addresses of those third-parties, please e-mail us at: disabilityover50@leadingresponse.com; or send us mail to: Disability Approval Guide, 1820 Preston Park Blvd., Suite 2200, Plano, TX 75093.

Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please e-mail us at: disabilityover50optout@leadingresponse.com; or send us mail to: DisabilityOver50, 1820 Preston Park Blvd., Suite 2200, Plano, TX 75093.

Personal Information Collected

For the purposes of this Privacy Policy, “personal information” shall mean individually identifiable information from or about an individual. We collect personal information when you access certain of the Site Offerings and complete the required information request form and/or otherwise provide such information to us.

Where a User attempts to utilize the Contact Services, that User may be required to submit, and Company may collect, some or all of the following information: (a) the User’s full name; (b) the User’s e-mail address; (c) the User’s telephone number; (d) the User’s mailing address; (e) the User’s date of birth; and (f) any other information requested on the applicable form (collectively, “Initial Contact Data”).

Where a User attempts to utilize the Contact Services in connection with Social Security Disability benefit-related products and/or services, that User may be required to submit, and Company may collect, some or all of the following information: (i) the nature of the User’s condition giving rise to the subject Social Security Disability benefits claim; (ii) whether the User expects to be out of work for at least twelve (12) months; (iii) whether the User is currently working and making more than One Thousand Dollars ($1,000) a month; (iv) whether the User has been prescribed medication or is being treated by a doctor; (v) whether the User already receives some Social Security benefits; (vi) whether the User has already retained a Social Security Disability benefits attorney or advocate; and (vii) any other information requested on the applicable form (collectively, “SSDI Contact Data”).

Where a User attempts to utilize the Contact Services in connection with workers compensation-related products and/or services, that User may be required to submit, and Company may collect, some or all of the following information: (A) whether the subject injury occurred while the User was working; (B) the approximate date of the subject injury; (C) whether the User reported the subject injury to her/his supervisor at work; (D) whether the User was still employed when she/he reported the subject injury; (E) whether the User was hospitalized for the subject injury; (F) whether the User’s claim has already been rejected or accepted by an attorney or law firm; (G) a description of the subject injury; and (H) any other information requested on the applicable form (collectively, “WC Contact Data”).

Where a User attempts to utilize the Contact Services in connection with veterans benefit-related products and/or services, that User may be required to submit, and Company may collect, some or all of the following information: (I) the nature of the User’s service-related condition giving rise to the subject veterans benefits claim; (II) whether the User is unable to work due to her/his service-related condition; (III) whether the User was discharged honorably; (IV) whether the User currently has a U.S. Department of Veterans Affairs (“VA”) appeal pending or a VA decision that the User would like to appeal; (V) whether the User has already retained an attorney in connection with the subject service-related condition; and (VII) any other information requested on the applicable form (collectively, “Vet Contact Data,” and together with the Initial Contact Data, the SSDI Contact Data and the WC Contact Data, the “User Data”).

Upon entering Contact Data and clicking on the applicable submission button on the Site, Company may pass your Contact Data along to one (1) or more of its Third-Party Service Providers.

Please be advised that Company does not itself provide any underlying Social Security Disability benefits-related, workers compensation benefits-related or veterans benefits-related, products and/or services, and the ultimate terms and conditions of any such products and/or services will be determined by the applicable Third-Party Service Provider(s). You understand and agree that Company shall not be liable to you or any third-party for any products and/or services offered by any Third-Party Service Provider.

Use of Personal Information

By submitting your personal information by and through the Site Offerings, you agree that we may share, sell, rent, lease or otherwise provide that personal information to any third-party for any purpose permitted by law, and we may work with other businesses to bring selected retail opportunities to our Users. These businesses and third-parties may include, but are not limited to: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers. We may also use your personal information to send you promotional messages regarding various Company products and/or services, as well as third-party products and/or services that we think may be of interest to you.

