Introduction: What Is FCC and Why Does FCC Process Protected Information
A. What Does Privacy Policy Cover?
B. What Protected Information Does FCC Process?
- Protected Information Provide to Us
- Protected Information Processed Automatically
- Contacts by E-mail
- Protected Information Purchased from Third Parties
- Special Categories of Protected Information
- Protected Information FCC Has Processed in the Last 12 Months
C. What Does FCC Do With Protected Information?
- Processing of Protected Information
- Storage of Protected Information
D. Will FCC Disclose Protected Information?
- Third Party Service Providers
- Business Transfers
- Legal Obligations, Protection of FCC, and Protection of Others
- Consent
- Protected Information FCC Disclosed to Third Parties in the Last 12 Months
E. What Are FCC’s Legal Bases for Processing Protected Information?
F. How Long Will FCC Retain Protected Information?
G. What Are Individuals’ Rights With Respect to Protected Information About Them?
- Requests to FCC
- Authorized Agent
- Do Not Sell
- Object or Challenge
- Filing a Complaint
- Prohibit Automated Processing
- Accessibility for Users with Disabilities
- Non-Discrimination
H. What Are FCC’s Financial Incentives?
I. Is Protected Information Secure?
J. Children’s Privacy
K. Contractual or Statutory Requirements
L. Failure to Provide Protected Information
M. Automated Decision Making
N. Transfer of Data
O. Changes to Privacy Policy
P. Contact Information
Q. Effective Date
Introduction: What Is FCC and Why Does FCC Process Protected Information
Fred C. Church, Inc. (FCC) is an insurance broker. FCC’s services including the following: (1) assisting existing and potential clients to evaluate and manage risk; (2) securing insurance for existing and potential clients; and (3) providing existing and potential clients with other related services. All such services are referred to, collectively, in this Privacy Policy as Services. In the course of providing Services, FCC Processes Protected Information from and about potential and existing clients, as well as their employees, officers, directors, managers, shareholders, owners, members, partners, parent companies, subsidiaries, affiliates, spouses, children, parents, other family members, friends, guests, visitors, and other individuals about whom potential and existing clients provide Protected Information for the purposes of FCC providing Services. In addition, FCC Processes Personal Information from and about individuals who access or use FCC’s websites, portals, applications, and other resources, communicate with FCC employees and agents, or otherwise provide Protected Information to FCC. This Privacy Policy informs individuals about FCC’s Processing of Protected Information about them. Individuals accept and consent to this Privacy Policy by retaining or seeking to retain FCC to provide any Service, accessing or using FCC’s websites, portals, applications, or other resources, communicating with FCC employees and agents, or otherwise providing Protected Information to FCC.
A. What Does Privacy Policy Cover?
This Privacy Policy covers FCC’s Processing of personally identifiable information (PII) covered by Security Regulations, personal health information (PHI) covered by HIPAA, and personal information (PI) covered by Privacy Regulations. PII, PHI, and PI are referred to, collectively, in this Privacy Policy as Protected Information.
PII means the following: (1) the last name of an individual, together with that individual’s first name or the first initial of that individual’s first name, in combination with (2) any of the following for that individual: (a) social security number; (b) governmental identification number, including driver’s license, non-drivers identification, passport, military identification, Medicaid or Medicare identification, etc.; (c) bank, credit, debit, insurance, investment, or other financial account number, with or without any username, password, personal identification number, or other code necessary to access or control such account; (d) password, personal identification number, or other code used to access or control any email, online, social media, or bank, credit, debit, insurance, investment, or other financial account; (e) biometric information; (g) geolocation information; and (g) any other information covered by a Security Regulation; provided that this term does not include any information that is generally publically available, including from any local, state or federal governmental records, as long as such information did not become generally publically available through the violation of a person’s obligation to maintain the confidentiality of that information, including pursuant to this Privacy Policy, Security Regulations, Privacy Regulations, or an applicable confidentiality agreement; and provided further that this Privacy Policy applies to PII only if and to the extent FCC Processes PII that is subject to Security Regulations and FCC is subject to such Security Regulations.
PHI means (1) information related to the physical or mental health or condition of an individual, health care provided to an individual, or payment for health care for an individual, where (2) the information identifies the individual or there is a reasonable basis to believe the information can be used to identify the individual; provided this Privacy Policy applies to PHI only if and to the extent FCC Processes PHI as a business associate of a covered entity under HIPAA.
