Privacy and Data Use Policy
Last updated: 8/8/2017
Benefit Headquarters, LLC and its related or affiliated companies (“Company”) are dedicated to providing information and useful products and/or services through online, mobile, and other software and related systems and platforms (collectively, the “System”), including, without limitation, on and through the domain name Benefitheadquarters.com and other Systems designated by Company from time to time. As a part of the operation of the System, Company gathers certain data and information about users. This Privacy and Data Use Policy (this “Policy”) applies to the System and governs data collection and usage at, on and through the System. Please read this Policy carefully. By accessing or otherwise using any part of the System, you signify your assent to this Policy. If you do not agree to this Policy, you are not permitted to access or otherwise use the website or any other part of the System.
Two types of data are collected: (a) personal data, such as names, company names, postal addresses, e-mail addresses, telephone numbers, occupation, dates of birth, age, gender, financial information, social security information or similar national ID number, medical or health information, service preferences, and comments that can be used to uniquely identify or contact a single person (“Personal Data”); and (b) non-personal aggregate or traffic data, such as your IP address, which web pages or portions of the System you are visiting, the order in which the areas are visited, unique device identifier, time zone, which hyperlinks or functions are being “clicked”, how many users are visiting or accessing the System, domain server, location-based or real-time geographic location information, type of computer or device, and type of web browser (“Traffic Data” and together with Personal Data, the “Collected Data”).
Collection and Usage
Personal Data is gathered when users provide or authorize Personal Data to or through the System, for example, when registering with the System, inputting content into the System, verifying user credentials, selecting services, or utilizing any other Company service through the System.
Traffic Data is tracked and gathered when you and other users visit or access the System. While gathering Traffic Data may not collect Personal Data, it may provide information on the geographical location from which users access the System. Traffic Data generally does not identify individual users. Instead, the Traffic Data identifies System users as a whole, including demographic information, preferences in content and advertising, quality of service, and web and application traffic patterns.
Company may, in Company’s sole and absolute discretion, release and disclose the Collected Data to affiliated or contracted persons, associations, or other entities of whatsoever nature, including, without limitation, strategic alliances and advertising affiliated persons and/or entities (the “Related Parties”) or to any law enforcement agency, court, or other governmental authority to: (a) fulfill a user’s lawful request; (b) conform to the edicts of the law or comply with legal process; (c) protect and defend Company’s rights and property; or (d) to protect the personal safety of Company’s users, Company’s employees, or the public. Where appropriate, in Company’s sole and absolute discretion, Company may provide notice to you.
For instance, Company may use your Personal Data to: (1) send you information about Company and its services, updates, important notices, health care related services and resources, and/or special offers; (2) send you information about the Related Party’s products and services; (3) conduct surveys about your opinion of Company, its staff, performance, products or services or the System; (4) verify your qualifications for certain promotions, special offers, products or services; (5) bill you for any products and services purchased through the System via a credit card, electronic, or other payment; (6) authenticate your login credentials and personal information; and/or (9) customize, improve, and/or tailor your experience on the System by displaying content that Company thinks you might be interested in according to your preferences.
Company may, in Company’s sole and absolute discretion, release and disclose the Collected Data to any persons, associations, or other entities of whatsoever nature not affiliated with Company (the “Non-Affiliates”) for the purpose of facilitating your claims, purchases, benefits, requests and/or registrations for services provided by Company or the Non-Affiliates (including, without limitation, customer support, information technology support, credit card or other electronic payment processing and personal profile services) when the transfer of such Collected Data is necessary to provide you with such products or services. By selecting, instructing, requesting, reserving, and/or registering for services from Company or the Non-Affiliates on or through the System, you consent to the release of your Collected Data to the Non-Affiliates. Company shall use reasonable efforts to provide the Non-Affiliates access only to the Personal Data necessary to assist in responding to your instructions, requests and/or registrations for such products or services and instruct such Non-Affiliates to use your Personal Data for these limited purposes.
In the event that Company sells, buys, merges, or otherwise reorganizes all or a controlling part of Company’s assets and/or equity (or intends or is considering its options to do so), your Collected Data may be disclosed, released, transferred, sold or otherwise conveyed to prospective or actual buyers, sellers or persons and/or entities related to such actions by Company. You consent to any and all such conveyances of the Collected Data.
Please note that chat rooms, forums, message boards, links to third party websites or mobile applications may be available through the System. Company does not control or manage the privacy policies of such third parties and advises you to use discretion in using third party services. While Company will only use and disclose the Collected Data as set forth herein, any information disclosed in these areas is or may be deemed public information and you must exercise caution and discretion when deciding to disclose personal and non-personal information.
In the event that Company wishes to transfer or release your Personal Data to a third person in a manner not set forth in this Policy, Company shall inform you prior to such transfer or release and provide you with the ability to opt out of such transfer or release of Personal Data. Please contact the Company at email@example.com if you have any questions as to how your Personal Data is being disclosed and to opt out of any specific disclosures, marketing programs, or other similar programs. Cookies and Related Files
The System may place small files, called ‘cookies’ onto your computer or electronic device, as well as related files, such as web beacons, pixel tags, or other means. Cookies are data files that websites or other portions of a system may write onto computer or other electronic device for record keeping purposes when you visit them. The cookie file then identifies you as a unique user. As a convenience feature, cookies simplify the process of recording personal information, so that, for example, users do not have to enter names, addresses or passwords repetitively. Cookies also allow users or Company to customize some System features. You can program your browser not to accept cookies, but if you do, you may be unable to access some parts of the System, and the System will not be able to customize features according to certain preferences. While on the System, you may receive cookies from third party advertisers or promotional entities. These cookies are outside the control of Company, are not subject to the Policy, and Company is not responsible for such third party cookies.
Measures to Safeguard Children
Company’s Services are not directed to or intended for the use of children or users under the age of 18. At various places on the System, Company may ask users whether they are 18 years of age or older or of proper legal age. Company relies on users to be truthful in responding to these questions. Company does not knowingly collect or maintain personal information from children under 13 years of age. Users of the System may provide personal information regarding their children under the age of 13 for the limited purpose of using the products or services available through the System, and it is the requirement of the parent or legal guardian of a child under the age of 13 making any such disclosures to ensure that any such disclosures fully comply with all applicable state and federal laws. If you are under 18 years of age or the proper legal age, you are not allowed to use or access the System at any time or in any manner and any such use is unauthorized.
Except where required in accordance with law, law enforcement agency, court, or other governmental authority, Company does not intentionally solicit Personal Data from individuals under 18 years of age. A parent or guardian whose child provided Personal Data to Company without the parent’s or guardian’s consent should immediately notify Company of such disclosure in writing to the contact provided below. Company, upon receipt of such written notice, shall take reasonable measures to remove such disclosed information from Company’s database and/or notify the appropriate authorities.
Company has implemented security measures to help protect the Personal Data. For example: (a) Company stores Personal Data on servers that are in one or more physical locations that are monitored and accessible by a limited authorized set of individuals and (b) certain Collected Data is obtained through a web form and transmitted using secure socket layer (SSL) or other secure technology as may be determined by Company from time to time. Although Company has implemented such security measures to help protect the Personal Data, the Personal Data may still be accessed, altered, disclosed and/or otherwise used in an unauthorized manner. Please keep in mind that despite the security measures described herein, no method of collecting, storing, or transferring data is without risk. As such: (a) Company is not able to guarantee the security of your Personal Data from unauthorized access, alteration, disclosure and/or other impermissible uses and (b)Company is not responsible if such unauthorized access occurs.
Changes to this Policy
Company will occasionally update this Policy to reflect company and user feedback, or changes in applicable law. You are encouraged to periodically review this Policy to be informed of how Company utilizes or discloses user information. Your continued use of the System constitutes your consent to any and all such changes.
This Policy, the System, and any claim associated with, related to, or arising from the Policy and/or System are governed by the law of the State of Nevada within the United States. Any claim associated with, relating to or arising from this Policy or the System shall be brought in a federal or state court in the County of Washoe, State of Nevada within one year after the claim arises. You hereby affirm your consent to the sole and exclusive jurisdiction of the courts located in the County of Washoe, State of Nevada as the most convenient and appropriate forum for the resolution of disputes concerning this Policy. The System is controlled, operated and administered entirely within the United States. Company’s use of your personal information may not comply with foreign law, so if you do not agree with this section, please do not use the System. Use of the System from locations outside the United States where these practices are illegal or violate any law is prohibited.
Company’s use of your Personal Data may, in some circumstances, be subject to the statutory requirements of the Health Insurance Portability and Accountability Act (“HIPAA”) of 1966. Under HIPAA, you are entitled to certain rights regarding your health information, including, without limitation, the ability to request confidential communications, ask Company to limit the health information we use or share, obtain a copy of the health information stored by Company, obtain a list of those with whom we’ve shared health information, designate someone to make choices on your behalf, and file a complaint with the U.S. Department of Health and Human Services Office of Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/. Company cannot retaliate against you for filing a complaint.
Contact Information Questions about this Policy should be directed to firstname.lastname@example.org.