Without limiting the foregoing, we may share your User Data with any and all applicable Third-Party Service Providers. These Third-Party Service Providers may, depending upon your stated preferences, use your User Data to offer you Social Security Disability benefits-related, workers compensation benefits-related and veterans benefits-related, products and/or services, and for any other lawful purposes, subject to any restrictions contained herein. The information that you supply directly to any Third-Party Service Providers shall be governed by the applicable Third-Party Service Providers’ privacy policy.

Where you submit personal information, we use the personal information that you make available to personalize your experience with the Site and to facilitate the delivery of the applicable Site Offerings to you, including to respond to any inquiries made by you.

You also agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Site Offerings, and to keep you informed of our other products and services.

We may also employ other companies and individuals to perform certain functions on our behalf. Examples include sending direct and electronic mail, removing duplicate information from User lists, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to our Users’ personal information as needed to perform these functions for us, but we do not permit them to use User personal information for other purposes.

We will also use your personal information for customer service, to provide you with information that you may request, to customize your experience with the Site Offerings and/or to contact you when necessary in connection with your use of the Site Offerings. We may also use your personal information for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the Site Offerings. We may also combine the information we have gathered about you with information from other sources.

By submitting your personal information by and through the Site Offerings, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.

Where you provide “prior express written consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive telephone calls from Company and designated Third-Party Service Providers, including artificial voice calls, pre-recorded messages and/or calls (including SMS text messages) delivered via automated technology, to the telephone number(s) that you provided. Please note that you are not required to provide this consent in order to obtain access to the Site Offerings, and your consent simply allows Company, as well as the designated Third-Party Service Providers, to contact you via these means. Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes. Without limiting the foregoing, if you: (i) have your telephone number reassigned to another person or entity; (ii) give up your telephone number so that it is no longer used by you; (iii) port your telephone number to a landline or vice versa; or (iv) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify Company of the Phone Number Change via e-mail at: disabilityover50@leadingresponse.com;, or by using one of the methods set forth in the “Contact Us” section below.

We reserve the right to release current or past personal information: (A) in the event that we believe that the Site Offerings are being or have been used in violation of the Terms and Conditions or to commit unlawful acts; (B) if the information is subpoenaed or requested pursuant to any court order or legal proceeding; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena/court order, prior to disclosure of any personal information pursuant to a subpoena; or (C) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if Company is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.

You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with third-parties for suppression purposes in compliance with applicable law, including the CAN-SPAM Act of 2003, as amended from time to time. Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third-parties without permission.

Non-Personal Information Collection and Use

IP Addresses/Browser Type

We may collect certain non-personally identifiable information about you and your desktop computer and/or mobile device when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the Site Offerings and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze usage of the Site Offerings.

Cookies

When a User visits the Site, we send one (1) or more cookies and/or gif files (collectively, “Cookies”) to assign an anonymous, unique identifier to the applicable User’s computer. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. We use Cookies to improve the quality of the Site Offerings, including for storing User preferences and tracking Site-User trends (such as pages opened and length of stay at the Site).

Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even in the case where a User rejects a Cookie, he or she may still use the Site Offerings; provided, however, that certain functions of the Site Offerings may be impaired or rendered inoperable if the use of Cookies is disabled. We reserve the right to retain Cookie data indefinitely.

Behavioral Tracking

Company, as well as third party entities such as Google®, Bing® and Facebook®, use Cookies, pixels and other tracking technology (collectively, “Tracking Technology”) in connection with the Site for purposes of tracking Users’ activities (such as websites visited, advertisements selected and pages viewed) after they leave the Site. Company, and its third-party partners, use this Tracking Technology to target applicable Users with advertisements featuring Company products and/or services, as well as third-party products and/or services, that may be of interest to applicable Users.

In general, Users may be able to disable some, but not all, of this tracking activity by utilizing the “Do Not Track” setting or similar options within most major Internet browsers. In addition, 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.

Further, 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: http://www.google.com/settings/ads. Google® also recommends installing the Google® Analytics Opt-out Browser Add-on for your web browser, which is available here: https://tools.google.com/dlpage/gaoptout. To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third-parties in connection with the Site.

Cross Device Tracking

Company tracks Users’ use of the Site Offerings across various devices, including your personal computer and mobile device, in order to optimize and personalize your Site Offerings experience. Company may collect certain of your personal information across various devices.

Aggregate Data

Company reserves the right to transfer and/or sell aggregate or group data about Users of the Site Offerings for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of Site Offerings Users as a group, without disclosing personally identifiable information.

Social Media Websites

If you engage in any interaction with Company, other end-users or any third-party on any Social Media Pages, you should be aware that: (a) the personal information that you submit by and through such Social Media Pages can be read, collected and/or used by other users of these websites/services (depending on your privacy settings associated with your accounts with the applicable Social Media Websites), and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire; and (b) where Company responds to any interaction on such Social Media Pages, your account name/handle may be viewable by any and all members/users of Company’s social media accounts.

We are not responsible for the personal information that you choose to submit on any Social Media Websites. The Social Media Websites operate independently from Company, and we are not responsible for such Social Media Websites’ interfaces or privacy or security practices. We encourage you to review the privacy policies and settings of the Social Media Websites with which you interact to help you understand those Social Media Websites’ privacy practices. If you have questions about the security and privacy settings of any Social Media Websites that you use, please refer to their applicable privacy notices or policies.

Third-Party Websites

This Site may contain links to third-party owned and/or operated websites including, without limitation, the Social Media Websites, Third-Party Links and websites owned and operated by Third-Party Service Providers. Company is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of these third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Company has no responsibility or liability relating to them.

Security

We endeavor to safeguard and protect our Users’ personal information. When Users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). Where our registration/application process prompts Users to enter sensitive information (such as financial information), and when we store and transmit such sensitive information, that information is encrypted with advanced TLS (Transport Layer Security).

Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. All of our Users’ personal information is restricted in our offices, as well as the offices of our third-party service providers. Only employees or third-party agents who need User personal information to perform a specific job are granted access to User personal information. Our employees are dedicated to ensuring the security and privacy of all User personal information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store User personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control.

Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site, other Site Offerings or otherwise via the Internet or wireless networks, is done at your own risk.

In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

Minors

Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information at the Site. Company does not knowingly solicit or collect information from visitors under eighteen (18) years of age. Company encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Opt-Out/Unsubscribe

To opt-out of receiving e-mail and other forms of communications from us, you can: (a) follow the instructions included in the applicable e-mail message or other communication; or (b) e-mail us at: disabilityover50optout@leadingresponse.com.

Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Site Offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving Site Offerings-related and/or inquiry response-related messages from Company, you must cease requesting and/or utilizing the Site Offerings and/or cease submitting inquiries to Company, as applicable.

Deleting, Modifying and Updating Your Information

At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected. You may do so by e-mailing us at: disabilityover50@leadingresponse.com. We ask individual Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Please be advised that deleting your personal information may terminate your access to certain of the Site Offerings. If you wish to continue using the full complement of Site Offerings, you may not be able to delete all of the personal information that we have on file for you.

Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

Transfer of Personal Information Internationally

If you are visiting the Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of information across international boundaries. By visiting the Site and/or otherwise communicating electronically with us, you consent to such transfers. Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Privacy Policy.

Changes to this Privacy Policy

Company reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site that we are changing our Privacy Policy. If the manner in which we use personal information changes, Company will notify Users by: (a) sending the modified policy to our Users via email; and/or (b) by any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use your information in this different manner and we will only use your information in this different manner where you opt-in to such use.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices in general, you may email us as at: disabilityover50@leadingresponse.com; or send us mail to: DisabilityOver50, 1820 Preston Park Blvd., Suite 2200, Plano, TX 75093.