PI means information that FCC Processes about an individual that is identified or identifiable to that individual. This term may include the following: (1) real name and alias; (2) mailing and physical address; (3) email account; (4) account name; (5) telephone and cellular phone number; (6) unique identification number; (8) online identifier; (9) internet protocol (IP) address; (10) Internet search and browsing activity and history; (11) interaction with an Internet website, application, or advertisement; (12) geolocation information; (13) biometric information; (14) property ownership, (15) professional and employment information; (16) education information; (17) income, credit, and other financial information; (18) information about any legally protected classification to which an individual belongs or may belong, including age, race, national origin, gender, gender identity, sex, sexual orientation, trade union membership, religion, religious affiliation, political party membership, and political affiliation; (18) information derived from other PI to create a profile about an individual; and (19) any other information that constitutes PI under any Privacy Regulations; provided that this term does not include any information about an employee or contractor of FCC unless explicitly governed by a Privacy Regulation; provided further that this term does not include any information that is generally publically available, including from any local, state or federal governmental records, as long as such information did not become generally publically available through the violation of a person’s obligation to maintain the confidentiality of that information, including pursuant to this Privacy Policy, Security Regulations, Privacy Regulations, or an applicable confidentiality agreement; and provided further that this Privacy Policy applies to PI only if and to the extent FCC Processes PI that is subject to Privacy Regulations and FCC is subject to such Privacy Regulations.
Security Regulations means domestic and foreign laws, rules, and regulations governing PII or PHI (including domestic state information security and breach notification laws and HIPAA’s Security Rule), administrative regulations adopted under them, and published administrative and judicial interpretations of them; provided that Security Regulations apply to FCC only if and to the extent FCC is subject to them and Processes PII or PHI governed by them.
HIPAA means the Health Insurance Portability and Accountability Act of 1996, the Health Information Technology for Economic and Clinical Health Act of 2009, and amendments to them, administrative regulations promulgated under them, and published administrative and judicial interpretations of them; provided this Privacy Policy applies to PHI only if and to the extent FCC Processes PHI as a business associate of a covered entity under HIPAA.
Privacy Regulations means domestic and foreign laws, rules, and regulations governing the Processing of PI (including the European Union General Data Privacy Regulation (GDPR), Canadian Personal Information Protection and Electronic Documents Act and similar Canadian Provincial laws like the Personal Information Protection Acts (collectively, PIPEDA), California Consumer Privacy Act (CCPA), California Online Privacy Protection Act, New York Stop Hacks and Improve Electronic Data Security Act, HIPAA Privacy Rule, and Children’s Online Privacy Protection Act), administrative regulations adopted under them, and published administrative and judicial interpretations of them; provided that Privacy Regulations apply to FCC only if and to the extent FCC is subject to them and Processes PI governed by them.
Process (and derivations of that word) means to handle information in any way, including the following: (1) create; (2) receive, collect, acquire, record, and purchase; (3) store, retain, and maintain; (4) access; (5) use; (6) modify and supplement; (7) transmit; (8) transport; (9) disclose, transfer, and sell; and (10) erase, delete, destroy, and discard.
FCC’s commitments under this Privacy Policy do not govern or apply to third parties that FCC does not own or individuals that FCC does not employ.
B. What Protected Information Does FCC Process?
FCC Processes only the types and amounts of Protected Information that are necessary or appropriate to provide Services. FCC Processes the following Protected Information.
1. Protected Information Provided to FCC
FCC Processes Protected Information from individuals as follows:
- Individual communicate with FCC through FCC’s websites and by email, mail, in person, phone, text, chat, or any other paper and electronic form. When individuals do so, FCC may Process name, contact information (including phone number, email address, work and/or home address), the content of any communication, the metadata associated with any communication, and other such Protected Information. Phone calls may be monitored or recorded.
- When individuals complete a “Request a Quote” form on FCC’s website, the information may include or an individual may choose to include, the following: name, state of residence, job title, employer, employer’s industry, types of insurance inquired about, phone number, email address, home address, work address, how the individual heard about FCC, any other information the individual provides to FCC, and other such Protected Information.
