Privacy Policy

Last Updated: February 13, 2026

Introduction

Clickdee Mediashare OÜ ("Clickdee," "we," "us," or "our") operates USAchoices.org (the "Site"). This Privacy Policy describes how we collect, use, share, and protect information when you visit our Site.

Who We Are: Clickdee Mediashare OÜ is an affiliate marketing company that connects consumers seeking Medicare and healthcare information with licensed third-party insurance providers. We are based in Estonia but operate exclusively in the United States market.

What We Do: We generate consumer inquiries through digital advertising and connect qualified consumers to licensed Medicare providers (such as United Healthcare, Humana, Aetna, and others) via inbound phone calls. We do not provide insurance services, maintain licensed agents, or handle insurance enrollment ourselves.

1. Information We Collect

1.1 Technical and Usage Data

When you visit our Site, we automatically collect certain technical information about your visit and device, including:

• Browser type and version
• Operating system
• IP address
• Device type and screen resolution
• Referral source (how you arrived at our Site)
• Date and time of visit
• Pages viewed and interactions with Site content
• Geographic location (city/state level based on IP address)

1.2 Cookie and Tracking Data

We use cookies, pixels, and similar tracking technologies to recognize your device, track your activity, and improve your experience. These technologies help us:

• Remember your preferences
• Analyze Site traffic and user behavior
• Measure advertising effectiveness
• Deliver relevant content and advertisements

You can control cookies through your browser settings. However, disabling cookies may limit your ability to use certain features of our Site.

1.3 Call Data

When you call phone numbers displayed on our Site, we may collect:

• Your phone number (caller ID)
• Call duration and timing
• Call outcome data (e.g., whether the call was answered, call length)

These calls connect you directly to licensed third-party insurance providers who handle all insurance-related discussions and services.

1.4 Information We Do NOT Collect Directly

Important: For consumers who qualify for Medicare through our questionnaire and are presented with a phone number to call, we do not collect personal identifying information such as name, email, postal address, or detailed demographic information. Your interaction with licensed providers occurs directly via phone.

For consumers who do not qualify for Medicare and are redirected to partner websites, any personal information is collected directly by those partner websites, not by us. The redirect occurs before you provide personal information on our Site.

2. How We Use Information

We use the information we collect for the following purposes:

2.1 Primary Business Purpose

• To connect you with licensed third-party Medicare and healthcare providers
• To pre-qualify you for Medicare eligibility through our interactive questionnaire
• To display appropriate phone numbers based on your qualification status
• To route non-qualified consumers to partner websites offering alternative insurance options
• To track call performance for our pay-per-call affiliate business model

2.2 Site Operation and Improvement

• To operate, maintain, and improve our Site
• To analyze traffic patterns and user behavior
• To troubleshoot technical issues
• To ensure Site security and prevent fraud

2.3 Marketing and Analytics

• To measure the effectiveness of our advertising campaigns
• To optimize our marketing efforts
• To conduct aggregate analytics and demographic analysis
• To serve relevant advertisements across the web

2.4 Legal and Compliance

• To comply with applicable laws and regulations
• To respond to legal requests and prevent illegal activity
• To enforce our Terms of Service
• To protect our rights, property, and safety

3. How We Share Information

3.1 Third-Party Insurance Providers

We facilitate connections between consumers and licensed Medicare insurance providers (United Healthcare, Humana, Aetna, and others). When you call numbers displayed on our Site, call data (phone number, call duration) is shared with these providers for call tracking and business purposes.

3.2 Advertising and Marketing Partners

We work with advertising partners, networks, and platforms to deliver targeted advertisements. We may share technical and usage data with:

• Google (Google Ads, Google Analytics)
• Advertising networks and exchanges
• Marketing analytics providers
• Social media platforms for advertising purposes

3.3 Partner Websites

Consumers who do not qualify for Medicare through our questionnaire may be redirected to partner websites that offer alternative insurance products. Technical data (but not personal identifying information) may be shared to facilitate this referral.

3.4 Service Providers

We share information with service providers who perform services on our behalf, including:

• Web hosting and IT infrastructure providers
• Analytics and data analysis services
• Call tracking and routing services
• Advertising and marketing services

These service providers are contractually obligated to use information only for the services they provide to us.

3.5 Legal Requirements and Business Transfers

We may disclose information:

• To comply with legal obligations, court orders, or government requests
• To protect our rights, property, or safety, or that of others
• In connection with a merger, acquisition, or sale of business assets

4. Consumer Rights

4.1 Rights Under US State Privacy Laws (CCPA and Similar Laws)

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or other states with comprehensive privacy laws, you may have the following rights:

Right to Know: You can request information about:

• Categories of personal information we collect
• Sources from which we collect information
• Purposes for collecting and sharing information
• Categories of third parties with whom we share information
• Specific pieces of personal information we hold about you

Right to Delete: You can request deletion of personal information we have collected from you, subject to certain exceptions.

Right to Opt-Out of Sale/Sharing: You can opt out of the "sale" or "sharing" of your personal information for targeted advertising purposes.

Right to Correct: You can request correction of inaccurate personal information.

Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To Exercise Your Rights: Contact us at privacy@usachoices.org or call 1-844-872-7854. We will verify your identity and respond within 45 days (or as required by applicable law).

4.2 Rights Under GDPR (European Economic Area, UK, Switzerland)

Although our Site targets US consumers, as an Estonian company, we comply with GDPR. If GDPR applies to you, you have rights including:

• Access: Request a copy of personal data we hold about you
• Rectification: Request correction of inaccurate information
• Erasure: Request deletion of your personal data
• Restriction: Request limitation of how we process your data
• Data Portability: Request transfer of your data to another service
• Object: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent for processing where consent is the legal basis

To exercise GDPR rights, contact us at privacy@usachoices.org. You also have the right to lodge a complaint with your local data protection authority.

4.3 Do Not Track Signals

Our Site does not currently respond to "Do Not Track" signals from browsers. You can manage tracking preferences through browser settings and opt-out tools provided by advertising networks.

5. Cookies and Advertising Choices

5.1 Managing Cookies

You can control cookies through your browser settings:

• Chrome: Settings > Privacy and Security > Cookies
• Firefox: Settings > Privacy & Security > Cookies and Site Data
• Safari: Preferences > Privacy > Cookies and website data
• Edge: Settings > Cookies and site permissions

5.2 Advertising Opt-Out Tools

You can opt out of targeted advertising through:

• Network Advertising Initiative
• Digital Advertising Alliance
• Google Ad Settings

6. Data Security

We implement reasonable technical, administrative, and physical security measures to protect information from unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption of data in transit (SSL/TLS)
• Secure hosting infrastructure
• Access controls and authentication
• Regular security assessments

Important: No method of internet transmission or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

7. Data Retention

We retain information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required by law. Specifically:

• Technical and Cookie Data: Typically retained for 30-180 days for active marketing purposes; archived data may be retained for up to 6 years for legal and compliance purposes
• Call Data: Retained for business and compliance purposes, typically up to 6 years
• Analytics Data: May be retained in aggregated, anonymized form indefinitely

8. Children's Privacy

Our Site is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child under 18, we will delete it promptly.

9. Third-Party Websites

Our Site may contain links to third-party websites, including partner websites to which we may redirect non-qualified consumers. We are not responsible for the privacy practices of these third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

10. International Data Transfers

Clickdee Mediashare OÜ is based in Estonia, but our operations are conducted in and focused on the United States. Information collected through our Site is processed and stored in the United States. By using our Site, you consent to the transfer of information to the United States.

We ensure appropriate safeguards are in place for international data transfers in accordance with GDPR and other applicable laws.

11. Legal Basis for Processing (GDPR)

For users in the EEA, UK, or Switzerland, our legal bases for processing personal data include:

• Consent: Where you have provided consent to our use of cookies and tracking technologies
• Legitimate Interests: To operate our business, improve our Site, prevent fraud, and conduct marketing activities
• Legal Obligations: To comply with applicable laws and regulations

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we will:

• Update the "Last Updated" date at the top of this policy
• Post the revised policy on this page
• Provide notice of material changes through the Site or other appropriate means

Your continued use of the Site after changes become effective constitutes acceptance of the revised Privacy Policy.

13. Contact Us

14. Additional Information for California Residents

Categories of Information We Collect

In the preceding 12 months, we have collected the following categories of personal information:

• Identifiers: IP address, device identifiers, online identifiers
• Internet Activity: Browsing history, search history, interaction with our Site
• Geolocation Data: Approximate location based on IP address
• Inferences: Preferences and characteristics derived from your activity
• Audio/Electronic Information: Call recordings and call metadata (when you call numbers displayed on our Site)

Sources of Information

• Directly from your device when you visit our Site
• From cookies and tracking technologies
• From call tracking systems when you call displayed numbers
• From advertising and analytics partners

Business/Commercial Purposes for Collection

• Operating our affiliate marketing business
• Connecting consumers with licensed insurance providers
• Improving Site functionality and user experience
• Conducting analytics and measuring advertising effectiveness
• Preventing fraud and ensuring security

Sale and Sharing of Personal Information

We "sell" or "share" personal information as those terms are defined under the CCPA, primarily for targeted advertising purposes. In the preceding 12 months, we have sold/shared the following categories:

• Identifiers (IP address, device identifiers, online identifiers)
• Internet activity information
• Geolocation data
• Inferences

We sell/share this information with advertising partners, marketing platforms, and analytics providers.

Opt-Out: To opt out of the sale/sharing of your personal information, email privacy@usachoices.org with subject "Do Not Sell My Personal Information" or call 1-844-872-7854.

Sensitive Personal Information

We do not collect or process "sensitive personal information" as defined under the CCPA.

Retention

We retain personal information for the periods described in Section 7 (Data Retention) above.

Non-Discrimination

We will not discriminate against you for exercising your CCPA rights. We will not:

• Deny you goods or services
• Charge different prices or rates
• Provide a different level or quality of service
• Suggest you will receive different prices or quality of service