Privacy Notice

California residents: click here for notice regarding your additional rights under California Consumer Privacy Act (CCPA)

Introduction

KEANE is the leading unclaimed property services provider offering communication, consulting and compliance services and programs to its institutional clients and consumers. KEANE is committed to using its best efforts to protect your privacy with technology that gives you the most powerful and safe online and commercial experience.

KEANE is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).  KEANE serves as a business associate for some clients, which may involve the use and disclosure of an individual’s protected health information. As a business associate, KEANE complies with certain laws under the Health Insurance Portability and Accountability Act and the Health Information Technology for Economic and Clinical Health Act (“HIPAA Laws”). All protected health information is handled in accordance with the privacy and security protections afforded under the HIPAA Laws.  KEANE’s subsidiary, Keane Financial, LLC, is a licensed broker-dealer and subject to the laws, rules and enforcement powers of the Securities and Exchange Commission (“SEC”).

With respect to data collected as a result of Keane’s solicitation of services in the European Economic Area (“EEA”), and/or transferred to it by clients who obtained the data from sources within the EEA, KEANE complies with the General Data Protection Regulation (“GDPR”) and the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data from individuals residing in European Union member countries. KEANE has certified that it adheres to the Privacy Shield Principles of Notice, Choice, and Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.

This Privacy Policy includes Venio LLC d/b/a Keane, Venio Holding Corp., Keane Financial, LLC, and Keane Holdings, Inc. (collectively  herein “KEANE”) and applies to all personal information received by KEANE whether in electronic, paper or verbal format. This Privacy Policy also applies to the KEANE family of websites and governs general data collection and usage. By using the KEANE website, you consent to the data practices described in this Privacy Policy.

GDPR and EU-US Privacy Shield Principles

For personal information of consumers, customers, investors, and government officials that KEANE, including its U.S. subsidiary Keane Financial, LLC, as defined above, receives from the EEA, either directly as Data Controller or as a Data Processor for its clients, KEANE has committed to handling such personal information in accordance with the GDPR and EU-US Privacy Shield Principles.

We self-certify compliance with: U.S. – E.U. Privacy Shield Certification.

KEANE’s Privacy Shield certification can be found at https://www.privacyshield.gov/list.

For more information about the Data Protection Act Principles, please visit the Data Protection Commissioner of Ireland’s Website: http://www.dataprotection.ie/.

For more information about the EU-US Privacy Shield Principles, please visit the U.S. Department of Commerce’s website at https://www.privacyshield.gov.

Purpose of Collection of your Personal Information and Legal Basis for Processing

Pursuant to contracts you enter into with KEANE, agreements you may already have in place with a financial institution or company holding your data, and/or KEANE’s contracts with such companies, KEANE collects personally identifiable information, such as your e-mail address, name, home or work address, telephone number, and/or other personally identifiable information. KEANE also collects anonymous demographic information, which is not unique to you.  The purpose of KEANE’s collection and processing of this information is to assist a company holding your property in complying with federal or state law to locate you, verify your identity, and reunite you with your property; and/or going beyond such requirements when such efforts have not reached you.  In addition, KEANE may collect personally identifiable information about you in order to determine if you are the correct entitled party where its client holds an asset registered to you or in the name of a deceased individual.  Such collection is in furtherance of the legitimate business and fraud prevention interests of KEANE’s clients.

There is also information about your computer hardware and software that upon your consent to the pop-up notification is automatically collected by KEANE’s internet optimization vendor. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by KEANE for the operation of this website, to maintain the quality of this website, and to provide general statistics regarding use of the KEANE website.

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through public comments on KEANE blog posts, this information may be collected and used by others.

KEANE encourages you to review the privacy statements of websites you choose to navigate to through a link from KEANE’s website so that you can understand how those websites collect, use and share your information. KEANE is not responsible for the privacy statements or other content on websites outside of the KEANE and KEANE family of websites.

Use and Storage of Your Personal Information

KEANE collects and uses your personal information to operate the KEANE Web site and to deliver the services you or a KEANE client have contracted with KEANE to receive. Where you provide consent pursuant to one of KEANE’s pop-up notices, KEANE also uses your personally identifiable information to inform you of other products or services available from KEANE. KEANE may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

KEANE does not sell, rent or lease its customer lists to third parties. If this business practice changes in the future, KEANE will provide individuals with opt-out choice.  KEANE may share data with vetted vendors to help us securely store and maintain data, perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to KEANE, and they are required to maintain the confidentiality of your information.

Upon consent pursuant to KEANE’s pop-up notifications, KEANE keeps track of the websites and pages you visit within KEANE to determine what KEANE services are the most popular. This data is used to deliver customized content and advertising within KEANE to customers whose behavior indicates that they are interested in a particular subject area.

KEANE stores personal Information within the United States of America on servers under our own exclusive custody and control, in a data co-location to ensure disaster recovery and business continuity, and on WORM (write once, read many) compliant, encrypted back-up tapes maintained at a secure commercial storage facility.  KEANE maintains a ten-year data retention policy in order to accommodate various United States’ jurisdictions’ audit review.

KEANE may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.  KEANE will disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on KEANE or the website; (b) protect and defend the rights or property of KEANE; and (c) act under exigent circumstances to protect the personal safety of users of KEANE or the public.

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, KEANE is potentially liable.

Use of Cookies

As disclosed in the pop-up notifications provided upon you navigation to the KEANE websites, it uses “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. KEANE may use a vendor that provides the ability to identify you personally based on links you have clicked in emails or information you have submitted in online web forms and associate this information with certain cookies. KEANE may continue to receive information that identifies you and tracks your web page views as you view other websites that use these certain services.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the KEANE services or websites you visit.

Security of Your Personal Information

KEANE takes all reasonable steps to secure your personal information from unauthorized access, use or disclosure in a controlled, secure environment. When personal information is transmitted by KEANE, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

Rights of Personal Data Subjects

KEANE acknowledges the right of individuals to access their personal data.  An individual who seeks access, or who seeks to correct, amend, limit use or delete inaccurate data, should direct his query to KEANE at compliance@keaneup.com.  If requested to remove data, we will respond within a reasonable timeframe to the extent that KEANE controls the data and can reasonably remove the same or is required to do so.

For personal data subject to the GDPR, you have the right to: (a) transfer personal data from one electronic processing system to another; (b) know what data has been collected about you and how such data has been processed; (c) make changes to inaccurate data; (d) to the extent that our retain of your data is in reliance on your consent to process your personal data, you have the right to withdraw your consent and ask for your personal data to be deleted, note that this does not apply to data that KEANE must maintain in order to fulfill its contractual obligations to the property holder.

Changes to this Privacy Policy

KEANE will occasionally update this Privacy Policy to reflect company and customer feedback. KEANE encourages you to periodically review this Privacy Policy to be informed of how KEANE is protecting your information.

Contact Information

KEANE welcomes your comments regarding this Privacy Policy. If you believe that KEANE has not adhered to this Privacy Policy, please contact KEANE at compliance@keaneup.com. We will use commercially reasonable efforts to promptly determine and remedy the problem.

Privacy Complaints by European Union Residents

In compliance with the GDPR and Privacy Shield Principles, KEANE commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union residents who were directly solicited by KEANE or a KEANE client for their personal information via solicitation to provide services in the EEA may lodge a complaint with a supervisory authority in the EU Member State of their residence, place of work, or where the alleged infringement occurred. We request that any concerns or complaints first be directed to KEANE so that we have an opportunity to resolve the issue.  You can contact KEANE at:

KEANE
640 Freedom Business Center
Suite 600
King of Prussia, PA 19406
USA
Phone:  1-800-848-8896
Web:    www.keaneup.com
Email:   compliance@keaneup.com

KEANE has further committed to refer unresolved privacy complaints under the US-EU Privacy Shield Principles to an independent non-profit dispute resolution mechanism, the BBB EU PRIVACY SHIELD, located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by KEANE, please visit the BBB EU PRIVACY SHIELD website at www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.


CCPA Privacy Notice for California Residents

Effective Date: 01/01/2020
Last Reviewed: 11/26/2019
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Introduction

This CCPA Privacy Notice for California Residents supplements the information contained in the Privacy Notice as set forth above and applies specifically to all visitors, users, customers, consumers, individuals that received requests to provide information to Keane and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

KEANE collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, KEANE has collected the following categories of personal information from its consumers within the last twelve (12) months:

CategoryExamplesCollected
A. Identifiers.A real name, alias, postal address, unique personal identifier, online identifier (such as cookies), Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, Social Security number, (home and/or work) address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information,. Some personal information included in this category may overlap with other categories.YES
C. Protected classification characteristics under California or federal law.Age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status.YES
D. Commercial information.Records of personal property owned.YES
E. Biometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.NO
F. Internet or other similar network activity.IP address, browser type, domain names, access times, referring website addresses, browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.YES
Geolocation data.Physical location or movements.NO
H. Sensory data.Audio information.YES
I. Professional or employment-related information.Current or past job history or performance evaluations.NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.NO
K. Inferences drawn from other personal information.Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.NO

Personal information does not include:

  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

KEANE obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms or documents that you have provided to us.
  • Indirectly from you. For example, through the use of cookies by us; and from third parties with whom you have an existing business relationship, that have engaged us as a service provider to perform services related to your information.
  • Directly and indirectly from your activity on our website. For example, from your submissions through our website portal or from your website usage details, which are collected automatically.
  • From third parties and/or service providers that interact with us in connection with the services we perform.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you or our clients have provided us with the information. For example, to comply with federal or state laws or legitimate business interests to locate you, verify your identity, and reunite you with your unclaimed property; or to enable our clients meet federal or state unclaimed property reporting obligations.
  • To carry out our obligations and enforce our rights arising from any contracts we enter, through the use of targeted telephone or mail outreach, email, or via the website portals.
  • To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
  • To provide, support and develop our website, products, and services.
  • To provide you and/or our clients with support and to respond to inquiries, including investigating and addressing concerns, and monitoring and improving our responses.
  • As necessary or appropriate to protect your rights, property or safety.
  • To respond to law enforcement requests and/or as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

KEANE will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

KEANE may disclose your personal information to a third party for a business purpose, but does not sell, rent or lease your personal information. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except to perform under the terms of the contract.

We share your personal information with the following categories of third parties:

  • Service providers.
  • Our affiliates.
  • Clients who have a legitimate business interest in your information as a result of an existing relationship with your or a deceased individual to whose property you are entitled.
  • Internet cookie information recipients.

Disclosure of Personal Information for a Business Purpose

In the preceding twelve (12) months, KEANE has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category F: Internet or other similar network activity.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agent authorize us to disclose your personal information in connection with products or services we provide to you.

Sale of Personal Information

In the preceding twelve (12) months, KEANE has not sold any personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that KEANE disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we shared that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights

You have the right to request that KEANE delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or our service provider(s), or otherwise perform our contract with you or our service provider(s).
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  • Maintain data in archives or back-up tapes until the archive or back-up tapes are next accessed in the regular course of KEANE’s conduct.

Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to an additional 90 days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales

We do not sell and will not sell the personal information of consumers regardless of age.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.?

However, KEANE may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive that KEANE offers will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Changes to Our Privacy Notice

KEANE reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the website and update the notice’s effective date. Your continued use of our website following the posting of charges constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, our Privacy Notice, the ways in which KEANE collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

KEANE
Attention: Compliance Director
640 Freedom Business Center Suite 600
King of Prussia, PA 19406 USA
Phone: 1-800-848-8896
Web: www.keaneup.com
Email: compliance@keaneup.com

Return to the Keane Unclaimed Property homepage.

Effective: 02/20/2013
Last revised: 11/12/2018

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