- When an individual creates or manages an account through FCC’s websites, portals, or other applications, the individual may provide the following: name; contact information (including home phone number, work phone number, personal email address, work email address, work address, and home address); date of birth; demographic information (including age, gender, household income, and marital status); family information (including name, age, gender, date of birth, contact information, marital status, insurance information for, and data concerning the health of a partner or spouse, children, and other family members); insurance information (including carrier name, policy numbers, types of policies, maximum coverage of each policy, individuals covered by each policy, personal property and real estate covered by each policy, and terms of each policy); information concerning health; information regarding accidents or other damage or injury to real estate, persons, or property; a user name or email address that would permit access to the FCC account; any other information the individual may provide to FCC, and other such Protected Information.
- When an individual retains or seeks to retain FCC to provide Services, the individual may provide all types of Protected Information to FCC, including the following: name; contact information (including home phone number, work phone number, personal email address, work email address, work address, and home address); date of birth; demographic information (including age, gender, household income, and marital status); social security number; passport number; driver’s license or state identification number; physical description (including height, weight, and physical characteristics); signature; education; current employment; employment history; employer’s information; family information (including name, age, gender, date of birth, social security number, contact information, marital status, accidents, injuries, employment, insurance information for, and information concerning the health of partner or spouse, children, and other family members); underwriting information (including driver license numbers; dates of birth; social security numbers; financial information; business plans; and health benefits); insurance information (including the carrier name, policy numbers, type of policies, maximum coverage of each policy, individuals covered by each policy, personal property and real estate covered by each policy, and terms of each policy); claims information (including description of accidents, damages, or injuries, and information regarding other people involved); immigration status; employee benefits information (including policies, coverages, and claims); security and travel plan arrangements; information concerning property and services purchased or obtained; health information; information revealing racial or ethnic origin; information about sexual orientation; information regarding damage to, or accidents involving, real estate, persons, or personal property; any other information the individual may provide to FCC: and other such Protected Information.
- When an individual applies for employment, FCC may Process or the individual may choose to provide the following: name, contact information (including phone number, email address, work and/or home address), date of birth, demographic information (like gender, age, household income, nationality, and race and ethnicity), immigration status and documentation, schooling and education information, disability information, recommendations, employment information and history, information from interviews, user name or e-mail address, any other information the individual may provide to FCC, and other such Protected Information.
An individual can choose not to provide FCC with Protected Information. However, doing so will affect FCC’s ability to communicate with, provide Services to, employ, or otherwise interact with that individual.
2. Protected Information Processed Automatically
When accessing or using FCC websites and applications, certain information may be passively Processed using various technologies, such as IP addresses and cookies.
- An IP address is a number assigned to a computer by an Internet service provider to access the Internet. In most consumer cases, an IP address is dynamic (changing each time connect to the Internet), not static (unique to a particular user’s computer).
- Cookies are small text files that are placed on computer by websites. They are widely used to make websites work more efficiently, and to provide information to the owners of the site. Most web browsers allow some control of cookies through browser settings. FCC may Process the following information via cookies: aggregate statistical information, information related to use of websites, IP address, device type, and browser type. An individual may be able to change the preferences on a browser or mobile device to send “do not track” signals or to prevent or limit a device’s acceptance of cookies, but this may change the functionality of the websites. If an individual clicks on a link to a third party website, such third party may also transmit cookies. This Privacy Policy does not cover the use of cookies by any third party.
FCC communicates with individuals by email. When it does so, it may receive a confirmation when an individual opens an email, which helps FCC improve its Services. If an individual does not want to receive unsolicited marketing email from FCC, that individual can indicate that preference by clicking on the unsubscribe link in such a FCC email or by contacting FCC using the contact information provided below. Please note that, if an individual does not want to receive emails or notices from FCC, those notices will still govern the individual’s interactions with FCC, and the individual remains responsible for reviewing and adhering to such notices, including this Privacy Policy and the Terms of Use on FCC’s website.
4. Protected Information Purchased or Otherwise Acquired from Third Parties
FCC purchases contact information for potential clients from direct marketing lead generation services. FCC Processes that information for marketing and development purposes. FCC does not sell or otherwise transfer this information to any third party.
FCC may obtain the following information from the registry or department of motor vehicles in the state where individuals live: name; license plate type and number; registration number; driver’s license number; vehicle identified number; date of birth; and insurance information. FCC uses this information to support its provision of the Services.
FCC may obtain insurance scores from Lexus Nexus. FCC uses this information to support its provision of the Services.
FCC may obtain the following information from insurance carriers: insurance score, insurance claims, history with carrier, social security number, date of birth, gender, and the social security number, date of birth, and gender of family members. FCC uses this information to support its provision of the Services.
5. Special Categories of Protected Information
From time-to-time, FCC Process the following special categories of Protected Information for the purposes of providing Services: information about age, race, national origin, gender, gender identity, sex, sexual orientation, trade union membership, religion, religious affiliation, political party membership, and political affiliation. FCC does not knowingly Process other special categories of Protected Information, including genetics, biometrics, and sexual activity.
6. Protected Information FCC Has Processed in the Last 12 Months
Except as excluded in the Section B(5), FCC has Processed all types of Protected Information in the 12 months immediately preceding the Effective Date of this Privacy Policy.
C. What Does FCC Do With Protected Information?
1. Processing of Protected Information
FCC Processes Protected Information for any and all legal and legitimate businesses purposes, including the following: (a) communicate with individuals; (b) conduct FCC’s business operations; (c) provide Services; (d) operate, maintain, and improve FCC’s websites and other applications; (e) evaluate and hire potential employees; (f) prepare and manage events; (g) investigate and resolve disputes and other issues; (h) disclose to third parties as set forth in this Section and Section D; and (i) any other lawful and legitimate business purpose.
2. Storage of Protected Information
Unless noted otherwise in this Privacy Policy, FCC stores all Protected Information in the United States. Third parties to whom FCC discloses Protected Information may store that Protected Information in other countries.
D. Will FCC Disclose Protected Information?
FCC disclosed Protected Information to third parties as described below. This Privacy Policy does not govern or apply to any third party that FCC does not own.
1. Third Party Service Providers
FCC discloses Protected Information to third parties necessary or appropriate to provide Services, including insurance carriers, wholesale and other insurance brokers, public adjustors, managing general agents and underwriters, and any other third party that an individual requests or authorizes FCC to disclose Protected Information about them to or that is necessary or appropriate for FCC to disclose Protected Information to in order to provide Services.
2. Business Transfers
FCC may sell its assets. In these types of transactions, Protected Information is one of the assets transferred. If FCC sells all or substantially all of its assets, or if FCC goes out of business, enters bankruptcy, or goes through some other change of control, Protected Information would be one of the assets transferred to or acquired by a third party.
3. Legal Obligations, Protection of FCC, and Protection of Others
FCC will Process any Protected Information that FCC reasonably believes is necessary or appropriate to comply with law or court order, enforce or apply FCC’s Privacy Policy, Terms of Use, and other agreements, or protect the rights, property, or safety of FCC, our employees, our users, the public, or others. This includes disclosing Protected Information to third parties for fraud protection and credit risk reduction.
4. Consent
Except as set forth above, we will obtain consent from an individual before disclosing Protected Information about that individual to a third party.
5. Protected Information FCC Disclosed to Third Parties in the Last 12 Months
The CCPA defines a “sale” of Protected Information broadly. In the traditional sense, FCC does not sell Protected Information. However, FCC discloses Protected Information to third parties in the course of providing Services, as described in this Section. In the course of doing so, except as noted in Section B(5) above, FCC has disclosed to such third parties all categories of Protected Information in the 12 months immediately preceding the Effective Date.
E. What Are FCC’s Legal Bases for Processing Protected Information?
FCC Processes Protected Information for the following purposes: (1) to provide Services, (2) for FCC’s legitimate business interests; and (3) pursuant to consent. Individuals hereby grant FCC such consent by confirming the prompts produced by FCC’s websites and other applications, retaining or seeking to retain FCC to provide Services, applying for employment with FCC, communicating with FCC employees, or otherwise providing Protected Information to FCC. If and to the extent an individual revokes such consent or objects to or restricts FCC’ Processing Protected Information about them, doing so will affect FCC’s ability to communicate with, provide Services to, employ, or otherwise interact with that individual.
To the extent that an individual gives FCC Protected Information about another individual, the individual providing such Protected Information will ensure, and hereby represents to FCC, that each such other individual has consented to FCC’s Processing of Protected Information about that individual, if and to the extent Privacy Regulations require such consent.
F. How Long Will FCC Retain Protected Information?
Except upon the request of an individual, as explained in Section G below, and except as Privacy Regulations permit or require otherwise, FCC will determine the retention period of any Protected Information based on the following criteria:
- nature of FCC’s relationship with the individual;
- existence of other ongoing or expected projects with the individual;
- nature of the Protected Information; and
- FCC’s business needs.
G. What Are Individuals’ Rights With Respect to Protected Information About Them?
Except where permitted or required by Privacy Regulations, individuals have the following rights regarding FCC’s Processing of Protected Information about them.
1. Requests to FCC
An individual may request the following from FCC with respect to Protected Information about that individual: (1) correction, updating, and restriction of FCC’s Processing of Protected Information; (2) a summary of the categories of Protected Information FCC Processes or the Protected Information FCC has Processed, and a summary of such Processing; (3) a summary of the sources that FCC receives Protected Information from; (4) the purposes for Processing Protected Information; (5) a copy of Protected Information to be delivered in a structured, commonly used and machine readable format to review or to transfer or transmit to another entity, to the extent technically feasible; (6) a list of the third parties that FCC has disclosed Protected Information to and contact information for them; (7) a summary of the categories of Protected Information that FCC has disclosed to third parties; and (8) the erasure or deletion of Protected Information.
If an individual requests that Protected Information be erased or deleted or that FCC otherwise restrict its Processing of Protected Information, FCC may terminate or limit that individual’s access to FCC’s websites, applications, and Services. If FCC does not have Protected Information, has not Processed Protected Information, or has not disclosed Protected Information to another party, FCC will inform the individual of that in response to such a request. Some information may remain in FCC’s backup media after erasure or deletion for a period of time. When an individual requests that FCC update information, FCC may retain a copy of the unrevised information in FCC’s records. FCC also may use any anonymized aggregated statistical data derived from or incorporating Protected Information after it is updated, erased, or deleted, but not in a manner that would identify the individual.
FCC responds to such requests within 30 days, subject to a lawful extension of that period, and there may be a delay in processing a request while FCC verifies that the request is authentic. FCC’s verification varies based on the source and nature of the request, but may include: comparing data in the request against Protected Information FCC retains; contacting the individual using other contact information; and requesting further information. To the extent permitted by Privacy Regulations, FCC may deny any request if FCC cannot verify that it originated from the individual about who the Protected Information pertains.
Individuals may make any of the foregoing requests by contacting FCC using the contact information provided below.
2. Authorized Agent
An individuals may authorize an agent to take any of the act permitted in this Section G on behalf of the individual. To do so, the individual must provide written and signed authority to the agent, and written and signed notice to FCC that FCC may act on such requests by that agent. Individuals may withdraw such authorization at any time by contacting FCC using the contact information provided below. Such withdrawal does not affect the lawfulness of FCC’s Processing of Protected Information before such withdrawal based on such authorization.
3. Do Not Sell
Other than providing Protected Information to third parties as described in Section D, FCC does not “sell” Protected Information, as that terms is defined in the CCPA. An individual may opt out of FCC’s disclosure of Protected Information about that individual to third parties by contacting FCC using the contact information provided below, or by completing the form at the following link: insert link.
FCC will comply with a request to opt out of all the disclosure of Protected Information as soon as feasibly possible, but no later than 15 business days after receiving request. FCC will not contact the individual about opting in to disclosing Protected Information for at least 12 months following receipt of the request.
Instructing FCC to not disclose Protected Individual to third parties will impact FCC’s ability to provide risk management and insurance brokerage services to the individual.
4. Object or Challenge
Individuals may object to, or otherwise challenge, FCC’s Processing of Protected Information. An individual may do either by contacting FCC using the contact information provided below or by completing the form at the following link: insert link.
FCC will respond within 30 days. Where such objection is received from an individual whose Protected Information FCC Processes as the processor for a controller (as those terms are defined in the GDPR), FCC will inform the controller of the objection within 30 days.
