CentiMark Supplemental Privacy Notice

For California and Other US Residents

Last Updated June 2026 

1. Overview 

CentiMark Corporation (“CentiMark”, “we”, “our” or “us”) prepared this US Supplemental Privacy  Notice (“Supplemental Notice”) to supplement the practices described in CentiMark’s Online  Privacy Notice, and it applies only to information collected about individuals covered by California’s Consumer Privacy Act (“CCPA”) and other similar privacy laws in the United States  (collectively, “US State Privacy Laws”). This Supplemental Notice is parallel in scope to  CentiMark’s Online Privacy Notice and should be read in conjunction with that notice. Some  portions of this Supplemental Notice apply only to consumers of particular states. In those  instances, CentiMark has indicated that such language applies only to those consumers. Any  terms defined in the CCPA or other State Privacy Laws have the same meaning when used in  this Supplemental Notice. 

As used in this Supplemental Notice, “Personal Information” means information that identifies,  relates to, describes, is reasonably capable of being associated with, or could reasonably be  linked, directly or indirectly, to you or your household or device. Personal Information includes the categories of Personal Information identified below if such information identifies, relates to,  describes, is reasonably capable of being associated with, or could be reasonably linked,  directly or indirectly, with a particular individual or household. Personal Information does not include: 

• Publicly available information from government records 

• De-identified or aggregated consumer information, including pseudonymized data  CentiMark receives from third parties 

• Other information exempted from the State Privacy Laws’ scope, such as: o Personal Information governed by certain sector-specific privacy laws,  including the Gramm-Leach-Bliley Act (“GLBA”), the Fair Credit Reporting  Act (“FCRA”), or the California Financial Information Privacy Act (“FIPA”). o Health or medical information governed by the Health Insurance Portability  and Accountability Act of 1996 (HIPAA) and the California Confidentiality  of Medical Information Act (CMIA). 

CCPA and other State Privacy Laws grant residents certain rights regarding the Personal  Information that businesses have about them. These include (a) the right to know about  Personal Information categories the business collected about you in the prior 12 months, the  source of such information, the purpose for collecting the information and the specific  information collected about you; (b) the right to request access or deletion of your Personal  Information, (c) the right to request correction of your Personal Information as well as (d) the  right to direct a business to stop selling your Personal Information. While CentiMark does not  sell Personal Information to third parties for monetary consideration, the CCPA and other laws  broadly define “sale” and “sharing” in such a way that certain data collected on CentiMark’ Site  by third parties for interest-based advertising purposes may have been considered a “sale” or  “sharing” under CCPA. The categories of third parties to whom Personal Information is  disclosed include advertisers and marketing partners and data analytics providers. The  categories of information CentiMark may share with such parties may include device information 

and identifiers, such as IP address, and unique advertising identifiers and cookies; usage  information, such as browsing history; location information, such as city; and inference data.  California residents can turn on the Global Privacy Control (“GPC”) to opt out of the “sale” or  “sharing” of Personal Information for each participating browser system that they use.  

2. Categories of Personal Information Collected and Business Purposes for  Processing 

CentiMark collects the following categories of Personal Information for the purposes described  below, as permitted by applicable law. These categories are defined by California law and  represent the Personal Information that CentiMark may have collected about California  residents, and how it may have been shared, over the past 12 months. The business purposes  for processing such information are provided below the chart. The inclusion of a category in the  list below indicates only that CentiMark may collect this information for certain individuals for  some activities within the scope of the identified business purpose. It does not necessarily mean  that CentiMark collects all the information listed in a particular category for all individuals. 

CentiMark has shared information in each category with its affiliates and service providers for its  business purposes within the last 12 months. CentiMark may also receive requests for  information from regulatory authorities, its auditors, and/or legal advisors. If requested from such  parties, CentiMark would share your Personal Information as appropriate: 

Personal Information Collected Directly from Employees and Prospective Employees

CATEGORY OF  

PERSONAL  

INFORMATION

TYPES OF INFORMATION COLLECTED

Personal Identifiers

Real name, alias, date of birth, residential address, postal  address, telephone number, unique personal identifiers  including online identifiers, internet protocol (IP) address, email  address, Social Security number, driver’s license or state  identification card number, passport number, visa information,  written signature, insurance policy number, or other similar  identifiers.

Demographic Identifiers

Demographic information protected under federal law, CCPA or  other State Privacy Law, including age, sex, gender, sexual  orientation, racial or ethnic origin, national origin, citizenship,  residency, or immigration status, marital status, health and  physical or mental disability status, or military/veteran status.

Employment Information

Employment history, occupation, position, professional  licensures, salary information, professional or employment related information, including written signatures, and other  information collected from a resume or application.

 

Education

Education history, including educational institutions attended,  degree(s) and/or certification(s) earned, and other information  collected from a resume or application.

Financial Information

Financial information including bank account number, source of  funds for the contract or policy, source of wealth, assets, or  other financial information.

Medical or Health  

Information

Medical information, including any information in possession or  derived from a healthcare provider, healthcare service plan,  pharmaceutical company, or contractor regarding an individual’s  medical history, mental or physical condition, or treatment.  Health insurance information including an individual’s insurance  policy number or subscriber identification number, any unique  identifier used by a health insurer to identify the individual,  transaction information, or any information in the individual’s  application and claims history.

Internet or other Electronic  Network Activity

Online identifiers, internet protocol (“IP”) address, and  information regarding an individual’s interaction with our website  including page visits, browsing or search history, including when  browsing anonymously, or an individual’s device interaction with  an internet website application or advertisement as described in  our Online Privacy Policy.

Profile Information 

Inferences drawn from any of the information listed above,  including creating a profile about you reflecting your  preferences, characteristics, psychological trends,  predispositions, behavior, attitudes, intelligence, abilities, and  aptitudes.

Audio/Visual Information 

On-site cameras for security, video, photos, and audio  recordings such as a recording of a customer service call.

 

3. Purposes for Which CentiMark Collects Personal Information 

CentiMark, and its Service Providers, collect and process the Personal Information (excluding  Sensitive Personal Information) described in this Supplemental Notice to: 

• Operate, manage, and maintain its business 

• Secure your account/policy with us 

• Respond to your inquiries and to fulfill your requests

• Use generative artificial intelligence models, including third-party external consumer data  and information sources, in compliance with applicable laws, to augment our products  and practices 

• Maintain quality assurance, including recording audio calls or voice messaging systems • Determine if a product or service may be suitable for you 

• Support or respond to your inquiries 

• Prevent fraud or other unlawful activities 

• Determine the effectiveness of promotional campaigns, so that CentiMark can adapt its  campaigns to the needs and interests of its users 

• Personalize, advertise, and market its products and services 

• Comply with law, legal process, and internal policies 

• Maintain records 

• Exercise and defend legal claims 

• Test or perform analysis, including data analytics and insights to improve its products • Otherwise accomplish its business purposes and objectives 

CentiMark also collects the below categories of Sensitive Personal Information as defined  under CCPA directly from Employees and Prospective Employees. 

 

CATEGORY OF SENSITIVE  PERSONAL INFORMATION

TYPES OF SENSITIVE PERSONAL INFORMATION  COLLECTED

Sensitive Personal  

Information / Not publicly  available

Social Security number, driver’s license number, state  identification card number or passport number, written  signature, policy number(s), health and physical or mental  disability status, racial or ethnic origin, national origin,  citizenship or immigration status, sexual orientation, or  physical characteristics or description.

 

In addition, CentiMark may use and disclose any Personal Information, including Sensitive  Personal Information, that CentiMark collects as necessary or appropriate to: 

• Comply with laws and regulations, including applicable tax, customer due diligence  (including identity verification), health and safety, anti-discrimination, immigration, labor  and employment, and social welfare laws. 

• Monitor, investigate, and enforce compliance with potential breaches of CentiMark’ policies and procedures and legal and regulatory requirements. 

• Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or  summons. 

• Detect, investigate, and help protect against malicious, deceptive, fraudulent, or illegal  activity. 

• Exercise or defend its legal rights, including employees, Directors, Officers, affiliates,  customers, contractors, and agents. 

4. Sources from Which CentiMark Collects Personal Information 

CentiMark may collect Personal Information directly from you, as well as from its affiliates,  business partners, joint marketing partners, public databases, providers of demographic data,  publications, professional organizations, social media platforms, third party information 

providers, affiliates with whom you have a business relationship, Service Providers with which  CentiMark has a contractual relationship and to which you have provided your personal  information, cookies and other tracking technologies, and Service Providers and Third Parties  when they share the information with CentiMark. CentiMark also collects Personal Information,  in certain instances, from data brokers and other information sources, as well as other public  databases. 

