Privacy Policy

Last Updated February 17, 2025

Diablo Media, LLC (“Company”, “we“, “us“, or “our“), is committed to protecting your privacy. This Privacy Policy outlines how your personal information is collected, used, and shared when you visit any of our websites or use our services. We collect personal data about you on different occasions, such as when you browse our websites (collectively, the “Website”) and request information about various resources and third-party partners promoted on the Website. Together, the Website, resources, and all other services provided by Company to you are referred to herein as the “Services.” This Privacy Policy, which is incorporated by reference into our Terms of Service, outlines how and when we collect, use, and share personal data from you and other users of our Services.

Who We Are

Diablo Media, LLC is an advertising network that provides advertising Services to its marketing partners and clients.

Company also owns and operates consumer-facing Websites that provide Website visitors with information on government grants and programs, consumer products, legal advocates, insurance providers, education, loans, household services, and other resources they may need from time to time (in each case, a “Resource”). These Resources are provided to interested persons by third-parties (collectively, “Resource Providers”). Resource Providers are not affiliated with Company and have their own contracts, rules, eligibility requirements, application fees, refund policies, and so forth as discussed more fully below.

Any information provided to or gathered by Company is controlled by:

Diablo Media, LLC
3001 Brighton Bld, Suite 769
Denver, CO 80211
United States

Third Parties

“Third Parties” include any person or entity other than you and our companies and employees. Third Parties include, but are not limited to, Resource Providers, our marketing partners, the suppliers, service providers, and other vendors that help us provide the Services.   The Website may include links to Third Party websites and apps.

Unless otherwise expressly stated, this Privacy Policy does not apply to any Third-Party practices, websites, mobile apps, or services. Third Parties may have their own privacy practices and policies, which you should review before engaging with their platforms and services.

Our Collection of Personal Data

How We Collect Personal Data

We collect personal data directly from you at various points during your interactions with us, including use of our Website. We primary collect personal data when you engage with us, whether through the Website, in person, or other means, such as:

• When you enter into a written agreement for advertising Services with Company, such as a Client Agreement;
• When you meet us at a trade show or other event and give us your contact information;
• When you interact with us through off-Website social media or instant messaging platforms;
• When you browse or complete a form on the Website;
• When you click on a link in a Company advertisement;
• When you communicate with us, such as by speaking to one of our customer service agents;
• When you post content to the Website, such as a review (“your Content”);
• When you sign up to receive email, text/SMS, or other communications from us or our Resource Providers;
• When you participate in a survey, contest, or sweepstakes administered by Company; and/or
• When you apply for a job with Company.

We collect personal data from Third Parties, such as:

• When you engage with a Resource Provider or other Third-Party.

Like most websites and apps, we collect data through automated technologies on our Website, such as cookies, web beacons and pixels. These practices are discussed more fully in the section below entitled Cookies and Other Data Technologies.

Categories of Personal Data Collected

Through the methods identified herein, we collect the following categories of personal data:

Identifiers

We collect basic contact information, such as name, the company you work for, address, phone number, mobile number, email address, date of birth, citizenship, and gender.

Commercial Data

We collect transaction information, such as details about your interests in specific resources, other products and Services you have purchased or considered, and your purchasing tendencies. For B2B clients of our advertising Services, Company also collects payment information, such as payment account and billing information, details about the Services performed and payments between the parties. Company does not collect payment information from consumers.

We may collect or create inferences, such as creating a consumer profile for you or a group of customers relating to consumer preferences and trends.

Personal Background

We collect certain protected class information, such as disability (e.g., when you seek SSDI resources), and age. We may also collect race, national origin, marital status, sex, and age when such details are pertinent to the resources you are investigating through the Website.

We collect employment information when you apply for a job with Company, including your contact information, government-issued identification, professional licenses and credentials, union membership, employment history, educational background, citizenship and immigration status, military service, and references.

Audio and Visual Data

We may collect audio and visual data during your use of the Website. For example, we and/or our Third-Party service providers may use screen recordings or keystroke logs to record your consent to be contacted by email, mail, telephone, or text message (SMS).

We create and store certain call recordings. When you call our customer service agents, your call may be recorded or monitored for quality assurance purposes and/or for legal compliance.

We may collect audio and visual data from you if you upload it to the Website as part of your Content, or if you authorize us to use or share Content posted to your Third-Party social media account(s).

Health Data

We collect health data when you provide it to us, including when you request resources relating to a disability or medical treatment.

Communications

We collect any information you communicate to us, such as to customer service agents, or via a feedback form, regardless of whether it fits into one of the other categories of personal data outlined herein. Such information is volunteered by you and we do not collect it surreptitiously.

When you communicate with us via any live chat feature on our Website, your live chat transcripts may be monitored or reviewed by the Third-Party live chat service provider.

We also collect information you communicate to Third Parties through the Website, including the contents of messages where we are not a recipient.

Geolocation

We collect general geolocation data from users of the Website by ascertaining approximate location (e.g., city or country) from the user’s IP address. We do not collect or track precise geolocation data.

Other Personalized Data

We may collect other personalized data on a case-by-case basis, but only when you expressly consent to the same before it is collected.

Non-Personalized Data

We collect device, internet, and network data, such as the type of device (e.g., computer, smart phone, tablet), device ID, MAC address, mobile carrier, phone number, operating system, IP address, internet service provider, browser language, browsing history, search history, advertising ID, and any other information regarding your interaction with the Website or a Company advertisement. See below for more information about cookies and other tracking technologies.

We may collect or create aggregate information or de-identified data from the personal data collected. For example, we may combine the personal data of multiple users of the Website to create data that no longer identifies the users on an individual basis but speaks to behavioral or consuming patterns. If we combine aggregate information or de-identified data with personal data, we will treat it as personal data in accordance with the provisions of this Privacy Policy.

Our Use of Personal Data

We use personal data for the same reasons that we collect it. Specifically, we process personal data for the following purposes:

Sensitive Personal Data

Certain categories of personal data collected—such as Health Data, protected class information, and some of your communications with Third Parties (e.g., email, text, or direct messages where we are not a recipient)—may qualify as “Sensitive Personal Data” under applicable law.

Limited Purposes

We only collect and use Sensitive Personal Data when reasonably necessary for and proportionate to one of the following business purposes: (a) to perform certain Services, such as verifying information or for analytics; (b) to verify or maintain the quality or safety of our Services, including our Website; (c) to perform Services reasonably expected by you, such as connecting you with Resource Providers at your express request; (d) for short-term use where there is no disclosure or profiling; and/or (e) to resist malicious, fraudulent, or illegal actions or to ensure physical safety.

Right to Limit Processing of Sensitive Personal Data

California Residents: Under California law, you have the right to limit our processing of your Sensitive Personal Data to only uses which are necessary to perform the Services reasonably expected by an average consumer who requests such Services. When we collect your Sensitive Personal Data, we collect and use that information to perform the Services for which that information is necessary and as reasonably expected by you. For example, we only collect Health Data when it is volunteered by you and relevant to specific resources you’ve indicated an interest in, such as SSDI assistance.

Other States: Under other state privacy laws, we are only permitted to collect certain pieces of Sensitive Personal Data after we have obtained your consent to do so. Where required, we get your agreement to collect and use Sensitive Personal Data—specifically, we only collect Sensitive Personal Data that is knowingly and voluntarily provided by you when you fill out a form or complete a survey on the Website.

Our Retention Policy for Sensitive Personal Data

All Sensitive Personal Data will be retained in compliance with any legislation governing the retention and deletion of such data. Unless otherwise required by law, Sensitive Personal Data will not be retained longer than two (2) years after fulfillment of the business purposes for which it was collected.

Data Security

We employ industry-standard security measures to protect the Sensitive Personal Data we collect, including encryption, access controls, and regular security assessments to prevent unauthorized access, disclosure, or alteration of the data.

Disclosure of Personal Data to Others

As part of our business, we disclose information to Third Parties as follows and for the outlined purposes, which include business purposes to provide. Safeguard, and improve our Website and related Services and to comply with legal and contractual obligations, as well as commercial purposes, such as to promote our Resource Providers and other offerings.

Service Providers and Contractors

Some Services that you obtain through us are provided by Third-Party Resource Providers, service providers and contractors. We need to communicate your name to such partners in order to provide you with the Services you’ve requested. Accordingly, such disclosure is for business purposes, including to provide you with Services that you have requested, and for commercial purposes, such as to advertise our Services, and those of Third-Party Resource Providers, to you and others.

These Third-Party service providers and contractors operate in several industries, including the following:

• Advertising (e.g., social media, web, streaming, and broadcast television platforms);
• Resource Providers (e.g., legal professionals, educational opportunities, debt relief resources, and so forth); and
• Software and technology (e.g., providers of hosting, security, email, and live chat Services for the Website, and the provider of the Technogym technology in our fitness centers).

