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Website Privacy Policy Last Revised: February 1, 2024
1. General
We know that your privacy is important to you, and we work hard to earn and keep your trust. Choice Administrators Insurance Services, Inc. (collectively with its subsidiaries, “Company,” “we,” “us,” and “our”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”).
This Policy describes:
• The types of information we collect from you or that you may provide when you visit our websites available at: www.choicebuilder.com and any other applicable website (“Websites”). • Our practices for collecting, using, maintaining, protecting, and disclosing that information.
This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Websites (for further information, see below, “Third-party Websites”).
This Policy governs our interactions with you in any one of the following capacities:
• Visitor. You may simply just visit our Websites and browse information, or possibly sign up for a newsletter or otherwise request communications from the Company. • User. You may have access to our Websites and services as an employee of one of our customers. As such, you may be granted an ID and password to access secure portals on our Websites.
Unless otherwise specified, this Policy applies in the same manner to you and your personal information.
Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Websites. By using our Websites, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our Websites after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates. 2. Website Terms of Use; Other Agreements
This Policy should be read in conjunction with any applicable Terms of Use, into which this Policy is incorporated by reference. Furthermore, as a User, your use of the Websites and our processing of your information may also be subject to a terms of sale, written contract with your employer, or other agreement specific to the nature of any transaction in which you are participating.
3. What We Collect and How We Collect It
To ensure that we provide you with the best possible experience, we will store, use, and share personal information about you in accordance with this Policy. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”). In particular, the Websites may collect the following categories of Personal Information from users of the Websites:
| | | Category | Examples | Collected | | Identifiers. | A real name, postal address, unique personal identifier, online identifier, Internet Protocol address,
email address, account name. | YES | Personal information categories
listed in the California Customer
Records statute
(Cal. Civ. Code §1798.80(e)). | A name, signature, Social Security number, address, telephone number, or health insurance information. | YES | Protected classification
characteristics. | Age, marital status, sex. | YES | | Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies. | NO | | Sensitive Personal Information | Social Security number. | YES | | Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a
template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints,
iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO | Internet or other similar network
activity. | Browsing history, search history, information on a consumer's interaction with a website, application, or
advertisement. | NO | | Geolocation data. | Physical location or movements. | NO | | Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO | Professional or employment-
related information. | Current or past job history or performance evaluations. | NO | Non-public education
information. | Education records directly related to a student maintained by an educational institution or party acting on
its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student
financial information, or student disciplinary records. | NO | Inferences drawn from other
Personal Information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities, and aptitudes. | NO |
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We obtain the categories of Personal Information listed above from the following categories of sources:
• Directly from you. For example, when you:
o register yourself with the Websites;
o subscribe to one of our e-newsletters;
o submit a job application; or
o communicate with us, such as request information.
• Indirectly from you. For example, through information we collect from you in the course of providing our services to you. • Directly and indirectly from activity on our Websites. For example, from Websites usage details that are collected automatically. For more information on automatic information collection, please review the “Automated Information Collection” section below.
The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting the Company to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.
Additionally, we may ask you to create a username and password that should only be known to you. When you provide this information to us, you are no longer anonymous. Moreover, we may receive information about you from other sources and add it to the information you have provided to us.
4. Automated Information Collection
In addition to the information that you provide to us, we may also collect information about you during your visit to our Websites. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Websites. Some of the tools we use to automatically collect information about you may include:
(a) Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use either (or both) of them:
(1) session cookies, which do not stay on your device after you close your browser, and
(2) persistent cookies, which remain on your device until you delete them or they expire.
We may use the following categories of cookies on our Websites.
i. Strictly Necessary Cookies. These cookies are essential in order to enable you to move around the Websites and use its features. Without these cookies, services you have requested, such as maintaining a record of your purchased items, cannot be provided.
ii. Performance Cookies. These cookies collect anonymous information on how you use our Websites to help us understand how you arrive at our Websites, browse or use our Websites and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.
iii. Functionality Cookies. These cookies remember choices you make such as the country from which you visit our Websites, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to our Websites more tailored to your preferences. The information in these cookies may be anonymized. These cookies cannot track your browsing activity on other websites.
iv. Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks. These cookies remember the websites you visit and that information is shared with other parties, such as advertisers.
Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Websites’ features or lose access to some functionality.
(b) Google Analytics. The Websites send aggregated non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Websites’ performance. For more information on how Google Analytics supports the Websites and uses information sent from the Websites, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites. (c) Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our Websites. This information is only collected in aggregate form and will not be linked to your Personal Information. Please note that any image file on a webpage can act as a Web Beacon. (d) Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns. (e) Third-party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Websites and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.
5. How We Use Your Information
The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to: • providing the information and services you request; • security, credit or fraud prevention purposes; • providing you with effective customer service; • providing you with a personalized experience when you use our Websites; • contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us); • contacting you with information and notices related to your use of our Websites; • inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us); • better understanding your needs and interests; • improving the content, functionality and usability of our Websites; • improving our services; • improving our marketing and promotional efforts; and • any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.
Duration. The length of time Company intends to retain each category of Personal Information, including sensitive information is for as long as reasonably necessary to carry out Company’s intended business purpose for such information.
6. How We Disclose Your Information
We do not sell or lease your Personal Information to any third party. We may disclose your Personal Information to a third party for a business purpose. When we disclose your Personal Information, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract.
In the preceding twelve (12) months, we may have disclosed the following categories of Personal Information for one or more business purposes:
• Commercial information; • Internet or other network activity information; • Inferences drawn from other Personal Information.
We may disclose your Personal Information for a business purpose to the following categories of third parties:
• Contracting health plan carriers; and • Third party vendors who provide services that enhance our Websites, products and services to you (such as vendors for credit card processing, advertising and marketing and customer support).
Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:
o We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;
o To respond to duly authorized information requests from law enforcement or other governmental authorities;
o To enforce our agreements, policies, or the Terms of Use;
o To investigate and prevent security threats, fraud, or other malicious activity; or
o To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.
• Sale of Business or Merger. There are circumstances where the Company may decide to buy, sell, or reorganize its business in selected countries. Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, the Company will ensure your information is used in accordance with this Policy.
7. Your Choices and Selecting Your Privacy Preferences
We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information.
If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.
We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information. After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.
8. Text Messaging
If applicable, you may have the opportunity to receive SMS or "text" messages, pre-recorded voice messages or auto-dialed phone calls from the Company, its affiliates and related entities as well as third parties. Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested. In providing your mobile device number or cell phone number to the Company, you knowingly consent to such communications from the Company or for the Company to use your cell phone number or mobile device number in accordance with the Company’s Terms of Use. In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to the Company, or from which you sent the text message request to us. You further acknowledge that no purchase is required to opt into this service, and you may opt out at any time by following the instructions provided in our communications to you.
Any such communications you receive from us will be administered in accordance with your preferences and this Policy. 9. Accuracy and Access to Your Personal Information
We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing. Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it. To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.
10. Information of Minors
We do not intentionally seek to gather information from individuals under the age of thirteen (13). We do not target the Websites to minors, and would not expect them to be engaging with our Websites or services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems. 11. Submissions
We welcome inquiries or feedback on the services or products you might use or like to use. Any inquiries, feedback, suggestions, ideas, materials, comments or other information you provide to us (collectively, “Submissions”) will be treated as non-proprietary and non-confidential. Your Submissions on or through this Websites are available to others who visit this Websites. In addition, we may use your Submissions in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the Submissions for such purposes. Therefore, you should have no expectation of privacy with respect to your Submissions on or through this Websites. You should not submit any content you do not wish to make available to the general public, and you must take special care to make sure your Submissions comply with our Terms of Use or other applicable agreements. All terms and conditions of our Terms of Use apply to Submissions on or through this Websites. In particular, your Submissions must not violate the privacy or other rights of others. You may not use false identifying information or contact information, impersonate any person or entity, or otherwise mislead us as to the origin of any Submission.
12. Third-party Websites
This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Websites may link to third-party websites and services. For example, if you click on an advertisement on this Websites, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.
13. Your Rights Under State Law
California
• Shine the Light law. Pursuant to California Civil Code Section 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent. • Do Not Track Signals. Other than as disclosed in this Policy, the Websites do not track users over time and across third-party websites to provide targeted advertising. Therefore, the Websites do not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser. • WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION. If we ever decide to “sell” or “share” Personal Information, as those terms are defined under the California Consumer Privacy Act of 2018, we will update you via this Policy and include a link entitled “Do Not Sell or Share My Personal Information,” to provide you with an opportunity to opt out of the selling or sharing of your Personal Information.
Your Consumer Rights
Some state laws in the United States provide consumers with additional rights with respect to their personal information (also known as “personal data”), as those terms are defined under those applicable state laws. Such state laws may include, but are not limited to, the California Consumer Privacy Act of 2018 (the “CCPA”) as amended by the California Privacy Rights Act, the Colorado Privacy Act (“CPA”) and the Virginia Consumer Data Protection Act (“VCDPA”). Any personal information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. If you reside in a state that provides additional rights with respect to your personal information, you may exercise each of your rights as identified below, subject to our verification of your identity.
A. Access. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. B. Correction. You can correct what personal data our Websites database currently contains by accessing your account directly, or by contacting us to request that we correct or rectify any personal data that you have provided to us. C. Limit Use and Disclosure of Sensitive Personal Information. If we collect any sensitive personal information, you have the right to request that we limit the use of the sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services. D. Portability. Upon request and when possible, we can provide you with copies of your Personal Information. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy. E. Deletion. You have the right to request that we delete any of your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. Where applicable, we will ensure such changes are shared with trusted third parties. F. Opt-out of Processing. You have the right to request that we do not sell your Personal Information, use your Personal Information for Targeted Advertising, or use your Personal Information for profiling. Where applicable, we will ensure such changes are shared with trusted third parties. G. Non-Discrimination. If a data subject exercises his or her rights under applicable state law, including but not limited to the CCPA, CPA, and VCDPA, we shall not discriminate against that data subject by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action. H. Exercising your rights. If you are a data subject that has rights under applicable state law, including but not limited to the CCPA, CPA, and VCDPA, who chooses to exercise the rights listed above, you can:
1. Submit a request via email at Compliance@ChoiceAdmin.com; or
2. Call us at (866) 251-4718 to submit your request.
Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.
Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.
We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.
In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
14. For Website Users or Visitors Outside of the United States
Our Websites are designed for use by individuals in the United States only. We do not warrant or represent that this Policy or the Websites’ use of your Personal Information complies with the laws of any other jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.
15. Safeguarding the Information We Collect
We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us of any actual or suspected unauthorized use. 16. Changes to this Policy
This Policy describes our current policies and practices with regard to the information we collect through our Websites. We are continually improving and adding to the features and functionality of our Websites along with the products and services we offer through our Websites. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).
17. How to Contact Us
We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us by email at Compliance@ChoiceAdmin.com or by telephone at (866) 251-4718.
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