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A mortgage company's website uses cookies to track visitors' browsing behavior across multiple sessions. A visitor has not yet applied for a loan but has used the mortgage calculator several times. Under GLBA, this tracking data is considered:

Correct Answer

C) Personal information but not subject to sharing restrictions until a customer relationship exists

Under GLBA, the Act's sharing restrictions and privacy notice requirements generally apply to 'customers' and 'consumers' who have established relationships with the financial institution. Website tracking of non-customers may be personal information but doesn't trigger the same GLBA obligations as information from customers, though other privacy laws may apply.

Answer Options
A
Nonpublic personal information subject to all GLBA protections
B
Public information not covered by GLBA
C
Personal information but not subject to sharing restrictions until a customer relationship exists
D
Anonymous data not subject to any GLBA requirements

Why This Is the Correct Answer

Under GLBA, the Act's sharing restrictions and privacy notice requirements generally apply to 'customers' and 'consumers' who have established relationships with the financial institution. Website tracking of non-customers may be personal information but doesn't trigger the same GLBA obligations as information from customers, though other privacy laws may apply.

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