When we provide your personal data to Third-Party Resource Providers, service providers and contractors, we only communicate data that is strictly necessary. We also have agreements in place with Third-Parties to ensure that the data we communicate to them is used only for specific purposes related to the fulfilment of your request.

Personal data of European residents may be transferred to a non-EU/EEA country if a specific Resource Provider, Third-Party service provider or contractor is based outside the EU/EEA.

Legal Process and Protection

We may disclose information as necessary to comply with our legal obligations, such as to respond to government requests, law enforcement inquiries, legal processes, subpoenas, and court orders.
We may disclose information when we believe it is necessary to investigate, prevent, or respond to illegal, fraudulent, or injurious actions, property damage, or other security incidents that may cause harm to us, our website users, Resource Providers, or others. We may also disclose information in good faith where necessary to investigate or enforce a violation of this Privacy Policy, our terms, or any legal rights.

Merger or Sale

We may share information with a buyer and/or its representatives for business purposes as part of a sale, merger, acquisition, or other change in control or entity status, either in whole or in part, of any company within the Company group. We reserve the right to transfer or assign your information as part of any such transaction or investigation.

Consent

We may disclose information to Third Parties as requested or consented to by you. Such disclosure may be for any business or commercial purpose as described by you.

Cookies and Other Data Technologies

Use of Data and Tracking Technologies on the Website

As with many companies, we may use cookies, pixels, gifs, web beacons, log files, and/or similar technologies to automatically collect certain information, including device, internet, and network data, general geolocation data, inferences, and aggregate information or de-identified data, when you use the Website or interact with our digital advertising content, such as when you click on an advertisement or a link to the Website within an email. This allows us to track individual users, determine when content is accessed, and customize user experiences.

Unless you have opted out of cookies or changed your cookie settings in your internet browser, your browser automatically sends us certain device, browser, internet connection, and general geolocation information and certain internet activity information. For instance, we may collect your mobile device identifier or MAC address, ISP carrier information, date and time you access the Service, the pages you visit, and whether you click on ads.

Cookies

Cookies are small text files sent by websites to users’ browsers for the purpose of automatic authentication, session tracking and storing of specific information regarding users. There are essentially three types of cookies used on the Website:

• “Technical cookies” are required for navigation within the Website and to use some of its functions (e.g. timing the display of certain pages in so-called “pop-up” mode etc.).
• “Statistical cookies” (e.g., Google Analytics) are supplied and managed by Google to provide a statistical analysis of access to the Website. The data collected is Non-Personalized Data, is solely collected anonymously and in aggregate form, and no personal user data is retained. You can decide not to use Google Analytics cookies by following the instructions at the following link: https://tools.google.com/dlpage/gaoptout?hl=en
• “Profiling cookies” are supplied and managed by Third Parties to generate specific advertising messages based on browsing habits and the interests of individual users. These cookies do not, however, use Sensitive Personal Data. The Website currently uses the Google Doubleclick cookie. For more information, including information to opt out from the cookie, please click the following link: https://policies.google.com/technologies/ads?hl=en-GB. Please see below for more information on personalized advertising.

You can change your cookie settings in your internet browser and use settings on your device to manage your privacy controls. For more information and ways to opt out, see https://www.allaboutcookies.org/, and learn how to disable these tools by opting-out of third-party cookies and mobile device ID practices.

Please note that disabling cookies may impair the correct functioning of certain Website features.

Pixels

Pixels are small pieces of code embedded on a website that allows website owners and third parties to track user behavior and gather information about how users interact with the website. Pixels can track actions like page views, clicks, and other related activities and are often used for Personalized Ads and website analytics.

We may use pixels on the Website to associate personal data with your device or IP address and to track and measure your engagement with the Website and Personalized Ads.

Marketing

Personalized Advertising

We may work with Third-Party advertising companies to process personal data (but not Sensitive Personal Data) for the commercial purpose of displaying ads tailored to your individual interests based on your online and transactional activity and to provide ad-related services such as analytics and market research (collectively, “Personalized Ads”). Third parties, in turn, may use a cookie, web beacon, pixel or other similar technology to collect personal data from you and/or associate it with other personal data collected.

We may also send you Personalized Ads in the form of email, phone, and SMS/text communications and newsletters tailored to your preferences and purchasing tendencies.

Other Marketing Communications

When you provide us your email address via the Website you will receive emails about your account, requested resources, Resource Providers, and related Services that may include non-personalized marketing messages.
Similarly, when you provide us your phone number and consent to receive calls or SMS/text messages, you may receive non-personalized marketing communications.

