Times U.S. Privacy Policy

Times Internet Limited ("Times" or "We" or “Us” or “Our”) respects your privacy and iscommitted to protecting it through Our compliance with this Privacy Policy. This Privacy Policydescribes:This Privacy Policy applies only to personal information that you provide or that We collect via our Website and services available herein (the “Services”). This Privacy Policy does not apply to information that We collect through websites not under our control, including websites you may access through our Website, or information that you provide to or is collected by any third party. These third parties may have their own privacy policies, which We encourage you to read before providing information on or through them. We do not assume any responsibility or liability for such third parties and their privacy practices nor do we endorse them. You agree and acknowledge that We shall not be liable and will not be held responsible for any losses whatsoever, ever direct, indirect, incidental or consequential, including without limitation any losses due to online fraud. In case of any fraud, you can file a complaint with such third party directly for redressal.If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Iowa, Nebraska, New Hampshire, New Jersey, Montana, Oregon, Texas, Utah, or Virginia, please also see our “State Privacy Rights” Section of this Privacy Policy.If you sign up for Abound via the use of our Website, We will share your personal data with Abound to facilitate the creation of your account and to integrate your Abound account into our services as appropriate. Abound’s privacy policy is available here.The Website is not intended for users under 18 years of age, and We do not knowingly collect personal information from individuals under 18. We also comply with the Children’s Online Privacy Protection Act (“COPPA”) and require parental consent for any data collected from users under the age of 13. If We learn that We have collected or received personal information from a user under 18, We will delete that information. Please be aware that We may not be able to fully delete certain user information until the user cancels their subscription through their account. If you believe We might have any information from or about an individual under 18, please contact us at the e-mail address provided to you in Contact Information section.We may collect information (including personal information) from and about users of the Website directly from you when you provide it to us and/or automatically when you use the Website. We may also collect personal information from you in connection with your sign-up application or if you are one of our users. We retain the personal information that we collect to achieve the purposes for which the personal information was collected. We also collect information from third-party sources, such as social media platforms, advertising partners, and analytics providers, as described below. In certain cases, we may need to retain personal information for purposes required under applicable law, for tax, accounting, or audit purposes, or for other purposes permitted or required under law. We limit data collection to only what is necessary for specific purposes, as outlined below, and we retain data only for as long as required by law or to fulfill the purposes for which it was collected.You may request deletion of your data at any time by contacting us here. We comply with all validated requests within the legally mandated timeframes, typically within 45 days or less.If automated decision-making is used, including profiling, We will inform you of its logic, significance, and the possible consequences of such processing, and provide an option to request human intervention.We may also combine information that identifies you personally with data that comes from an app or affiliate that has a different privacy policy, including for marketing purposes. When We do that, our Privacy Policy applies to the combined data set.Information You Provide to Us via the Website.When you use the Website, We may ask for you to provide information by which you may be personally identified, such as, but not limited to, name, postal address, email address, telephone number, location, or any other identifier by which you may be contacted online or offline (collectively, “personal information”) as required for specific purposes such as account creation or transaction facilitation, or that is about you but individually does not identify you.This information includes information that you provide by filling in forms on the Website. This includes information provided when posting material and requesting information. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the Website. We may also collect (a) records and copies of your correspondence (including email addresses and phone numbers), if you contact us; (b) your responses to surveys that we might ask you to complete for research purposes; (c) details of transactions you carry out through the Website; (d) details you share while applying for a job or submitting any application for career opportunity; and (e) your search queries on the Website.You may provide information to be published or displayed to other users on or through the Website (collectively, “Content”). Your Content may be transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your Content. Therefore, we cannot and do not guarantee that your Content will not be viewed by unauthorized persons.In the event that we provide you with social media login capability, in order to register as a user with us, you may be asked to sign in using your Facebook or other social media site (“SMS”) login. If you do so, you authorize us to access certain SMS account information, such as your public SMS profile (consistent with your privacy settings in SMS), your email address, interests, likes, gender, birthday, education history, relationship interests, current city, photos, personal description, friend list, and information about and photos of your SMS friends who might be common SMS friends with other users. You will also be asked to allow us to collect your location information from your device when you use the Website. In addition, we may collect and store any personal information you provide while using the Website or in some other manner. This may include identifying information, such as your name, address, email address and telephone number, and, if you transact business with us, financial information. You may also provide us with photos, a personal description and information about your gender and preferences for recommendations, such as search distance, age range and gender. If you chat with other users, you provide us the content of your chats, and if you contact us with a customer service or other inquiry, you provide us with the content of that communication.Automatic Information Collection and Tracking.When you access the Website, technology may be used to automatically collect certain information, including, but not limited to:IDs. Web servers, the main computers that serve up web pages, automatically identify your computer by its IP address. As permitted under applicable law, Times collects IP addresses for the purposes of system administration, gathering and analyzing aggregated information, creating a better experience for users and auditing the use of our site. We do not normally link IP addresses to anything personally identifiable, which means that your session will be logged, but you remain anonymous to us. We will seek to link your IP address when we feel it is necessary to protect this site and other users from harm and to prevent criminal misconduct.We also may use technologies to collect information about your usage of the Website over time. If you do not want us to collect this information, either cancel your account or do not access the Website.Session Replay DisclosureWe may use session replay technologies to help us identify user behavior, pain points, errors encountered on our Website and Services, and general product improvement opportunities, among other uses. Session replay technology enables us to review and replay a user’s actions on a website, such as scrolls, clicks, information entered, and other such data. This information may be collected by our session replay vendor(s) and then later shared with us. By using our Services, you consent to the use of session replay technologies.Additional DetailsThe below details further summarize our collection, use, and disclosure of personal information:We capture a range of user data, including but not limited to:We collect user data for a variety of purposes, including:We share user data with:Internal Teams: For purposes such as user profile management, content personalization, and advertising. External Partners: Including Google Analytics, Facebook, Pubmatic, Appsflyer, and other third-party service providers for advertising, analytics, and payment processing.Collaborators: Agencies and vendors involved in e-commerce, surveys, and marketing campaigns. User data is stored in: Internal Databases: Centralized servers for managing data at both the platform and application levels. External Databases: Partner servers (e.g., Google Analytics, Facebook) for tracking and reporting. Local Storage: Browser cookies and app memory for storing user preferences and session data.You may register on Our Sites using Times Internet Limited (“TIL”) SSO login. During registration, We ask that you provide basic personal information from you to continue to interact with you and to continue providing you the Services. Information that We collect includes but is not limited to the following:You may also refer to Our SSO Policy for more details regarding the personal information processed while registering on the Sites.In short, when you use Our Sites, We may also collect, including but not limited to, the below information from you-If you send Us personal correspondence, such as emails or letters, or if other users or third parties send Us correspondence about your activities or postings on the Site, We may collect and store such information. We may collect additional information at other times, including but not limited to, when you change your content or email preferences, comment on stories, write a movie review of Our services, or communicate with Us.The technologies We use for automatic information collection may includeCookiesA cookie is a small file placed on your smartphone or browser. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your browser or smartphone. However, if you select this setting, you may be unable to access certain parts of our Website. Please see our Cookie Policy for further information.Web BeaconsSome of the areas of the Website may contain electronic images known as web beacons (sometimes known as clear gifs) that allow us, and our third-party providers or affiliates, to count and track users who have visited certain portions of the Website. Web beacons collect only limited information and do not collect any of your personal information. Specifically, we may use a type of web beacon known as a “retargeting pixel,” which will allow users to receive targeted advertising from us via certain social media sites.For example, the Website may use Meta Pixel, which is a tool that allows us to measure the effectiveness of our advertising by understanding the actions you take on our Website. In this way, we can tailor our marketing to better suit your needs and display ads that are relevant to you. According to the "How do we use your information?" section of Meta's Privacy Policy, Meta may use information from the Meta pixel to provide a personalized experience to you, including ads, as well as for other purposes such as: promoting safety, security, and integrity; providing measurement, analytics, and business services; communicating with you; and researching and innovating for social good. For some purposes, Meta uses information across its products and across your devices. If you would like to opt-out of the Pixel, go to “Activity Off Meta Technologies” in