I disclose information about my customers who do not opt out to a residential plumbing company. Can the plumbing company use the information for marketing purposes?
A. Yes. This is permissible because you disclosed nonpublic personal information to the plumbing company in accordance with the notice and opt out provisions of the GLB Act. 502(a)-(b) of the Act, as codified at 15 U.S.C. 6802(a)-(b). In other words, you disclosed information about a consumer consistent with your privacy notice and the consumer’s choice not to opt out. As illustrated in the following questions and answers, when the plumbing company receives from you nonpublic personal information about a consumer who has not elected to opt out, the company is free to use the information for marketing or other purposes. However, the plumbing company may disclose the nonpublic personal information it receives from you only if such a disclosure is consistent with the restrictions on disclosure of the information described in your privacy policy. 313.11(d). The plumbing company therefore is required to honor any subsequent opt out elections made by consumers pursuant to your privacy policy
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