HIPAA

INFORMATION COLLECTED FOR TEXTING PROGRAM

PERSONAL INFORMATION WE COLLECT

CATEGORY EXAMPLES AND SOURCES

information. We collect your name, phone number, postal address, and email address when you submit a form requesting to be contacted or when you submit an application for enrollment in an insurance product. Login credentials. This includes username and password* if you choose to create a profile with us. Health information*We collect supplemental information about your health and healthcare, such as the medication you take, your preferred pharmacy, and your preferred clinician, your tobacco use, your height, your weight when you provide such information to us on the Platform. This information is used to identify appropriate Medicare plans/life insurance products for you.
Demographic Information*We collect your age, date of birth, and gender when you provide this information to us through our Platform.
Internet or other similar network activity Automatically-collected information on your interaction with the Platform. This may include your browsing history (including the site you came from before visiting our website and the site you went to after leaving our website), duration of browsing session, device ID, and IP address. Audio, electronic, or visual information We may have access to video snippets of users’ online activity, such as clicks and scrolling, that show how users provide consent to be contacted or interact with our Platform. We may also have audio recordings of your conversations with our customer service, sales, or other Company representatives in connection to your inquiries about the Platform.  data We collect geolocation* from users to ensure the security and integrity of the Platform and provide our services. Commercial information.  We collect information about the products and services that may interest you or are requested by you. Professional or employment-related information We collect information about your employment when you provide it to us in the course of submitting an application for enrollment in an insurance product.

USE OF PERSONAL INFORMATION

We may use or disclose the Personal Information that we collect for one or more of the following purposes:

• Operate the Platform, including finding appropriate insurance plans and processing your plan enrollment requests;
• Communicate with you regarding the Platform;
• Connect you with a licensed agent at your request;
• Address your inquiries;
• Process transactions;
• Tailor the content and information that we may send or display to you;
• Analyze use of our products and services;
• Develop new products and services;
• Comply with legal obligations;
• Protect our rights, property, and safety or the rights, property, and safety of others;
• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers is among the assets transferred. You hereby consent to such transfers and we may assign and transfer all of the rights, benefits, duties, and obligations of this Privacy Policy, under the circumstances described in this paragraph

SHARING PERSONAL INFORMATION

We may disclose all categories of Personal Information described above in “Personal Information We Collect” to the third parties listed below for the purpose of facilitating the sale of insurance products to individuals who are interested in purchasing such products.

• With Our Service Providers. We may share Personal Information about you with third parties who perform services for us or on our behalf. For example, this may include payment processors or other operating systems or platforms that help us run our services.
• With Our Business Partners. We may share Personal Information (but not Personal Information that you provide when opting into text messaging communications) with the independent licensed agents who are contracted to sell insurance policies with the same carriers as us, and business partners that assist us with analytics, marketing, and advertising.
• With Law Enforcement, Government Agencies, or Parties to a Legal Proceeding. We may share Personal Information with such entities to comply with the law or assist in law enforcement.
• With Our Independent Agents and Advisors. Agents and advisors have access to Personal Information that is provided by you when you request information regarding insurance products.
• With Data Analytics Providers and Advertising Service Providers. Third-party data analytics providers may collect Personal Information about users over time and across different websites, applications, and devices for the purposes of targeted advertising. These providers may collect Personal Information, specifically internet or other similar network activity information, social media information, and/or commercial information in this manner on our Platform. For more information on these third parties, please see the below “Cookie Policy.”
  
  We partner with these third parties to tailor and customize our advertising to Users. The practice of targeted advertising may be considered a “sale” of Personal Information under some state laws. For more information about your choices related to this practice, please see “Rights Regarding Personal Information,” below.

COOKIE POLICY

CHILDREN UNDER THE AGE OF 16

The Platform is not intended for children under 16 years of age. We do not collect information about individuals under the age of 16. No one under age 16 may provide any information through the Platform. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information through the Platform. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.

YOUR PRIVACY RIGHTS

State consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Information as described in more detail below. However, these rights are not absolute, and, in certain cases, we may decline your request as permitted by law. 

 

Consumer Right Description Right to Know You may request the categories of Personal Information collected by Company about the data subject, the purpose and source of that collection, whether or not the Personal Information was sold to a third party, and the categories of third parties to whom Company disclosed the data subject’s Personal Information.

Right to Access. 

ou may request to access, inspect, and receive a copy of Personal InformationRight to Delete Personal InformationYou may request to delete non-exempt Personal Information held or stored by Company or on Company’s behalf. Some exceptions apply to these types of requests.Right to CorrectYou may request to edit or correct your Personal Information at any time.Right to Opt-outYou may request to opt-out of certain uses or disclosures of Personal Information, including selling or “sharing” (i.e., using Personal Information from non-Integrity websites for targeted advertising (“targeted advertising”)).Right to Request to AppealSome data subjects may have the right to request that Company reconsider a denial of a data subject request.

