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  • VIA BENEFITS Privacy Policy

    Last Updated: December 31, 2019

    In this Privacy Policy ("Policy"), we describe how Extend Insurance Services d/b/a Via Benefits, a Delaware limited liability company, and our affiliate subsidiary companies (collectively, "Via Benefits," "we" or "us") collect, use and otherwise process personal information about our customers and users of our websites and services.

    Overview of Categories of Personal Information Collected and Purposes of Use

    This overview is intended to summarize key information about our information practices, which are further explained below. (Skip to full details.) While the actual information we collect about you and our use of such personal information varies depending upon the nature of our relationship and interactions with you, below we provide an overview of the categories of personal information we collect about Users and the purposes for which we use such information.

    Categories of Personal Information Collected (described in greater detail below).

    • Name, Contact Information, and Other Identifiers: identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
    • Customer Records: paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, current employment, employment history, social security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial or payment information, medical information, or health insurance information.
    • Protected Classifications: characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.
    • Commercial Information: including records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
    • Internet or Other Electronic Network Activity Information: including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
    • Audio, Video and Other Electronic Data: audio, electronic, visual, thermal, olfactory, or similar information such as, CCTV footage, photographs, and call recordings.
    • Employment History: professional or employment-related information.
    • Education Information: education information that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
    • Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

    Use of Personal Information

    • Providing our Services and related support
    • Protecting the integrity of the Services
    • Analyzing and improving the Services and our business
    • Personalizing the Services
    • Advertising, marketing and promotional purposes
    • Securing and protecting our business
    • Defending our legal rights
    • Auditing, reporting, corporate governance, and internal operations
    • Complying with legal obligations

    California residents

    If you are a California resident, please be sure to review the section Additional Information for California Residents below for important information, as required by California privacy laws, about the categories of personal information we collect and disclose and your rights under California privacy laws.

    Scope

    This Privacy Policy applies to the personal information that Via Benefits collects and processes about individuals related to our services, including users of any websites (each a "Site") that we operate and which include this Privacy Policy (collectively, the "Services"). This Privacy Policy does not apply to any third party websites, services, products or mobile applications maintained by other companies, which are linked to or from our Services. In addition, this Privacy Policy does not apply to any personal information that we collect and process that is subject to the Health Insurance Portability and Accountability Act ("HIPAA") and associated regulations.

    The Services include providing you with information about insurance options, assisting with the selection of and enrollment in an insurance plan, providing you with an opportunity to interact with other users, and other products and services that may be available to you.

    By providing your information to us through or in connection with the Services, or otherwise using any of our Sites or Services, you understand and acknowledge that Via Benefits may process your personal information in accordance with this Privacy Policy. If you do not want this Privacy Policy to apply to you, please do not use the Services or communicate with us via the Services. If required by applicable law, we will obtain your consent to our collection, use, transfer and disclosure of your personal information.

    Personal Information Collected

    The information we collect about individuals varies depending upon the circumstances and the Services. Via Benefits collects personal information directly from individuals, automatically related to the use of the Services, and from third parties (such as current or former employers that provide us with information about individuals who may be interested in our Services).

    Information Collected Directly

    We collect information that you provide to us when you inquire about or use our Services. For example, you may be required to provide us with certain information, including, without limitation, some or all of the following information:

    • Name
    • Address
    • E-mail address
    • Daytime telephone number
    • Evening telephone number
    • Cellular telephone number
    • Social security number, Health insurance claim number, and/or Tax identification number
    • Certain other personal or company information reasonably required by us

    In addition, if you decide to use our Services to apply for or receive a health, life or other qualified insurance policy (each a "Policy") offered by our third party insurers with whom we work (each a "Third Party Insurer"), we may collect additional information as necessary to submit your application to such Third Party Insurer for processing. In this regard, we may collect from you the following information:

    • Your health care providers and any medications that you take
    • Credit card or bank account information

    Information Received from Third Parties

    We may receive information about you from your current or former employer or labor union, which may include your social security number, Health Insurance Claim Number, and/or Tax identification Number. Otherwise we may work with third parties who provide us with the name, contact details and other relevant information about potential customers, who may be interested in the Services, as well as third parties that assist us in updating or enhancing the information—such as contact information—that we have collected about individuals. The personal information we collect from third parties may be combined with the other information we have collected about individuals or demographic information obtained from secondary sources, such as address update services. In addition, when we help an individual identify, apply for or obtain a Policy from a Third Party Insurer, we may receive limited information back from Third Party Insurer when your Policy is issued (such as the date, term, premium amount, payment terms, etc.).

    In addition, when engaging or using our Services, we collect information about you from your health care providers, such as hospitals, doctors, and laboratories. We may also collect information about your health condition from your health plan.

    Social media sign-on: if you choose to log in to our community forum board through a social media service (e.g., Facebook, Twitter, Instagram, etc.), we collect your permission to access certain information from your profile with that social media service. If you post in or engage the community forum board through such a social media service, we may collect personal information about you related to those interactions.

    Information Collected Automatically

    Our Sites use cookies, pixels, tags, log-files, and other technologies, which may be provided by third parties, to collect information about a user’ from their browser or device, including, without limitation, your browser type, platform-dependent information, requested document, referrer URL, date and time of your visit, clickstream data (e.g., about the pages you view, links you click and date and time stamps for your activities on our Sites) and the IP address associated with your transactions in the system. This information that we collect automatically may be linked with other personal information we have collected. For more information, see the Cookies and Tracking section below.

    Use of Personal Information

    We may use the personal information that we collect about you for the following purposes:

    • Providing our Services and related support: including to help fulfill your requests for products and services; to communicate with you about you use of our Services; to respond to your inquiries; to facilitate your application for one or more Policies; to provide troubleshooting and other technical support; and for other customer service and support purposes.
    • Protecting the integrity of the Services: including to verify your identity; to detect and prevent fraud and unauthorized activities; to facilitate software; to preserve the integrity of the Services and our systems, and prevent unauthorized access and activities; to enforce our applicable terms; and to protect the rights and safety of others
    • Analyzing and improving the Services and our business: including to better understand how users access and use our Services; to evaluate and improve the Services and our business operations; to develop new features, offerings and services; to conduct surveys and other evaluations; and for other research and analytical purposes.
    • Personalizing the Services: including to tailor content we send or display on our Sites and Services (e.g., for your geographic area); to offer personalized help and instructions; and to otherwise personalize your experiences with the Services.
    • Advertising, marketing and promotional purposes: including to send or display targeted marketing; to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to contact you about our Services, and those of our affiliates, as well as other information we think may interest you; and to share your information with third parties so that they may contact you with information about products and services you may be interested in. Where required by applicable law, we will obtain your consent to use your personal information for marketing and related purposes. We do not use personal information from your application(s) with any Third Party Insurer for marketing or advertising purposes.
    • Securing and protecting our business: including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct.
    • Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with Users or third parties.
    • Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; to maintain appropriate business records; to enforce company policies and procedures; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.
    • Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or law enforcement requests.

    Disclosure of Personal Information

    We may share or disclose the personal information we collect as follows:

    • Insurance companies and authorized plan administrators: If you submit an application for a Policy, we will disclose your personal information to your chosen insurance company to process your application. If you enroll in a health subsidy account (such as a Health Reimbursement Arrangement) or other similar account offered through an authorized plan administrator with whom we have associated, we may disclose your personal information that trustee or administrator to complete your enrollment in the account.
    • Service Providers: We may disclose personal information with third-party service providers who use this information to perform services for us, such as hosting providers, auditors, advisors, consultants and customer service and support providers.
    • Third parties: We may share personal information with third parties that provide advertising, campaign measurement, online and mobile analytics, and related services. These third parties may receive or access as browsing and other data about your use of the Services, in order to help us better reach individuals with relevant ads and measure our ad campaigns, or to better understand how individuals interact with our Site and online services overtime and across devices. We do not share personal information from your application with a Third Party Insurer with third parties for marketing or advertising purposes.
    • User generated content: If you post or communicate information through certain features of our Site or services, such information may be publicly available to other users. For example, if you submit a comment to a blog post, your comment may be published on the Site and elsewhere (as provided in our Terms of Service).
    • Business transfers: We may disclose or transfer personal information as part of any actual or contemplated merger, sale, and transfer of our assets, acquisition, financing or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.
    • Legally required: We may disclose personal information if we are required to do so by law (e.g., to law enforcement, courts or others, e.g., in response to a subpoena or court order).
    • Protect our rights: We may disclose personal information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation and protect the rights, property or safety of Extend Health, our clients and customers or others.

    Anonymized and Aggregated Data. We may share aggregate or de-identified information with third parties for research, marketing, advertising, analytics and other purposes.

    Cookies, Analytics and Personalization

    We use cookies, pixels, tags, and other technologies, which may be provided by third parties, on our Sites to enable certain functionality and for security and fraud detection and prevention, as well as to collect usage information about our Sites and the emails that we send and to personalize content and provide more relevant ads and information. We may combine the information we collect via these technologies with other information, including personal information, that we collect.

    Cookies: Cookies are alphanumeric identifiers that are transferred to your computer through your web browser for record-keeping purposes. Some cookies enable you to log-in to our Sites or save certain settings and preferences, while others, allow us to track usage and activities on our Sites, personalize content on our Sites, or deliver more relevant ads on our Sites and third party sites. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The “Help” tab on the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies, however, certain features on our Sites may not be available or function properly.

    Pixel tags and embedded script (aka clear GIFs and web beacons): Pixel tags are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, pixel tags are embedded invisibly on web pages. We may use these, in connection with our Sites to, among other things, track the activities users of our Services, improve ads, personalize and manage content, and gather usage information about our Sites. We may also use these in HTML emails to, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

    Do-Not-Track signals: Please note that our Websites do not recognize or respond to any signal which your browser might transmit through the so-called 'Do Not Track' feature your browser might have. If you wish to disable cookies on our Services, you should not rely on any 'Do Not Track' feature your browser might have. For more information about do-not-track signals, please click here.

    Interest-based Advertising: We work with third party ad networks, channel partners, measurement services and others ("third party ad companies") to display advertising on our Services, and to manage our advertising on third party sites, mobile apps and online services. We and these third party ad companies may use cookies, pixels tags, and other tools to collect activity information on our Services (as well as on third party sites and services), as well as IP address, device ID, cookie and advertising IDs, and other identifiers, general location information, and, with your consent, your device’s geolocation information; we and these third party ad companies use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.

    You may control how participating third party ad companies use the information that they collect about your visits to our Sites, and those of third parties, in order to display more relevant targeted advertising to you; for more information and to opt-out of go to:

    Opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.

    Your Choices

    If you need to update your contact details or other personal information provided to us, please contact us as set forth in the Contact Us section below. California residents have certain rights, under California privacy laws, regarding their personal information, which are set forth below, in the Additional Information for California Residents section below.

    Opt Out/Unsubscribe: To stop receiving future e-mail marketing communications from us, please send an e-mail to support@viabenefits.com or write to us at the following address requesting that we stop sending future e-mail marketing communications from us.

    Sales Support
    Via Benefits Insurance Services
    10975 S. Sterling View Drive, Suite A1
    South Jordan, UT 84095

    To unsubscribe from the applicable insurer’s communications, you must contact such insurer directly. To opt-out of certain targeted advertising, follow the instructions set forth in the Interest Based Advertising section above.

    Third Party Links and Websites

    Our Sites may contain links to other third-party owned and/or operated websites. We are not responsible for the privacy practices or the content of such third-party websites. In some cases, you may be able to make a purchase through one of their third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and we have no responsibility or liability relating to such policies or practices.

    Security

    We have taken certain physical, electronic, contractual and managerial steps to safeguard and secure the personal information we collect. Please note, however, that it is your responsibility to maintain the confidentiality of your password associated with this Site, if any. In addition to using a variety of security technologies and procedures to protect your personal information generally, to the extent your Social Security Number ("SSN") is collected, we also take measures to maintain its confidentiality, to protect it from unlawful disclosure and limit access to it by unauthorized third parties. Specifically, we will not make your SSN available to the general public, print your SSN on any card, require your SSN to access products or services, require you to transmit your SSN on the Internet unless the connection is secure or the SSN is encrypted, or require you to transmit your SSN to access a website without requiring additional authentication.

    Minors

    Our Services are not designed for individuals under 18, and we do not knowingly solicit or collect information from individuals under the age of 18. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children. We will not be liable for any content or advertisements viewed by minor children in violation of the terms of this Privacy Policy.

    Changes to this Privacy Policy

    We may amend this Privacy Policy from time to time. When we do, we will post the change on this Website. If we change the Privacy Policy in any material way, we will provide appropriate online notice to you.

    Contact Us

    If you have any questions or suggestions regarding this Privacy Policy, you should feel free to contact us at privacy@extendhealth.com or at

    Privacy Policy
    Via Benefits Insurance Services
    10975 S. Sterling View Drive, Suite A1
    South Jordan, UT 84095

    IMPORTANT ADDITIONAL PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS

    In this section, we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act ("CCPA"), which requires that we provide California residents certain specific information about how handle their personal information, whether collected online or offline.

    This section does not address or apply to our handling of personal information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA, such as protected health information that is subject to HIPAA or the California Medical Information Act, or publicly available data lawfully made available by federal, state or local government records. This section also does not apply to personal information we collect about job applicants, independent contractors, or current or former full-time, part-time and temporary employees and staff, officers, directors or owners of Via Benefits.

    Categories of Personal Information that We Collect and Disclose
    The list below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect and disclose to others for a business purpose. We do not sell personal information about California residents. We collect these categories of personal information from the sources described in the Personal Information Collected section above, and for the purposes described in the Use of Personal Information section above. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident.

    Categories of personal information that we collect and disclose for a business purpose

    • Name, contact information and other identifiers: identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
    • Customer records: paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, current employment, employment history, social security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial or payment information, medical information, or health insurance information.
    • Protected classifications characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.
    • Commercial information including records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
    • Internet or Other Electronic Network Activity Information: including records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
    • Audio, Video and other Electronic Data: audio, electronic, visual, thermal, olfactory, or similar information such as, CCTV footage, photographs, and call recordings.
    • Employment history: professional or employment-related information.
    • Education information: education information that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
    • Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

    California Resident Rights
    California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.

    Notice at Collection: At or before the point of collection, notice must be provided to California residents of the categories of personal information collected and the purposes for which such information is used.

    Verifiable Requests to Delete and Requests to Know: Subject to certain exceptions, California residents have the right to make the following requests, at no charge:

    Request to Delete: California residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies.

    Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:

    • categories of personal information collected;
    • categories of sources of personal information;
    • business and/or commercial purposes for collecting their personal information;
    • categories of third parties/with whom we have disclosed or shared their personal information;
    • categories of personal information that we have disclosed or shared with a third party for a business purpose;
    • categories of personal information collected; and
    • categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.

    California residents may make Requests to Know up to twice every 12 months.

    Submitting requests. Requests to Know, and Requests to Delete may be submitted:

    We will respond to verifiable requests received from California residents as required by law.

    Right to Non-Discrimination: The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

    Your California Privacy Rights Under the Shine the Light Law
    California law allows individuals that reside in California to know the third parties with whom we shared their personal information for those parties’ own marketing purposes. The type of information and instances in which we share such information is detailed in this Privacy Policy. However, if you are a resident of California and you would like to know the specific companies with whom we shared your personal information and the categories of the information we shared, you should please feel free to send us an email at privacy@extendhealth.com. Alternatively, you may send us a written request for such information to the following address: