We have changed affiliate information in the prior privacy notice, because it was wrongly disclosed. We just deleted the wrongly disclosed affiliate.

We have privacy notice available on the website, which do not require log-in.

We have not included a statement in the monthly statements that the privacy notice is available on the website.

Can we still not send the annual notice?

Deletion of an affiliate does not trigger revised privacy disclosures under 1016.8.

If you offer an affiliate opt-out, you are not eligible for the website alternative version.

1016.9(c)(2) Alternative method for providing certain annual notices. (i) Notwithstanding paragraph (a) of this section, you may use the alternative method described in paragraph (c)(2)(ii) of this section to satisfy the requirement in § 1016.5(a)(1) to provide a notice if:

(B) You do not include on your annual privacy notice pursuant to § 1016.6(a)(7) an opt out under section 603(d)(2)(A)(iii) of the Fair Credit Reporting Act (15 U.S.C. 1681a(d)(2)(A)(iii));

If you have customers in Vermont, you may need to send them annual notices under Vermont's state privacy regulations.