5. Filing a Complaint
Regulatory authorities that oversee Privacy Regulations and Security Regulations typically advise individuals to file an objection or challenge with the company before lodging a formal complaint with a regulatory authority. If an individual is dissatisfied with FCC’s response to an objection or challenge filed under Section G(4), or wishes to file a complaint with a regulatory authority first, the individual may do so, including as follows:
PIPEDA: Office of the Privacy Commissioner of Canada;
GDPR: a supervisory authority in the relevant European Union member state;
CCPA: California Attorney General; and
Security Regulations: Attorney General for the state in which the individual resides.
6. Prohibit Automated Processing
At the request of an individual, FCC will terminate any automated decision making, including profiling, that is the sole source of decisions that produce a legal effect concerning or similarly significantly affecting the individual. Consistent with Section M, FCC does not use any such automated decision making or profiling at this time.
7. Accessibility for Users with Disabilities
If an individual is unable to review this Privacy Policy or any portion of this Policy, the individual should contacting FCC using the contact information provided below to request that FCC provide this Privacy Policy in an alternative format.
8. Non-Discrimination
FCC will not discriminate against any individual because the individual has exercised any of the right under this Privacy Policy, Privacy Regulations or Security Regulations, including by not doing any of the following: (a) denying any Service to the individual; (b) charging the individual a different price or rate for Services, including through the use of discounts or other benefits or imposing penalties; (c) providing a different level or quality of Services to the individual; and (d) suggesting that the individual will receive a different price or rate for Services or a different level or quality of Services. Consistent with Privacy Regulations, FCC may do the following: (e) charge a different price or rate, or provide a different level or quality of goods or services to the individual if that difference is reasonably related to the value provided to FCC by Protected Information; (f) offer financial incentives, including payments to the individual as compensation, for the Processing of Protected Information; and (g) enter into a financial incentive program if FCC clearly describes the material terms of the financial incentive program and the individual gives FCC prior opt-in consent, which may be revoked at any time; provided that FCC will not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.
H. What Are FCC’s Financial Incentives?
FCC does not offer any financial incentives for providing Protected Information.
I. Is Protected Information Secure?
FCC employs reasonable and appropriate technological, physical, and administrative measures to safeguard the confidentiality, integrity, and availability of Protected Information. Individuals seeking additional information about such safeguards may contact FCC using the contact information provided below.
FCC websites and applications may contain links to other sites and third party content. FCC is not responsible for the security or privacy provided by such third parties.
J. Protected Information About Children
FCC does not knowingly Process Protected Information from or about anyone under the age of 16 without first obtaining verified parental consent. If an individual is under the age of 16, the individual may not register or attempt to register for an account on any FCC website, retain FCC to provide any Services, or give any information to FCC. If and to the extent FCC learns that it has Processed Protected Information from a child under age 16 without verified parental consent, FCC will either delete that Protected Information or obtain verified parental consent to Process that Protected Information. If any individual believes that FCC may have received any Protected Information from a child under age 16 without first obtaining verified parental consent, the individual should contact FCC using the contact information provided below.
K. Contractual or Statutory Requirements
Except as noted in this Privacy Policy or any contract governing the Services that FCC provides, FCC’s Processing of Protected Information is not a contractual or statutory requirement or a requirement necessary to enter into a contract.
L. Failure to Provide Protected Information
Individuals can opt not to disclose information to FCC. If and to the extent an individual elects to do so, that decision will affect FCC’s ability to communicate with, provide Services to, employ, or otherwise interact with that individual.
M. Automated Decision Making
FCC does not rely on automated decision making, including profiling, that will produce legal effects concerning or similarly significantly affecting any individual. Pursuant to Article 4(4) of the GDPR, profiling is defined as “any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse [sic] or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior [sic], location or movements.”
N. Transfer of Data
If and to the extent that FCC transfers Protected Information from another country into the United States, FCC does so in compliance with the Privacy Regulations and Security Regulations of the originating country.
O. Changes to Privacy Policy
FCC may amend this Privacy Policy from time to time. FCC’s Processing of Protected Information is subject to the Privacy Policy in effect at the time such Processing occurs. If FCC changes this Privacy Policy, FCC will notify individuals by posting an announcement on our websites or sending an email.
P. Contact Information
All questions, concerns, or requests about or under this Privacy Policy or about FCC’s Processing of Protected Information should be directed to FCC as follows:
41 Wellman Street, Lowell, MA 01851
Q. Effective Date
This Privacy Policy is effective as of September 17, 2020.