To appeal a decision regarding a consumer rights request, please fill out  this form and include “APPEAL” in your request details, along with a short description of your prior request and the outcome that you are seeking. We may request more information in order to locate your prior request.Right to Limit Use and DisclosureYou may request the right to limit our use and disclosure of your Personal Information defined as sensitive under the CCPA.Non-discriminationYou have the right to be free from discrimination related to your exercise of any of your privacy rights.To exercise any of these rights, please click here. Only you, or under some state privacy laws, someone legally authorized to act on your behalf, may make a request related to your Personal Information.

Exercising Your Privacy RightsProcessDescriptionVerification Use of Authorized AgentsYou may use an authorized agent to submit a data rights request. If you do so, the authorized agent must present signed written authorization to act on your behalf, and you will also be required to independently verify your own identity directly with us and confirm with us that you provided the authorized agent permission to submit the data rights request.

YOUR RIGHTS – CALIFORNIA

The following disclosures are made in compliance with the CCPA, as amended. In the past twelve (12) months, we have collected the Personal Information described above, and disclosed it to the third parties listed under the section “Sharing Personal Information” for the business purposes identified therein and under the section “Use of Personal Information.” This information falls into the following categories of Personal Information under the CCPA:

• Identifiers;
• Categories of Personal Information described in section 1798.80(e) of the California Civil Code;
• Characteristics of protected classifications under California or federal law;
• Commercial information;
• Geolocation information;
• Audio, electronic, or visual information;
• Internet or electronic network activity information;
• Professional or employment-related information; and
• Sensitive personal information identified by asterisk (*) in the above table.

Consumer RightDescriptionAccessYou may request that we provide the following information about how we have collected and used your Personal Information:

• The categories of Personal Information we have collected about you;
• The sources from which that Personal Information was collected;
• The business or commercial purpose for collecting, selling, and/or sharing your Personal Information;
• The categories of Personal Information we shared or sold about you;
• The categories of third parties to whom we shared or sold Personal Information about you;
• The categories of Personal Information we disclosed for a business purpose; and
• The categories of third parties to whom we disclosed Personal Information about you for a business purpose.

Request a Copy of Your Personal Information CorrectionYou may request to edit or correct your Personal Information at any time.DeletionYou may have the right, under certain circumstances, to request that we delete the Personal Information you have provided to us.Opt Out of Sales and/or SharingThe CCPA may classify our use of some services as “selling” or “sharing” your Personal Information with the partners that provide the services. You can opt out of the “selling” and/or “sharing” of your Personal Information.Limit Processing of Sensitive Personal InformationWe use sensitive Personal Information only as necessary for our (1) service delivery and operations, (2) compliance and protection, (3) quality control and improvements, or (4) Service improvement and analytics purposes in accordance with CCPA. If we use sensitive Personal Information outside the permitted purposes of CCPA, you have the right to limit such processing of sensitive Personal Information.

Exercising Your Privacy RightsProcessDescriptionVerification Use of Authorized AgentsYou may use an authorized agent to submit a rights request. If you do so, the authorized agent must present signed written authorization to act on your behalf, and you will also be required to independently verify your own identity directly with us and confirm with us that you provided the authorized agent permission to submit the rights request. This verification process is not necessary if your authorized agent provides documentation showing that the authorized agent has power of attorney to act on your behalf under Cal. Prob. Code §§ 4121 to 4130.

SALE AND SHARING OF PERSONAL INFORMATION

RETENTION OF DATA

We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we refer to these criteria in order to determine retention period:

• Whether we have a legal or contractual need to retain the data;
• Whether the data is necessary to provide our Platform; and
• Whether our Consumers or Agents would reasonably expect that we would retain the data until they remove it or until their accounts are closed or terminated.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and cease any further processing until deletion is possible.

DATA SECURITY

No security is foolproof, and the Internet is an insecure medium. We cannot guarantee absolute security, but we work hard to protect our Company and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information that we collect and store.

THIRD PARTY APPLICATIONS AND INTEGRATIONS

Our Platform uses third-party applications and integrations to enhance its experience. We disclaim any and all liability and responsibility for the use of these applications and integrations, and encourage you to review their individual privacy policies before using our Platform or otherwise engaging with us. We disclaim any and all liability and responsibility for the use of these applications and integrations and encourage you to review any individual privacy policy related to those applications and integrations.

UPDATES TO THIS PRIVACY POLICY

We may revise this Privacy Policy from time to time. If we make material changes to this Privacy Policy, we will notify you by email or by posting a notice on our Platform prior to or on the effective date of the changes. By continuing to access or use the Platform after those changes become effective, you acknowledge the revised Privacy Policy. We specify the date of the last changes at the beginning of the notice.

CONTACT INFORMATION

If you have any questions or comments about this notice, or the ways in which we collect and use your personal information, please do not hesitate to contact us at: