Effective Date: January 5, 2023
Date Last Updated: October 1, 2023
1. Introduction
If you are a California resident, see Section 13 for more
information about your specific privacy rights.
Thank you for your interest in Insure Choice , LLC (“Insure
Choice,” “we,” “us,” or “our”). We are committed to protecting the privacy of
those with whom we interact. This Privacy Statement (“Statement”) contains
details about how we collect, use, and share personal information about you
(defined below) that we obtain from you when you interact with us via our
websites (including those listed below), email, mobile application, social
media accounts, insurance agent and representative services, communication
channels (including online chat and telephone call centers), in other online
and offline interactions and services, and from other sources (collectively,
the “Service”).
Please read this Statement carefully. It applies to the
following websites owned and operated by Insure Choice, and our other websites
where we post this document as the applicable Privacy Policy:
Applicability: We collect personal
information in several contexts as described below. However, this Statement
does not apply to the following information:
Changes: We may update this
Statement from time to time. The current Statement will be effective when
posted. Please check this Statement periodically for updates. If any of the
changes are unacceptable to you, you should cease interacting with us. When
required under applicable law, we will notify you of any changes to this
Statement by posting an update on this website. When required under applicable
law, we will seek affirmative consent from you before making material changes
to the way we handle personal information previously collected from you. If you
do not provide such consent, personal information will continue to be used in a
manner that is consistent with the version of this Statement that was in effect
when the information was collected.
2. Sources of Personal Information
We collect information about you and how you interact with
us in several ways, including:
a.
Information you provide to
us directly. We collect information that you
provide to us directly, such as when you register with us through our Services,
or you apply for a health insurance or other product through our Services.
b.
Information automatically
collected or inferred from your online interaction with us. We automatically collect technical information about
your online interactions with us (such as IP address and browsing preferences).
c.
Information from public
sources, such as information from public
records maintained by government entities, and information you submit in public
forums.
d.
Information from third
parties. We receive information about you
and your interactions with us from third parties, such as pharmacies,
healthcare providers, insurance companies, credit reporting agencies, marketing
and advertising providers, social network services, referral partners, data
brokers, and companies that provide or sell lists of potential purchasers. We
also may receive information about you from friends and family members (such as
other people insured under the same policy as you).
We may combine information that we receive from the various
sources described in this Statement, including third-party sources and public
sources, and use or disclose it for the purposes identified below.
3. Types of Personal Information We Collect
The types of personal information that we may collect about
you include:
a.
Identifiers, such as your name, alias, postal address, , telephone
number, unique personal identifier, online identifier, internet protocol
address, email address, username, phone number, social media identifiers (e.g.,
Twitter handle, Instagram name, etc.), Social Security number, driver’s license
number, or other similar identifiers, including identifiers for family members
who may be insured under an insurance policy.
b.
Customer records, such as your name, signature, address, telephone number,
bank account number, credit card number, or other payment information.
c.
Application and
eligibility information for you and family members
who may be insured under an insurance policy, such as age, date of birth,
gender, health status, race and ethnicity information, disability, medical
history, military or veteran status, date of birth, and financial and tax
information (for government subsidies).
d.
Commercial information and
preferences, including product preferences,
advertising preferences, products or services purchased, obtained, or
considered, or other preferences or interests.
e.
Internet or other
electronic network activity information, such
as your browsing history, search history, IP address, and information regarding
your interactions with us (including interacting with us online, by the mobile
application, and through advertisements).
f.
Geolocation information, such as approximate location based on your IP address.
g.
Audio, electronic, visual,
or similar information, such as call center
recordings, photos at events or customer support chat logs.
h.
Professional or employment
information, such as job title, employer,
business address and contact information.
i.
Inferences drawn from any of the information we collect to
create a profile about you reflecting your preferences and characteristics.
4. How We Use Your Personal Information
We may use each category of your personal information
described above in the following ways:
a.
To enable interactions
between you and us, such as to facilitate online
quoting, applications for, and purchases of our products; to register and administer
your account, to support your interactions with us; to provide information
about insurance plans; to communicate with you about your policy or our data
practices; to install and configure changes and updates to programs and
technologies related to interactions with us; to authenticate those who
interact with us; and to respond to your requests, complaints, and inquiries.
b.
For our own internal
business purposes, such as to evaluate or audit the
usage and performance of programs and technologies related to interactions with
us; to evaluate and improve the quality of your interactions with us and the
quality of programs and technologies related to interactions with us; to design
new services and products; to process and catalog your responses to surveys or
questionnaires (e.g., customer satisfaction reviews); to perform internal
research for technological development and demonstration; to conduct data
analysis and testing; and to maintain proper business records.
c.
For legal, safety, or
security reasons, such as to comply with laws and
other legal requirements; to protect our safety, our property or the rights of
those who interact with us, or others; and to detect, prevent, and respond to
security incidents or other malicious, deceptive, fraudulent, or illegal
activity.
d.
In a de-identified,
anonymized, or aggregated format. We may convert personal
information into a de-identified, anonymized, or aggregated format, and use
such information for any legal purpose.
e.
For marketing. We may use your personal information to market our
products or services or those of third parties, such as our business partners.
We may use your personal information to invite you to participate in marketing
surveys, questionnaires, promotions, events or contests. We may audit aspects
of our ad impressions. We may use your personal information for short-term
transient use, including for contextual ad customization. We may use your
personal information to enhance our content, to better design and target
marketing campaigns, and to deliver advertisements to you, including in
commercial emails. For more information about online marketing activity, see
Section 6 below.
f.
To fulfill other purposes disclosed at the time you provide personal
information or otherwise where we are legally permitted or are required to do
so.
g.
For any other purposes for which you provide consent.
5. With Whom We Share Your Personal Information
We may share your personal information with the categories
of recipients
described below:
a.
Affiliates and
subsidiaries: We may share your personal
information within the Insure Choice Insurance group of companies, which
includes parents, corporate affiliates, subsidiaries, business units and other
companies that share common ownership for the purposes described above.
b.
Insurance providers,
government health care exchanges, and related entities: In order to provide you with insurance you request, we may
share your information with insurance companies, Federally-facilitated
Exchanges or State-based Exchanges, HSA Trustees or Administrators, and similar
entities.
c.
Service providers and
other third parties that help fulfill requests: We may share your personal information with third-parties
and service providers that facilitate and support us in processing a request or
transaction on your behalf; to provide you with quotes, products, and services;
and to process payments. We may share your personal information with an
insurance agent when you request to be contacted by an agent, or when you
request information about or an application for insurance that is offered
through an insurance agent with whom we associate. If you are contacted by a
third party, any additional information that you subsequently choose to provide
to any third-party entity will be governed by that entity’s privacy policy.
d.
Third parties that provide
business and professional services to us, such
as web hosting service providers, IT providers, operating systems and
platforms, internet service providers, analytics companies, and marketing
providers (e.g., we may share your email address with our outbound email
marketing providers), our attorneys, accountants, and auditors. We take
reasonable efforts to provide these companies with only the information they
need to perform services on our behalf and to limit their use and disclosure of
personal information.
e.
Business partners: We may also provide your personal information or provide
access to your personal information to our business partners, such as marketing
and advertising providers; social media companies; partners who work with us on
joint marketing efforts and/or joint promotional or sponsorship opportunities,
including co-branded products and services; referral, lead generators, and
other commercial data partners; and other similar third parties.
f.
For legal, security and safety
purposes: We may share your personal
information with third parties such as law enforcement, regulators, or others
to comply with federal, state, or local laws, a subpoena or other legal
process, and other applicable legal requirements; to protect the
confidentiality and security of our records; to protect against or prevent
fraud; for claims administration; to enforce or apply our Terms of Use and
other agreements; and to protect our rights and our property or safety of our
users or third parties.
g.
In connection with a
corporate transaction: We may transfer any
information we have about you in connection with a change in corporate control,
including but not limited to a merger or sale (including transfers made as part
of insolvency or bankruptcy proceedings) involving all or part of Insure Choice
, LLC and its business, or as part of a corporate reorganization or stock sale.
h.