Revoking Consent

To opt-out of cross-device linking and Personalized Ads, visit www.aboutads.info/choices or perform a global opt-out on each browser and device.

You can opt-out of receiving Personalized Ads and other marketing communications by email by clicking the unsubscribe link and following any subsequent instructions.

You can opt-out of receiving Personalized Ads and other marketing communications by SMS/text message by replying STOP.

You can opt-out of receiving Personalized Ads and other marketing communications by phone by asking to be placed on Company’ internal Do Not Call list.

To opt-out of Personalized Ads and other marketing communications and notifications on Third-Party platforms, such as Meta (Facebook, Instagram), Google, Android, and iOS, you can change your user settings on such platforms.

Sale of Personal Data

As stated in the Website Terms of Service, Company earns its money on the Website through affiliate commissions paid by certain Resource Providers. As such, when you indicate an interest in a certain type of Resource, we may disclose your Information to our Resource Providers, and we may earn an affiliate commission as a result of connecting you with such Resource Providers. Under some privacy laws, this may constitute a “sale” of your personal Information.

As discussed above, Company participates in targeted advertising or Personalized Ads, which is also called interest-based or online behavioral advertising and may include cross-contextual advertising. Under some privacy legislation, Personalized Ads may constitute the “sale” or “sharing” of personal data, such as for business purposes (e.g., providing resources and related Services) and commercial purposes (e.g., marketing).

To opt out of these practices, please see the section above about revoking consent or visit our Do Not Sell or Share My Personal Information page.

Financial Incentives

We may offer incentives related to the collection, retention, or sharing of information that may be deemed a “financial incentive” or “price or service difference.” If you opt in to such an offering pursuant to the terms described at the time of signup, we may collect information such as contact information, transactional information and inferences, internet or other network activity, and device information. Any difference in price or rate, such as a discount, will be reasonably related to the value of the data. If you want to withdraw from the offering, please contact us as instructed below.

Children’s Information

Company does not solicit or knowingly collect personally identifiable information from children under the age of 13. If Company obtains actual knowledge that it has collected such information, that information will be immediately deleted from our database. Because Company does not collect such information it has no such information to use or disclose to third parties. Company has designed this Privacy Policy in order to comply with the Children’s Online Privacy Protection Act (COPPA).

Protection of Personal Data

Consistent with others in our industry, we take efforts to employ technical, administrative, and physical security measures for personal data, taking into account reasonable security procedures and accessible technology. However, no system can be completely secure; and we cannot promise, and you should not expect, that your personal data will always remain secure. Your provision of personal data is at your own risk. The safety and security of your information also depends on you. Take steps to safeguard your passwords and other data and notify us as soon as possible if you believe your account security has been breached.

Tracking and Privacy Controls

Our Website does not currently respond to Do Not Track, or “DNT” requests. DNT is a feature that, when enabled, sends a signal to websites to request that your browsing not be tracked.

“GPC” is short for Global Privacy Control settings in your browser or extension. Our Website recognizes GPC signals. This means that if your browser has GPC enabled, our Website will automatically recognize your GPC signal and opt you out of the sale of your personal information, if any. For more information about GPC, please click here: https://globalprivacycontrol.org/.

Your Privacy Rights

Company is committed to giving you the appropriate control of your own personal data. Dependent upon the laws of the jurisdiction where you reside, you may have the following rights in connection to your personal data:

• The right to access your personal data and obtain specific information about how we process it. Please be aware that you can only exercise this right in relation to your own data or to the data of a minor or another vulnerable person, where you have provided such data as a holder of parental authority or legal responsibility. Company reserves the right to ask for proof of identity, as well as to refuse to provide the personal data if the identity or relevant connection to the data subject cannot be proven.
• The right to rectify your personal data, including by means of providing a supplementary statement.
• The right to obtain the erasure/deletion of personal data concerning you, subject to certain legal limitations depending upon the laws of your jurisdiction of residence.
• The right to limit or restrict the processing of your personal data, in particular, any Sensitive Personal Data and the use of automated decision making, such as profiling.
• The right to data portability. You may exercise this right in cases where the processing is based on your consent or on your contractual relationship with Company and the processing is carried out by automated means.
• The right to object, at any time, to the processing of the personal data concerning you. You may exercise this right where the processing is based on the performance of a task carried out in the public interest or in the exercise of official authority vested in us, or where the processing is based on our legitimate interests.
• The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or which similarly significantly affects you. You may exercise this right unless the processing is necessary for entering into, or performance of, a contract between you and Company, or is authorized by applicable law that lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or if the processing is based on your explicit consent.
• The right to opt-out of certain data practices, such as by unsubscribing from marketing communications by following the opt-out instructions in each message or by contacting us as outlined in this Privacy Policy.
• The right to lodge a complaint with a supervisory authority in your jurisdiction of residence, place of work or place of the alleged infringement. Similarly, you have the right to not be discriminated against for asserting your privacy rights, and your exercise of these rights will have no adverse effect on the price and quality of our goods or Services.
• Other Rights. If certain other privacy laws apply to you that provide you with additional rights, please contact us to make a request, as we strive to comply with all privacy rights.

To exercise your data subject rights, please email us at privacy@diablomedia.com or fill out our Privacy Request Form.

Jurisdiction-Specific Rights

In addition to the foregoing Privacy Rights, if you are a resident of any of the following jurisdictions within the United States, the corresponding privacy rights apply to you:

For California Residents

The “right to access your personal data” includes the right to request the following:

• what personal data we have collected, used, disclosed and “sold” about you, including the categories of personal data;
• the categories of sources from which the personal data is collected;
• the business or commercial purpose(s) for collecting, selling, or sharing personal data;
• the categories of Third Parties to which personal
  the specific pieces of personal data we have collected about you.

Please note that we are only required to honor “right to access” requests twice in a 12-month period.

The “right to rectify your personal data” includes the right to correct inaccuracies, considering the nature of the personal data and the purposes of the processing.

The “right to obtain erasure/deletion of your personal data” is not absolute and we will, in some cases, retain personal data as allowed by applicable laws and to support essential functionality, such as maintaining your subscription.

You may also designate an authorized agent to make a privacy rights request on your behalf.

In addition, California law requires us to identify, for the 12-month period prior to the date of this Privacy Policy, what information we may have “sold” or “shared” about you. For the 12-month period prior to the date of this Privacy Policy, Company has only sold or shared personal data about its customers as expressly described in this Privacy Policy.
The Shine the Light law permits you to request and obtain from us, once per calendar year, information about any of your personal data shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information and for any other questions about our privacy practices and compliance with California law, please contact us as described below in the section entitled “Contact Us.”

For Virginia, Colorado, Connecticut, and Utah Residents

The “right to access your personal data” means you have the right to confirm whether we process your personal data and access your personal data.

Please note that we are only required to honor “right to access” requests twice in a 12-month period.

The “right to rectify your personal data” includes the right to correct inaccuracies, considering the nature of the personal data and the purposes of the processing.

The “right to obtain erasure/deletion of your personal data” is not absolute and we will, in some cases, retain personal data as allowed by applicable laws and to support essential functionality, such as maintaining your subscription.

You have the right to opt out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, and/or profiling in furtherance of decisions that produce legal or similarly significant effects. Please see our Do Not Sell or Share My Personal Information page for information on exercising this right.

Please note that we do not process your personal data using machine learning and/or profiling methods in ways that would impact you in a legal or similarly significant manner.

If we deny your privacy request, you have the right to appeal our decision. To appeal a decision we have made regarding your request, you may contact us as instructed below. We will respond to appeals within 45 days.
You may also designate an authorized agent to make a privacy rights request on your behalf.

For Residents of Other Jurisdictions

It is our intention to honor all privacy rights. Residents of jurisdictions other than those specified above may have the same or similar privacy rights including, without limitation, the right to access, correct, delete, obtain personal information we have collected or processed about you or to opt-out of certain data processing activities, including the sale of your personal information. To exercise any such privacy right, please contact us in accordance with the section entitled “Contact Us” below.

California Data Broker Disclosures

Company is a registered data broker and is required under certain privacy laws to report the following, which pertain to requests to delete, to know, to access, to opt-out of sale or sharing, or to limit the use of a consumer’s personal information received from California consumers only (each a “Request”):

Updates

We reserve the right to update, modify, add or remove portions of this information notice at any time. Significant changes to the processing of your personal data will require your approval, in accordance with the applicable legislation. If you would like to obtain a copy of the current or a previous version of the information notice, please contact us using our contact details provided below.

Contact Us

Diablo Media, LLC controls the information and data provided to and collected by us. If you would like to access, correct, amend, or delete any information we have about you, make a complaint, or simply want more information, please contact us at privacy@diablomedia.com or fill out our Privacy Request Form.