Last Modified: November, 2021
This policy includes specific disclosures for residents of California.
Persons with disabilities may obtain this notice in alternative format upon request by contacting us at firstname.lastname@example.org
CHILDREN UNDER THE AGE OF 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, please do not register on the Website, make any purchases through the Website or send any information about yourself to us, including your name, address, telephone number or e-mail address. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at email@example.com
NON-US AND CALIFORNIA USERS
Our Website and services are not intended for use by persons outside of the United States.
INFORMATION WE COLLECT ABOUT YOU
We collect several types of information from and about users of our Website, including:
- Information you provide to us (including through any insurance broker submitting an application for insurance on your behalf). This may include information you provide to a third-party website with whom PivotHealth has a commercial relationship that is transferred when you click through to PivotHealth after submitting information on such a third-party website.
- Information we collect as you navigate through the Website, including usage details, IP addresses, and other device and session information typically collected by cookies, web beacons and other tracking technologies as further described below.
- Information we receive from third parties, for example, our business partners, which include:
- Google Analytics Advertising demographics and interests are enabled, and we collect this information from Google on all traffic to PivotHealth.com.
- We use Google Analytics cookies to identify the demographics and interests of users of PivotHealth.com.
- You may opt-out of the Google Analytics Advertising Features at any time, including through Ads Settings. Opt-out of Google Analytics here.
INFORMATION YOU PROVIDE TO US
We may collect and use the following information that you provide to us:
- Information that you provide (including through any insurance broker submitting an application for insurance on your behalf) by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
- Records and copies of your correspondence (including e-mail addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes, although you do not have to respond to them.
- Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
If you submit an application for insurance through our Website, you may be asked certain questions and the responses to which may constitute “Protected Health Information”. For example, you may be asked questions regarding past or current medical conditions. Protected Health Information is further defined by the federal Health Insurance Portability and Accountability Act of 1996 (HIPAA) and is subject to the protections of HIPAA.
USAGE DETAILS, IP ADDRESSES AND COOKIES AND WEB BEACONS
- Session Cookies. As you navigate through the Website, we may collect details of your visits to our Website using session cookies or other similar tracking technologies, including web beacons. Information collected by session cookies includes, but is not limited to, traffic data, location data, logs and other communication data, the resources that you access on our Website, as well as information about your computer and internet connection, including your IP address, operating system and browser type. The following are illustrative examples of the purposes for which session cookies are used: for billing purposes, for system administration, to improve our Website and services and to report aggregate information to our advertisers. This is statistical data about our users’ equipment, browsing actions and patterns, and does not identify any individual, except to the extent such information is paired with personally identifying information.
- Permanent Cookies. For the same reason, we may obtain information about your general internet usage by using permanent cookies or other similar tracking technology. A permanent cookie is a small file stored on the hard drive of your computer until it is removed. Use of permanent cookies help us to improve our Website and to deliver a better and more personalized service by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
USES MADE OF THE INFORMATION
We use information that we collect about you or that you provide to us, including any personal information, in the following ways::
- To assist you in completing applications for insurance.
- To present our Website and its contents in a suitable and effective manner for you and for your computer.
- To provide you with information, products or services that you request from us.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- To notify you about changes to our service.
- To allow you to participate in interactive features of our service, when you choose to do so.
We may also use your information, or permit selected third parties to use your information, to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, or to provide your information to third parties for marketing purposes, please either (i) do not provide your personal information; or (ii) elect to opt out of further marketing communications by following the opt-out instructions in any marketing communications you do receive. We may also provide our advertisers with aggregated information about our users (for example, we may report to them that 500 men aged under 30 clicked on their advertisement on a given day). We may also use such aggregated information to help advertisers reach the kind of audience they want to target. We may make use of the personal information we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience. When you click on or otherwise interact with an advertisement there is a possibility that the advertiser may assume that you meet the target criteria they selected.
DISCLOSURE OF YOUR INFORMATION
We may disclose personal information that you provide via this Website to the following third parties:
- The insurance carrier (or an intermediary with which such carrier has a commercial relationship) whose products you are applying for.
- Third parties who may send you health insurance related marketing communications via email.
- Contractors and service providers we use to support our business where such persons have a legitimate operational need to know that information.
We may also disclose your personal information to third parties to:
- Comply with any court order or other legal obligation.
- A third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
- Protect the rights, property, or safety of PivotHealth, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
PRIVACY RIGHTS OF CALIFORNIA USERS
California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org.
California Consumer Privacy Act: The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to know/access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.
To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.
Right to Notice at Collection Regarding the Categories of Personal Information Collected
You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. This notice should be provided at or before the time of collection. The categories we use to describe the information are those enumerated in the CCPA.
- Personal Identifiers:
- We collect your name, phone number, email address, contact address and other identifiers when you provide that information to us. We use this information to provide the services, respond to your requests, and send information and advertisements to you.
- We collect medical information and health information that you provide, such as whether you use tobacco, are eligible for Medicaid, or qualify for medical subsidies. We use this information to provide targeted services and offers to you.
- We collect your IP address automatically when you use our Services. We use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities.
- We collect your device identifiers automatically when you use our Services. We use this information to monitor your use, and the effectiveness of, our Services, to identify you, and to provide you with targeted information and offers.
- We collect personal identifiers of your spouse and dependents when you provide that information to us, in order to provide you with targeted services and offers.
- Protected Classifications: We collect your age and gender in order to provide you with targeted services and offers, and to comply with laws that restrict collection of personal information from minors. We collect your language preferences to facilitate our communications with you. We do not collect your race, ethnic origin, disability, or sexual orientation.
- Commercial Information: We collect information regarding your household size and income, for the purpose of targeting services and offers to you. We also collect information regarding any qualifying life event that may apply to your eligibility for particular health care services and benefits.
- Biometric Information: We do not collect information about your physiological, biological, and behavioral characteristics to identify you.
- Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history, information regarding your interaction with websites, and applications or advertisements automatically when you utilize our Services. We use this information to gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities
- Geolocation Data: As described above, we collect your IP address and device identifiers automatically when you use our Services. We may be able to determine your general location based on the IP address.
- Audio, electronic, visual, thermal, olfactory, or similar information: If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call.
- Professional or employment-related information: We do not collect information about your employment or employment history.
- Education information: We do not collect information about the institutions you have attended and the level of education you have attained.
- Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We may analyze your actual or likely preferences through a series of computer processes. On some occasions, we may add our observations to your internal profile. We use this information to gauge and develop our marketing activities, measure the appeal and effectiveness of our Services, applications, and tools, and to provide you with targeted information, advertisements, and offers.
We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.
We also sell some information to third parties. To opt out of the sale of your information visit our Do Not Sell My Information page or submit an inquiry at our contact form
Right to Know About Personal Information Collected, Disclosed, or Sold.
You have the right to request that we disclose to you the Personal Information we collect, use, disclose, or sell. In order to process your request to know/access your Personal Information or delete your Personal Information we may ask you to take additional steps to verify your request or identity. Verification Procedures
In order to process your request to know about or delete personal information we collect, disclose, or sell, we must verify your request. We do this by:
- Providing personal identifiers we can match against information we may have collected from you previously; and
- Asking you to confirm your request using the email or telephone account stated in the request.
If you have authorized someone else to make requests on your behalf, we require that you provide notarized statements confirming the identity and authority of that person.
Right to Know/Access Information
You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request.
Right to Request Deletion of Information
You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Right to Information Regarding Participation in Data Sharing for Financial Incentives
You have the right to be free from discrimination based on your exercise of your CCPA rights. For example: We may run promotions from time to time whereby we incentivize a consumer to share certain pieces of information with us; for example, we may offer a one-time discount if consumers sign up for our email marketing list. Participation in these incentives is voluntary, and you may opt out of the data sharing at any time.
Right to Opt Out of Sale of Personal Information to Third Parties
We sell information we collect to our Network Partners and other third parties, in order to provide you with targeted services and offers. A company may be considered a third party either because the purpose of sharing is not an enumerated business purpose under California law, or because our contract does not restrict them from using Personal Information for other purposes.
You have the right to opt out of any sale of your personal information to third parties. To exercise this right, please submit a request by emailing email@example.com.
Please note that your right to opt out does not apply to our sharing of personal information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal information only for that function.
How to Submit a Request Under the CCPA
You may submit a request to exercise your rights by sending an email to firstname.lastname@example.org. You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you and the individual complete notarized affidavits in order to verify the identity of the authorized agent and confirm that you have authorized them to act on your behalf. Parents of minor children may submit a birth certificate of the child in lieu of an affidavit, in order to make requests on the child’s behalf. Please contact us at email@example.com for our required forms of affidavits.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. The information you share in public areas may be viewed by any user of the Website. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk.