Every role at is impacted by privacy, security and confidentiality. Each associate has a responsibility to safeguard and protect from misuse or unauthorized access all data under’s stewardship and our privacy policy, including client data and “owned” data.’s best-practice compliance approach includes three layers of compliance and practice: 1) federal, state laws; Finally provides extensive education to all of the associates including executives, product development teams, sales staff, and client teams. executives are, in fact, frequent presenters at events on best-practice privacy practices and consumer advocacy.

Record Keeping

All associates must maintain accurate and complete records in compliance with any and all regulatory requirements. Business records must never be falsified nor may they be knowingly destroyed if they are subject to legal or regulatory process. If there is any question about whether destruction of records is appropriate and acceptable, associates are expected to consult a member of the legal team prior to destruction. Falsification or inappropriate destruction of records could result in disciplinary action against the associate as well as criminal and/or civil penalties against the individual associate and

SMS opt-in

SMS opt-in is a choice that users get to make whether a certain company can contact them. The word “opt” literally means to “make a choice.” In practice, that would usually translate to a user’s consent on receiving the company’s text messages or emails.

Open Communications Policy

Open communication is a hallmark of the culture, and associates should feel free to discuss ideas or problems related to these Guidelines directly with their Leader. Associates should never hesitate to ask a question or report a concern. In some cases, the Leader will be able to help the associate resolve the dilemma and make an ethical choice. In other cases, the Leader may ask for guidance from the associates responsible for the day-to-day administration of these Guidelines or a third party advisor.

If the Leader’s response is not adequate or if the problem or complaint is one that for whatever reason cannot be discussed with one of these individuals, the associate may approach a member of Human Resources for additional assistance.


All reports concerning unethical behavior will be promptly and thoroughly investigated and will be treated confidentially to the extent possible under the circumstances. Investigations will be conducted by’s internal compliance team.

Investigations may involve complex legal issues; therefore, associates who witness or report possible violations may not conduct their own investigations. Associates are expected to cooperate with the investigation of any alleged violation and to answer questions truthfully and to the best of their ability. If the result of the investigation indicates that corrective action is required, steps to rectify the problem and avoid its recurrence will be identified and implemented.

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