Organizations with which
you have a relationship: We may disclose personal
information to an affinity group, employer, provider group, benefits
administrator or consultant, healthcare system, pharmacy, financial services
provider, or other entity with which you may have a relationship when such
entity referred you to us or when you use our website or call center in connection
with your relationship to such entity.
i.
To others with your
consent.
We may also de-identity, anonymize, or aggregate personal
information to share with third parties for any purpose.
6. How We Use Cookies and Automatic Data Collection Tools
We (and authorized third parties) use cookies and other
tracking technologies on our websites, mobile application, online
advertisements, and other online properties (“Digital Properties”) to collect
information about you, your device, and how you interact with our Digital
Properties. This section contains additional information about:
a.
Types of Cookies and
Tracking Technologies We Use
Our
Digital Properties and the third parties that we authorize may use the
following tracking technologies:
o
Cookies, which are a type of technology that install a small
amount of information on a user’s computer or other device when they visit a
website. Some cookies exist only during a single session and some are
persistent over multiple sessions over time.
o
Pixels, web beacons, and
tags, which are types of code or
transparent graphics. In addition to the uses described below, these
technologies provide analytical information about the user experience and help
us customize our marketing activities. In contrast to cookies, which are stored
on a user’s computer hard drive, pixels, web beacons, and tags are embedded
invisibly on web pages.
o
Session replay tools, which record your interactions with our Digital
Properties, such as how you move throughout our Digital Properties and engage
with our webforms. In addition to the uses described below, this information
helps us improve our Digital Properties and identify and fix technical issues
visitors may be having with our Digital Properties.
o
Embedded scripts and SDKs, which allow us to build and integrate custom apps and
experiences, some of which may be developed by a third party.
b.
Purposes for Using These
Technologies
We and
authorized third parties use these technologies for purposes including:
o
Personalization, such as remembering user preferences, login details and
browsing behavior; tracking your activity across online properties and
platforms over time to better understand your preferences and interests; and
personalizing online content;
o
Improving performance, such as maintaining and improving the performance of our
Digital Properties;
o
Analytics, such as analyzing how our websites are used. For example,
we use Google Analytics to help us improve our Digital Properties’ performance
and user experiences. Google Analytics may use cookies and other tracking
technologies to perform their services. To learn how Google Analytics collects
and processes data, please visit: “How Google uses data when you use our
partners’ sites or apps” located at www.google.com/policies/privacy/partners;
o
Advertising, such as providing you with offers that may be of interest
to you; conducting targeted advertising to you on our Digital Properties and
those of third parties, including jointly marketing the products and services
of our and other businesses; and measuring the effectiveness of our
communications with you and advertising campaigns, including identifying how
and when you engage with our communications.
c.
Information Collected
These
tracking technologies collect data about you and your device, such as your IP
address, location (both approximate and precise), cookie ID, device ID, AdID,
operating system, browser used, browser history, search history, and
information about how you interact with our Digital Properties (such as pages
on our Digital Properties that you have viewed).
d.
Disclosures of Your
Information
We may
disclose information to third parties or allow third parties to directly
collect information using these technologies on our Digital Properties, such as
social media companies, advertising networks, companies that provide analytics
including ad tracking and reporting, security providers, and others that help
us operate our business and Digital Properties. These companies may use these
technologies to gather information about both your visits to our Digital
Properties and your visits elsewhere on the Internet, including to provide you
with more relevant advertising in what is known as interest-based advertising.
e.
Your Choices
Some of
the companies that perform advertising-related services for us may participate
in the Digital Advertising Alliance (“DAA”) and/or Network Advertising
Initiative (“NAI”). The DAA and NAI provide mechanisms for you to opt out of
interest-based advertising performed by members at http://www.aboutads.info/choices
and https://optout.networkadvertising.org/. You may also click on the AboutAds
icon on advertisements and follow the instructions on how to opt out. Opting
out of interest-based advertising will not opt you out of all advertising, but
rather only interest-based advertising from us or our agents or
representatives. Also, if your browsers are configured to reject cookies when
you visit these opt-out webpages, or you subsequently erase your cookies, use a
different device or web browser or use a non-browser-based method of access
(e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no
longer, be effective.
You can
also refuse or delete cookies using your browser settings. If you refuse or
delete cookies, some of our website functionality may be impaired. If you
change computers, devices, or browsers, or use multiple computers, devices, or
browsers, and delete your cookies, you may need to repeat this process for each
computer, device, or browser. Please refer to your browser’s Help instructions
to learn more about how to manage cookies and the use of other tracking
technologies.
Some
browsers have incorporated Do Not Track (“DNT”) preferences. Most of these
features, when turned on, send signals to the website you are visiting that you
do not wish to have information about your online searching and browsing
activities collected and used. As there is not yet a common agreement about how
to interpret DNT signals, we do not honor DNT signals from website browsers at
this time.
7. Security
We maintain reasonable security procedures and technical
and organizational measures to protect your personal information against
accidental or unlawful destruction, loss, disclosure, access, alteration, or
use. Nevertheless, transmission via the Internet and online digital storage are
not completely secure and we do not guarantee the security of your information
collected through the Service.
8. Children’s Privacy
Interactions with us are intended for individuals 16 years
of age and older. Our interactions are not directed at, marketed to, nor
intended for, children under 16 years of age. We do not knowingly collect
any information, including personal information, from children under 16 years
of age. If you believe that we have inadvertently collected personal
information from a child under the age of 16, please contact us at the address
below and we will use reasonable efforts to delete the child’s information from
our databases.
9. External Links
When interacting with us you may encounter links to
external sites or other online services, including those embedded in
third-party advertisements or sponsored content which we do not
control. We are not responsible for the privacy practices and data
collection policies for such third-party services. You should consult the
privacy statements of those third-party services for details.
10. Your Rights
Upon request, Insure Choice will provide you with
information about whether we hold any of your personal information. If your
personal information changes, or if you otherwise want to correct, update,
delete, or make other requests regarding your data (such as limiting sharing
with non-affiliates), you may email us at [email protected] or
by mail at:
Insure Choice
1700 S. Lamar Blvd Ste 338 Austin, TX 78704
We will make reasonable efforts to respond to your request
but cannot guarantee that we will be able to honor your request. For
example, we generally will retain your information for as long as your account
is active, as needed to provide you services, or for other business purposes.
We will retain and use your information as necessary to comply with our legal
obligations, resolve disputes, and enforce our agreements.
Please note that once your application has been submitted
to your chosen health insurance company or any other relevant party (such as
the federal government in the case of an application involving advanced premium
tax credits) you may have to contact the insurance company or such other party
directly to update your application and/or exercise your individual rights
under HIPAA.
To opt-out of receiving promotional email messages from us,
please click on the “Unsubscribe” link contained at the bottom of each email or
by contacting us using the information above. To opt-out of receiving
satisfaction surveys and/or information on additional products and services
from us, you may contact us at the information above. Please note that you will
still receive communications from us regarding your insurance quote,
application, policy or advanced premium tax credit even if you opt-out of
receiving our surveys and/or notices of additional products or services.
11. Terms of Use
The Terms of Use for interactions with us is incorporated
by reference into this Statement and can be found here.
12. Contact
If you have questions regarding this Statement or our
privacy practices, please contact us at:
Insure Choice , LLC
ATTN: Privacy
1700 S Lamar Blvd Ste 338
Austin, TX 78704
[email protected]
13. California Consumer Privacy Act
As an insurance broker, Insure Choice rarely handles
personal information that is subject to the California Consumer Privacy
Act (“CCPA”). In the very limited cases where we may collect information about
certain California residents subject to the CCPA, this section applies.
This CCPA notice does not apply to the following information:
We collect limited personal information subject to the CCPA
from data brokers. We use and disclose such information for our marketing
and related operational purposes. We do not “sell” personal information as
defined under the CCPA and we do not knowingly sell the personal information of
minors under 16 years of age.
We use and disclose sensitive personal information only for
(i) performing services or providing goods reasonably expected by an average
consumer; (ii) detecting security incidents; (iii) resisting malicious,
deceptive, or illegal actions; (iv) ensuring the physical safety of
individuals; (v) short-term, transient use, including nonpersonalized
advertising; (vi) performing or providing internal business services; (vii)
verifying or maintaining the quality or safety of a service or device; or
(viii) purposes that do not infer characteristics about you.
We retain your Personal Information as long as necessary to
fulfill the purposes outlined in this Notice unless we are required to do
otherwise by applicable law. This includes retaining your Personal Information
to provide you with the products or services you have requested and interact with
you; maintain our business relationship with you; improve our business over
time; ensure the ongoing legality, safety and security of our services and
relationships; or otherwise in accordance with our internal retention
procedures. Once you have terminated your relationship with us, we may retain
your Personal Information in our systems and records in order to ensure
adequate fulfillment of surviving provisions in terminated contracts or for
other legitimate business purposes, such as to enable easier future user
onboarding, demonstrate our business practices and contractual obligations, or
provide you with information about our products and services in case of
interest.
The following chart contains more detail about the
categories of personal information we collect and disclose.
Categories of Personal Information
We Collect |
Categories of Third Parties With
Whom We Disclose Personal Information for a Business Purpose |
Identifiers, such your name, alias, postal address, telephone
number, unique personal identifier, email address, phone number, or other
similar identifiers. |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the
disclosure |
Records about you, such as estimated income, financial information, and
other demographic information we receive from data brokers. |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety
purposes · In connection with a corporate
transaction · Entities to which you have consented to the
disclosure |
Characteristics of protected
classifications under California or Federal Law, such as age and gender. |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the
disclosure |
Commercial information, including records of personal property, product or
services purchased, obtained or considered, or other purchasing or consuming
histories or tendencies. |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the
disclosure |
Geolocation data, limited to your address. |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the
disclosure |
Professional, employment, or
education information, such as job title,
employer, business address and contact information, employment history, other
professional information, or education history. |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the
disclosure |
Inferences drawn from any of the information identified above
to create a profile about a consumer reflecting the consumer’s preferences
and characteristics. |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the
disclosure |
Sensitive personal information, such as health information and racial or ethnic origin. |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the
disclosure |
Your Rights
Subject to legal limitations and exceptions, California
residents may exercise the following rights by calling us toll free at
800-977-8860 or by using our webform:
Non-Discrimination: In accordance with
applicable law, we will not discriminate against you for exercising these
rights.
Verification: In order to exercise
your rights, we may need to obtain information to locate you in our records,
verify that you are a California resident, and/or verify your identity
depending on the nature of the request.
Please be aware there might be circumstances where we will
not honor you request, as permitted under the CCPA. For example, if we are not
able to verify your identity and that you are a California resident, we may not
honor your access, correction, or deletion request. Additionally, we may not
delete your personal information if an exception under the CCPA applies to your
deletion request. When making a request, you will be asked to provide your zip
code, first and last name, date of birth, phone number (optional) and indicate
how you would like to be contacted, which may require you provide contact
information. You will also be required to attest that you are entitled to make
the request.
We may request alternative information under certain
circumstances and will inform you if such information is needed in the verification
process.
Authorized Agents: Authorized agents may
exercise rights on behalf of consumers, but we reserve the right to also verify
the consumer directly as described above. Authorized agents must contact us by
mail at the address provided above and include a signed declaration from the
consumer demonstrating the agent has authority to exercise rights on the
consumer’s behalf. We may also require the consumer to directly verify
their own identity with us or directly confirm they provided the agent
permission to submit the request.
Timing: We will respond to
Requests to Know, Requests to Delete and Requests to Correct within 45 calendar
days, unless we need more time (in which case we will notify you) and may take
up to 90 calendar days in total to respond to your request.
California Shine the Light: We do not share personal information subject to
California Civil Code § 1798.83 (the “Shine the Light law”) with third parties
for their direct marketing purpose.