By accessing or using any of the American Ombudsman Enterprises ("AOE") Internet properties including, without limitation, www.adrprogram.com, www.aoeusa.com, www.workcompadr.com, mobile websites, microsites, mobile applications, AOE profiles on social media sites and any other digital services or properties operated or used, and any others released by AOE from time to time (collectively referred to as the "AOE Sites") you agree to comply with and be bound by this Privacy Policy, the AOE Code of Conduct, the AOE Copyright and Intellectual Property Policy (collectively, the “AOE User Policies”), and the AOE Terms of Use. Please read this Privacy Policy carefully as well as the other AOE User Policies and AOE Terms of Use. If you do not agree to the AOE Terms of Use or the AOE User Policies, you must immediately terminate use of the AOE Sites.

This Privacy Policy explains how AOE collects, uses, shares and safeguards Personal Data and Non-Personal Data on the AOE Sites, as well as by phone or by paper.

Changes to the Privacy Policy

As AOE, its products and its services change from time to time, this Privacy Policy is expected to change as well. We reserve the right to amend the Privacy Policy at any time, for any reason. The date of the last revision to the Privacy Policy will be indicated by the "Effective Date" at the bottom of this page.

Types of Data We Collect

Personal Data

We collect information (whether online, by phone, or by paper) that enables AOE to identify or contact you (“Personal Data”) to carry out its business purposes. The AOE Sites collect this information for a variety of business reasons, including but not limited to, registering for an AOE event or program, purchasing AOE products or services, or otherwise interacting with AOE.

The types of Personal Data we collect include, but are not limited to:

• General data (e.g., names, dates of birth, home and business addresses, email addresses, Internet protocol addresses and mobile/landline business/personal telephone numbers).
• Professional data.
• Government-issued identification numbers (e.g., social security numbers, national identification numbers and tax identification numbers), for example from employees and independent contractors.
• Other identification information (e.g., photographs).
• Financial information (e.g., credit and debit card numbers, credit reports, passwords and PIN numbers) for product sales or employment purposes.
• Sensitive Personal Data for diversity or accessibility purposes.

Non-Personal Data

We collect information (whether online, by phone, or by paper) that does not directly identify you as you interact with the AOE Sites (“Non-Personal Data”). The types of Non-Personal Data we collect includes, but is not limited to:

• Site usage (e.g., browsing history, search terms, number of clicks, referring/exit pages, date/time stamp, time on Site).
• Products and services viewed, including advertisements for such products and services.
• Computer type, operating system and platform type.
• Internet service provider.
• Your industry and business (e.g., company size and location, job functions and seniority levels).

How We Use Your Data

In addition to the uses described above, we use your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the below, in order to:

Personal Data

• Identify you when you visit AOE Sites.
• Provide service communications.
• Provide products, information and services you request or that we think you may be interested in.
• Respond to your emails or online requests for products, services, or information.
• Deliver and process surveys.
• Personalize and improve the usability of AOE Sites.
• Fulfill and/or deliver AOE products and services.
• Tailor content, advertising and marketing to you.

Non-Personal Data

We use Non-Personal Data to improve the usability of AOE Sites and for other business reasons. We or other third-party companies also use the Non-Personal Data to provide advertisements and targeted advertisements to you (ads based on the Non-Personal Data). We do not provide Personal Data to third parties with whom we share your Non-Personal Data. Please note that, when you select an advertising link or other link that takes you to sites not operated by AOE, you may be subject to the privacy policies of these third-party sites.

How We Share Your Data

AOE does not sell, rent, or otherwise provide the information we collect to outside third parties for the purpose of direct or indirect mass email marketing. AOE shares Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to, the following:

• Share data with third parties to fulfill service requests and to perform business functions.
• Share data with third parties as required by law or to protect AOE in the good-faith belief that such action is necessary to: (a) cooperate with the investigations of purported unlawful activities and conform to the edicts of the law or comply with legal process served on AOE; (b) protect and defend AOE's rights or property; (c) identify persons who may be violating the law, the rights of third parties, or otherwise misusing the AOE Sites; or (d) protect the personal safety of AOE personnel or members of the public in appropriate circumstances.
• Share data with third parties if AOE and/or its assets (or a portion of its assets) are sold, assigned, transferred, or merged, or if AOE undergoes some other change including a change to its corporate form as part of a legal proceeding or otherwise; information may be transferred as part of that transaction or change.
• Share data with third parties to offer you products and services that may be of interest to you professionally or personally. Users can request their information to be removed from such lists by contacting us, as set forth in the “Contact Information” section below.
• Share data with social media sites such as Facebook, LinkedIn, Twitter and others who may contact you with “targeted ads” relating to various products and services.
• Share data with third parties under other unanticipated situations, but only with your consent.
• Share your email address, but only as permitted as follows: (a) AOE does not sell or rent your email addresses to any party outside of AOE; (b) except in certain circumstances for the purpose of conducting AOE business, your email addresses are not shared, without prior consent, with corporate sponsors, advertisers, or any third-party selling products and services on AOE's behalf.

Please keep in mind that whenever you voluntarily disclose personal information online - for example through e-mail, discussion boards, or elsewhere - that information can be collected and used by others. In short, if you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties in return.

Ultimately, you are solely responsible for maintaining the secrecy of your personal information. Please be careful and responsible whenever you are online.

How You Can Manage the Processing of Your Data

You can manage your profile and email preferences, including “opting out” of email by contacting us using the information in the “Contact Information” section below, including if you prefer to receive hard copy mailings only from AOE. For California residents, please consult the “California Privacy Rights” section for additional considerations.

Our processing of your data is based upon your consent, contract performance (e.g., your purchase of products), legitimate business interest (e.g., direct marketing of goods and services), or compliance with law. You have the right to object to our processing of your data or to restrict our processing of your data. In addition, if you have consented to the processing of your Personal Data, you have the right to withdraw your consent at any time.

California Privacy Rights

In addition to the rights as explained in this Privacy Policy, under California’s "Shine the Light" law, California residents who provide personal information (as defined in the statute) to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the personal information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g., requests made in the current year will receive information about the prior year). To obtain this information please write to us at: American Ombudsman Enterprises, 1950 W. Corporate Way, Anaheim, CA 92801, Attn: California Privacy Law. Please include your full name, address, phone number, and email address, if applicable.

Canada Anti-Spam Law

AOE complies with the Canada Anti-Spam Law. Those who provide us a Canadian mailing address will not receive unauthorized Commercial Electronic Messages (as defined under the Canada Anti-Spam Law) unless these individuals have “opted-in” to receive Commercial Electronic Messages.

Children

We do not knowingly collect Personal Data from or market to children under the age of 13.

How We Protect Personal Data

AOE implements commercially reasonable security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data.

If we collect sensitive information, that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon on your web browser, or looking for "https" at the beginning of the address of the web page.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job are granted access to personally identifiable information.

Unfortunately, no data transmission over the Internet or electronic storage is fully secure. Accordingly, and despite our reasonable efforts to protect your Personal Data from unauthorized access, use, or disclosure, AOE cannot guarantee or warrant the security of the Personal Data you transmit to us, or to or from the AOE Sites. Please contact us if you have questions about this Privacy Policy.

User ID and Password

Certain areas of the AOE Sites require the use of a user ID, email address, or password as an additional security measure that helps protect your Personal Data. To help you protect your privacy, the AOE Sites have tools to help you log in and log out.

Linking to Other Internet Sites

You should be aware that other Internet sites that are linked from the AOE Sites or from an AOE email message may contain privacy provisions that differ from the provisions of this Privacy Policy. To ensure your privacy is protected, we recommend that you review the privacy statements of these other linked sites, applications, or other digital platforms.

How You Can Access, Change and Delete Your Personal Data

We rely on you to update and correct your Personal Data. If you are a user of AOE Sites, subscriber to AOE publications, or purchaser of AOE products and services, you can review, update and correct your information directly on AOE’s website or by contacting us using the information in the “Contact Information” section below. Typically, we retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. This may include retaining your Personal Data indefinitely in order to provide you with future marketing opportunities and other purposes, as well as to comply with our legal obligations, resolve disputes, or enforce any of our agreements. Please note that you can request, at any time, that we delete your Personal Data. All requests must be directed to the contact in the “Contact Information” section below. We can decide to delete your Personal Data if we believe that the data is incomplete, inaccurate, or that our continued use and storage are contrary to our obligations to other individuals or third parties. When we delete your Personal Data, it will be removed from our active databases or anonymized so that the data is no longer identified with you, but the data may remain in our archives if AOE determines that it is not practical or possible to delete it.

Cookies and Other Web Devices

AOE Sites send cookies (e.g., pieces of code or text placed on your computer by us or third-parties when you browse AOE Sites) to your web browser (if your browser’s preferences allow it) to collect data when you browse AOE Sites. Cookie settings can be controlled in your Internet browser to automatically reject some forms of cookies. If you view our website without changing your cookie settings, you are indicating your consent to receive all cookies from AOE Sites. If you do not allow cookies, some features and functionality of AOE Sites may not operate as expected. In addition to cookies, we place technological tools (and allow certain third parties to place technological tools) such as tags and beacons (e.g., code scripts that are primarily used to track visitors’ activities on AOE Sites by web analytics software), Internet Protocol (IP) addresses, and other tools, to collect your data for the purposes listed in this Privacy Policy.

Transmission of Data to Other Countries

Your Personal Data is processed in the United States where privacy laws may be less stringent than the laws in your country and where the government, courts, or law enforcement may be able to access your data. By submitting your Personal Data to us, you agree to the transfer, storage and processing of your Personal Data in the United States.

Right to Complain to Supervisory Authority

You, as the data subject, have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you believe that the processing of your personal data does not comply with legal requirements.

Breach Notification

In the event we determine the occurrence of a data security incident, we will notify you by email, US mail, telephone, or other means as permitted by law.

Contact Information

We welcome your comments or questions regarding this Privacy Policy. Please email us or contact us at the following address or phone number:

American Ombudsman Enterprises
1950 W. Corporate Way
Anaheim, CA 92801
United States of America
(800) 541-9275

Effective Date: September 9, 2023