the Settings section of any of your Facebook or Instagram accounts or by visiting the Facebook Help Center. You may also opt out by declining cookies through the consent tool on the Website. We may also use tools connected to other social media platforms with similar functionalities. Additionally, we use third-party platforms to purchase advertising space and integrate and measure the performance of our advertisements across other websites. The information that our service providers collect about you may include behavioral information, demographic data, interest-based information, geolocation, and contextual search information.Advertising based on our Custom AudiencesFrom time to time, we provide third-party companies (e.g., Meta, Google, Criteo) with your personal information to request that such companies create custom or lookalike audiences (i.e., past customers or customers likely to be interested in our offerings because they share characteristics similar to our existing customers). This enables us to target our advertising efforts more effectively to those who may be interested in products and services. Web Beacons: Pages of the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Times, for example, to count users who have visited those pages and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).Aggregated and/or non-personal information: We may use and disclose non-personal information we collect with third parties under any of the above circumstances. We may also share it with third parties to develop and deliver targeted advertising on the Website and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated, non-personal information, or personal information in hashed, non-human readable form, with third parties, including advisors, advertisers, and investors, for the purpose of conducting general business analysis or other business purposes. For example, we may engage a data provider who may collect web log data from you (including IP address and information about your browser or operating system), or place or recognize a unique cookie on your browser to enable you to receive customized ads or content. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us (such as your email address), that we may share with a data provider solely in hashed, non-human readable form. To opt-out of cookies that may be set by third-party data or advertising partners, please go to www.aboutads.info/choices/.When you use the Website or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include: advertisers, social media platforms, ad networks and ad servers, analytics companies, your mobile device manufacturer, your mobile service provider, etc.These third parties may use tracking technologies to collect information about you. The information they collect may be associated with your personal information or they may collect information, including data about your online activities over time and across different websites, apps, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.These third parties may include but are not limited to: At Times, we are committed to using your personal information responsibly and transparently. This section outlines the purposes for which we collect, process, and use your personal information, as well as the legal bases that guide our practices.We use your personal information to deliver the services and features available on our Website and associated mobile applications. This includes: We collect and process personal information to tailor our services to your individual preferences. This includes: We analyze user behavior to better understand how our Website and applications are used. This helps us improve performance, refine our offerings, and address user needs. Specifically, we use:We leverage personal information for marketing and advertising purposes, including:We take the protection of your personal information seriously and use it to:We may use aggregated and anonymized personal information to conduct research and improve our offerings. This includes:We process personal information to comply with applicable laws, regulations, and legal processes. This includes:When you interact with social media platforms or use third-party login features (e.g., Facebook or Google), We use your personal information to:In addition to the disclosures described above, we may disclose aggregated information that does not constitute personal information about our users without restriction. Further, we may disclose personal information that we collect or you provide:In order for you to make purchases through the Website, service providers like Plaid and Stripe may collect and share financial and payment card account information. This information is shared with us on a tokenized basis and with your authorization. From some of our service providers and/or business partners, we receive details about specific transactions. You can learn more about Stripe's privacy policy here, Plaid's privacy policy here, and their relationship to provide you with money transfer services here.The Website will also allow you to intentionally interact with third parties, such as those whose products or services are made available through the Website. We do not necessarily control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.We operate a centralized data system to enhance collaboration and operational efficiency among its various commonly owned group companies, some of which may be expressly branded as Times Group companies, while others may utilize independent brands. This platform consolidates user data, such as personal information and subscription details, from different services offered by affiliated companies. The purpose of this data sharing is to enable cross-selling and upselling opportunities, improve customer insights, and streamline service offerings across all affiliated entities. By pooling data into a shared system, an affiliate company delivers personalized services and targeted marketing, thereby increasing customer engagement, retention, and revenue growth.The types of data shared with the centralized data system include personal identifiers such as names, phone numbers, email addresses, dates of birth, and location details. It also includes information about subscription plans, such as whether they are paid, free, or trials, along with the start and end dates of those plans. Additionally, the platform tracks user behavior, including whether the customer is a repeat user and the specific services or plans they subscribe to. This shared data allows affiliated companies to analyze customer preferences and usage patterns, enabling them to offer complementary services and personalized recommendations. For example, if a user subscribes to one company’s mobile phone plan and another’s TV streaming service, a third affiliated company uses this data to offer a broadband internet plan tailored to the user’s needs; similarly, if Abound acquires users from TOI, a third Times Group company may be able to tailor its offerings to cater to that user’s needs.This intra-group data sharing initiative improves the customer experience by offering more tailored services, supports business development through targeted marketing, and enhances operational efficiency across Times Group entities. We maintain a commitment to addressing legal and privacy considerations to ensure compliance and uphold user trust.We transfer personal information to countries outside of the United States, including to India, where our affiliates and service providers are located. Transfers are conducted in compliance with applicable laws, using safeguards such as standard contractual clauses or similar mechanisms.What Information Are We Sharing? We may share the following video viewership data:Who Will Receive This Data? Your video viewership data will be shared with:Why Are We Sharing This Data? We will share your video viewership data for the following purposes:By using our Services and/or those of our group companies, you agree that we may share your video viewership data with its affiliates and partners as described above. You may withdraw your consent at any time by contacting us at grievance[dot]toi[at]timesinternet[dot]in and in certain cases closing or deactivating your account with our affiliates and partners as described in their respective Terms of Use.Notice of Right to Opt-out of Sale and Sharing Personal Information and Targeted AdvertisingWe may allow certain third parties (such as online advertising services) to collect your personal information via automated technologies via our Website. Under certain U.S. state privacy laws, this may constitute a “sale” or “share” of personal information or “targeted advertising”. To comply with these laws, we provide you with the option to opt out of this data sharing by clicking on the “Do Not Sell or Share My Personal Information” link at the bottom of our Website. We may have “sold” or “shared” personal information, which consists of identifiers, commercial information, and internet or other electronic network activity information to data analytics providers, advertisers, and social networks for the business and commercial purposes of online advertising and to provide third-party social network features and functionality. Under certain U.S. state privacy laws, you have the right to opt-out of this disclosure of your information, which may be considered a “sale”, “sharing”, or “targeted advertising” under such laws. On our Website, you may opt-out of this “sale”, “sharing”, or “targeted advertising” on our Website by rejecting cookies in our cookie banner. You may also request to opt-out of this “sale”, “sharing”, or “targeted advertising” by e-mailing us at grievance[dot]toi[at]timesinternet[dot]in or by filling the form here.Direct Marketing. California Civil Code Section 1798.83 permits users of the Website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as noted below in Section 14. Contact Information.CCPA: This Section of our Privacy Policy contains certain required information and informs California residents of certain rights arising under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”).Categories of Personal Information Collected: We may have collected the following categories of personal information from you within the last twelve (12) months:Categories of Sources From Which Personal Information Is Collected. We may have collected personal information from you from the following categories of sources: (1) directly from you via our services or when you visit one of our digital properties; (2) your devices; (3) your family and friends; (4) our affiliates and subsidiaries; (5) our third-party providers; (6) social networks; and (7) other available sources, such as public records. Business or Commercial Purposes for Collecting Personal Information. The business or commercial purposes for collecting your personal information are set forth in the “How We Use Your Personal Information” Section of this Privacy Policy.Categories of Personal Information “Sold” or “Shared” to Third Parties and the Business and Commercial Purposes: The categories of personal information that We have “sold” or “shared” to third parties in the last twelve (12) months and the business and commercial purposes for “selling” or “sharing” such personal information are set forth in the “Notice of Right to Opt-out of Sale and Sharing Personal Information and Targeted Advertising” Section of this Privacy Policy. You have the right to opt out of such practices as outlined above. We do not knowingly “sell” or “share” the personal information of individuals under sixteen (16) years of age.Categories of Personal Information Disclosed to Third Parties. All of the categories of personal information described above may be shared with third parties as set forth in the “Other Disclosure of Your Information” Section of this Privacy Policy. Personal Information Retention. We retain the personal information that We collect to achieve the purposes for which the personal information was collected. In certain cases, We may need to retain personal information for purposes required under applicable law, for tax, accounting, or audit purposes, or for other purposes permitted or required under law.Notice of Financial Incentive: The CCPA’s implementing regulations define a “financial incentive” as a program, benefit, or other offering “related to the collection, deletion, or sale of personal information.” TIL may enable third-parties to offer their loyalty programs, including, without limitation, through its partner, Abound, which offers the Abound Loyalty Program (the “Program”). For further details, you may refer to Abound’s terms and conditions and privacy policy here. The amount of personal information that We collect from a member or non-member may vary and is dependent on the level of interactions and engagement that the member or non-member has with Times.Exercising Your California Privacy Rights. For information on how to exercise your rights under the CCPA, please review the “Exercising Your Rights” Section of this Privacy Policy. Colorado, Connecticut, Delaware, Florida, Iowa, Nebraska, New Hampshire, New Jersey, Montana, Oregon, Texas, Utah, and Virginia ResidentsThe following rights apply to residents of Colorado, Connecticut, Delaware, Florida, Iowa, Nebraska, New Hampshire, New Jersey, Montana, Oregon, Texas, Utah, or Virginia:Exercising Your RightsYou may make privacy requests by contacting us at grievance[dot]toi[at]timesinternet[dot]in. However, please see the “Notice of Right to Opt-out of Sale and Sharing Personal Information and Targeted Advertising” Section of this Privacy Policy above for additional information on how to opt-out of “sale”, “sharing”, or “targeted advertising”. You may designate an authorized agent to make such requests on your behalf by having your authorized agent make a privacy request as set forth above. Your authorized agent must complete the webform with their information and disclose the fact that they are your “authorized agent” and provide your first and last name in connection with the request. Before We can honor your requests, We may confirm that the requesting party is the consumer whose information is sought or a person authorized to act on that consumer’s behalf. Our process for verifying the identity of the requesting party includes confirming account credentials or requesting additional information to match our records. This may further include requesting additional information, or verifying a government-issued ID. If a requesting party is an online account holder with a password-protected account, it may be necessary for the account to be accessed by the requesting party to confirm the request(s). In addition, depending on the type of request and the categories of information subject to the request, We may request verifying information from the requesting party such as identifiers or commercial information (e.g., service history) already known to or collected by us. If We refuse to take action upon your request, you may appeal such refusal by contacting us after your receipt of the refusal at grievance[dot]toi[at]timesinternet[dot]in.Do Not TrackCertain state laws require that We indicate whether We honor “Do Not Track” settings in your browser. We adhere to the standards set out in this Privacy Policy and applicable law. Given a lack of support and widespread adoption, We do not respond to Do Not Track (DNT) signals.Email Consent and Opt-outYour provision of personal information on a registration form in the course of our providing our services to you constitutes your affirmative consent that We may contact you by email to provide you with information and notices relating to the services and various other offerings that may be available and of interest to you in the future. It also means We may email you regarding updates to this Privacy Policy. We notify you of this at the time you choose to register, and We will provide you the option not to receive further marketing communications from us at the time you register. Mass commercial email sent by us contains a link with instructions on how to remove yourself from our email list. You will also need to opt-out separately from any third-party e-mails you may receive.Information SecurityWe take commercially reasonable technical, physical, and organizational steps to safeguard any information you provide to us designed to protect it from unauthorized access, loss, misuse, or alteration.We try to ensure that all information you provide to us is transferred securely via the website (always check for the padlock symbol in your browser, and “https” in the URL, to ensure that your connection is secure).All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.Although we take reasonable security precautions, no computer system or transmission of information can ever be completely secure or error-free, and you should not expect that your information will remain private under all circumstances. The Company will not be liable for any damages of any kind arising from the use of the Platform, including, but not limited to any indirect, incidental, special, consequential or punitive damages, or any loss of profits or revenues, whether incurred directly or indirectly or any loss of data, use, good-will, or other intangible losses.Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although We do our best to protect your personal information, We cannot guarantee the security of your personal information transmitted through our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures We provide. If you receive a suspicious email on our behalf, We suggest you do not reply to it and do not open any attachments, click on links contained in the e-mail or provide any information in response to it. You can report suspected fraud involving us by sending an e-mail to grievance[dot]toi[at]timesinternet[dot]in. Please include the word "phishing" in the subject line of your e-mail and provide as much information as possible about the fraudulent activity or message. We do not send e-mails requesting a user for payment information, username or passwords. However, We may verify the user name, password etc. provided by you from time to time.The safety and security of your information (including personal information) can also depend on you. For example, where We have given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. You should not share your password with anyone.Online Account ManagementIf you elected to subscribe to any online services provided via the Website, including the ability to access any password-protected areas of the Website, you will be required to submit personal information for the purpose of verifying your identity and your authority to manage the account (“Access Credential Information”). This Access Credential Information will be used exclusively by Times, our agents, suppliers and third-party service providers for internal use and to respond to your service requests.Changes to Our Privacy PolicyWe may update our Privacy Policy from time to time. If We make material changes to how We treat our users' personal information, We will notify you by e-mail to the primary e-mail address specified in your account or an in-Website alert the first time you use the Website after We make the change. All such updates and amendments are effective immediately upon notice thereof. We expressly reserve the right to make any changes to this Privacy Policy at any time, without early or prior notice to you. The most recent version of the Privacy Policy is reflected by the effective date located at the bottom of this Privacy Policy. The version of this Privacy Policy posted at [insert URL] on each respective date you use the Website shall be the Privacy Policy applicable to your access and use of the Website on that date. Our electronically or otherwise properly stored copies of this Privacy Policy shall be deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Policy which were in force on each respective date you used the Website.Contact Informationgrievance[dot]toi[at]timesinternet[dot]in To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: grievance[dot]toi[at]timesinternet[dot]inNotice of Financial Incentive for California-based UsersEffective Date: December 2024This notice applies if you are a California resident. Times Internet Limited and/or its subsidiary or affiliated companies, including Abound (“TOI,” “we,” or “us”) may offer financial incentive programs that provide certain coupons, gift cards, discounts, price reductions and exclusive offers to eligible users (“Programs”) either independently or in collaboration with our trusted partners. (1) Material Terms of the Programs. The Programs are subject to the Abound Terms of Use. Please see below summary of key terms for the programs We are currently offering:Incentives for Times of India readership and commenting. You may choose to read articles, leave comments, and take other actions on the Times of India website or associated apps. By registering with Abound, you may be eligible to receive incentives such as rewards within the Abound program, as may be offered from time to time.Incentives for Other Abound Activities. Abound may, from time to time offer incentives for other activities, such as shopping with preferred partners, using Abound’s financial offerings, or other activities as Abound may designate from time to time. By registering with Abound, you may be eligible to participate in these Programs as well.(2) Information Collected. We collect different categories of information based on the Programs you chose to participate. This includes your name, address, email address, phone number, information relating to products you purchased through us, internet usage or network activity information, data about your conversations and communications etc. For details, you may refer to “Information We Collect” section of the Abound Privacy Policy.(3) Value. TOI does not assign independent monetary value to personal information collected in connection with the Programs. The precise value each participant receives from the Programs can vary greatly by individual, and depends on the benefits and insights that We realize and expect to realize when you continue to purchase with us, sales directly or indirectly generated from participation in each Program, whether the sales generated by the Programs exceed the cost to us of offering the Programs, how many users sign up for the Programs and increased goodwill towards us. To the extent that TOI calculates a value for personal information it collects through the Programs, it does so in good faith based on the expenses related to the collection and retention of personal information as part of the Programs. TOI estimates in good faith that the value of personal information TOI receives through the Programs is reasonably related to, and generally less than, the value that the Programs provide to participants. The disclosure of the value calculations described is not intended to waive, nor should be interpreted as a waiver to, our proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.(4) Consent and Withdrawal. If you choose to participate in any of the Programs described above, please register with Abound. To sign up for a Program, you will need to provide certain personal information. Participation is entirely voluntary, and by signing up, you consent to the collection, use, and sharing of personal information in connection with the Program. You have the right to withdraw from any Programs at any time. To withdraw your consent, please follow the instructions set forth in the Terms of Use.Please note that if you choose to exercise your rights to opt-out of direct marketing or the sale of your personal information as is understood under the California Consumer Privacy Act (CCPA), your participation in the Programs above will not be affected and you will continue to receive all the benefits to which you are entitled. If you make a request to delete all your personal information, We will no longer be able to provide you with any Program benefits because We are unable to relate you to the benefits you are entitled to under the Programs.