5. Disclosure of Personal Information 

Unless specifically stated, CentiMark has not sold or shared Personal Information about  California consumers with third parties for their own use in the past twelve months. CentiMark may, however, disclose Personal Information to third parties (e.g., Service Providers) for  business purposes. When CentiMark discloses Personal Information for a business purpose,  CentiMark enters into a contract that describes the purpose and requires the recipient to ensure  the information is confidential, and not to use it for any purpose other than performance of the  contract. For purposes of the CCPA, “selling” is the disclosure of Personal Information to a  Third Party for monetary or other valuable consideration, and “sharing” is the disclosure of  Personal Information to a Third Party for cross-context behavioral advertising, whether or not for  monetary or other valuable consideration. CentiMark has no actual knowledge that CentiMark sells or shares Personal Information of California consumers under 16 years of age. CentiMark may share your Personal Information as allowed by law for the business purposes described in  this Supplemental Notice with the following parties:

CATEGORY 

DESCRIPTION

Corporate Affiliates

CentiMark may share your information with  its corporate affiliates and with their  

respective officers, directors, employees,  accountants, attorneys, and agents.

Acquisitions and Similar Transactions

If CentiMark is sold or part of its assets are  merged with another company, your Personal  Information may be transferred as part of the  merger or sale.

Disclosures with Your Consent

CentiMark may ask if you would like it to  share your information with other unaffiliated  third parties not described elsewhere in this  Policy. CentiMark will only disclose your  information in this context with your consent.

Legal Obligations and Rights (Subpoenas,  Court Orders, and Warrants); Regulatory  Authorities

CentiMark may disclose information to  comply with the law, including disclosure to  relevant industry regulatory bodies, or in  response to subpoenas, warrants, court  orders, or other legal process.

Service Providers

CentiMark may share your Personal  Information or aggregated information with  third party Service Providers for purposes  such as providing operational or support services on CentiMark’ behalf including  servicing a contract, providing policy benefits,  or to prevent, detect, and investigate  deceptive, fraudulent, or illegal acts. Service  Providers may include vendors providing  software, platforms, or tools (including  generative AI tools) to perform operational or  business functions and augment CentiMark’  practices. Service Providers may provide  website tracking technologies such as  cookies, tags, or pixels that use anonymous  browsing information or Personal Information  as described in CentiMark’ Online Privacy  Notice.

Professional Advisors (Auditors and Legal  Advisors)

CentiMark may share your information with  our professional advisors, including  

attorneys, auditors, and accountants, to  provide services on its behalf.

De-identified or Aggregated Data

CentiMark may disclose aggregated  information or de-identified information about  our users that does not identify any specific  individual.

Other 

Where required or permitted by law.

6. Data Retention 

Depending on the product or service, CentiMark will retain your Personal Information only for  the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer  retention period is required or permitted by a law that applies to CentiMark. CentiMark keeps records containing Personal Information in accordance with applicable state and federal rules that apply to it. CentiMark considers the following criteria when determining how long to retain  Personal Information: why CentiMark collected the Personal Information; the nature of the  Personal Information; the sensitivity of the Personal Information; our legal obligations related to  the Personal Information; and the risks associated with retaining the Personal Information.  CentiMark aims to retain Personal Information only for as long as necessary for the purposes it  was collected for, including defending or advancing legal claims, and to comply with legal  obligations. CentiMark may need to keep some Personal Information for longer than other  information to comply with applicable laws and regulations, including litigation. 

7. Your Privacy Rights 

Exercising Privacy Rights. Consumers who live in California have certain rights with respect  to the collection and use of their Personal Information. You may access these data rights by  calling or e-mailing us as set out below:

 

CentiMark Corporation 

12 Grandview Circle 

Canonsburg, PA 15317 

Email: [email protected] 

Agents. Consumers in some states may also authorize an agent to make data subject requests  on their behalf. 

Verification of Data Subject Requests. CentiMark may ask you to provide information that will  enable us to verify your identity to comply with your data subject request. In particular, when a consumer authorizes an agent to make a request on their behalf, CentiMark may require the  agent to provide proof of signed permission from the consumer to submit the request, or  CentiMark may require the consumer to verify their own identity to us or confirm with us that  they provided the agent with permission to submit the request. In some instances, CentiMark may decline to honor your request if an exception applies under applicable law.  

There are circumstances in which CentiMark may not be able to comply with your access,  deletion, or other request, including when CentiMark cannot verify your request, or when there  is a conflict with our own obligations to comply with other legal or regulatory requirements.  Additionally, in certain instances, some information CentiMark collects from you may be  excluded from the definition of Personal Information as defined under applicable State Privacy  Laws, and, as such, this information is exempt from certain rights otherwise available to you.  CentiMark will respond to your request consistent with applicable law. 

Non-Discrimination. CentiMark will not discriminate against you for exercising your data  subject rights. For example, CentiMark will not deny goods or services to you, or charge you  different prices or rates, or provide a different level of quality for products or services as a result  of you exercising your data subject rights. 

Appeals. To appeal our decision on your data subject requests, you may send it to:  

CentiMark Corporation 

12 Grandview Circle 

Canonsburg, PA 15317 

ATTN: Privacy Appeals 

Email: [email protected] 

Please enclose a copy of or otherwise specifically reference the decision on your data subject  request, so that CentiMark may adequately address your appeal. CentiMark will respond to your  appeal in accordance with applicable law. 

1. Right to Access Your Data. You have the right to request that CentiMark disclose  certain information to you about our collection and use of your Personal Information for  the 12-month period preceding your request. California residents may request  information for the prior 24-month period. Once CentiMark receives and verifies your  identity, you have the right to receive: 

• The categories of Personal Information CentiMark collected about you. • The categories of sources for the Personal Information CentiMark collected about  you.

• The business or commercial purpose for collecting, selling or sharing that  Personal Information. 

• The specific pieces of Personal Information CentiMark collected about you,  including by a service provider or contractor. 

• The categories of third parties with whom CentiMark shared that Personal  Information. 

• The specific pieces of Personal Information disclosed for a business or  commercial purpose, identifying the Personal Information categories that each  category of recipient obtained about you. 

2. Right to Data Portability. You have the right to a “portable” copy of your Personal  Information that you have submitted to us. Generally, this means you have a right to  request that CentiMark move, copy or transmit your Personal Information stored on its  servers / IT environment to another service provider’s servers / IT environment. 

3. Right to Correction. You have the right to request correction or changes of your  Personal Information if it is found to be inaccurate or out of date. 

4. Right to Delete Your Data. You have the right to request that CentiMark delete any of  your Personal Information that CentiMark collected from you and retained, subject to  certain exceptions. Once CentiMark receives and confirms your verifiable consumer  request, CentiMark will delete (and direct its service providers to delete) your Personal  Information from its records, unless an exception applies. 

5. Right to Opt-Out of Sale or Sharing of Personal Information. CentiMark currently  does not sell Personal Information to third parties or share your Personal Information  with third parties for cross-context behavioral advertising purposes, and, therefore, this is  inapplicable to us. CentiMark may disclose Personal Information about you to its  affiliates and service providers as permitted by law. Please see the “Sharing Personal  Information” portion of this policy for more information. 

6. Right to Limit Use and Disclosure of Sensitive Personal Information. You have the  right to request CentiMark limit the use of your sensitive Personal Information to only  purposes necessary to engage with you. This sensitive Personal Information is defined  in California law, and you will find a more detailed description of what type of information  this entails in the charts included above. CentiMark does not use your sensitive Personal  Information for purposes other than those necessary to engage with you, to aid in  protecting and securing your Personal Information and its systems, to verify or maintain  the quality or safety of its services and systems, or as otherwise permitted under  regulations or required law. 

7. Right to Non-Discrimination. CentiMark will not discriminate against you for exercising  any of your privacy rights. 

8. Changes to Our US Supplemental Notice. 

CentiMark reserves the right to amend this US Supplemental Notice at our discretion and at any  time. When CentiMark makes material changes to this US Supplemental Notice, CentiMark will  post an updated Supplemental Notice on the Site listing the effective date of those updates. 

If you have any questions or comments about this US Supplemental Notice, the ways in which  CentiMark collects and uses your information described here, your choices and rights regarding  such use, or wish to exercise your rights under state privacy laws, please contact:

 

CentiMark Corporation 

12 Grandview Circle

Canonsburg, PA 15317

Email: [email protected]