Employer Healthcare & Benefits Congress (Free Health Inc), inclusive of its affiliates and/or subsidiaries (collectively, “EHBC”), is committed to protecting the privacy of its clients’ and client customers’ non-public personal information (“NPPI”). Keeping that information secure and ensuring an understanding of how we collect, use and maintain such information is important to us.
We have implemented privacy policies consistent with applicable law and regulatory requirements, and as may be required by the business operations of our clients. We have also adopted policies and procedures specifically designed to safeguard the security and confidentiality of our clients’ and client customers’ records and NPPI. These policies and procedures are recurrently evolving, consistent with applicable law and regulatory compliance necessities.
This Privacy Statement provides basic information relating to the types of non-public personal information EHBC collects; how we use the NPPI we collect; how and under what circumstances we may disclose that information; as well as how we safeguard it. From time to time, we will update this Privacy Statement to reflect changes in our policies, procedures and practices. If you are a EHBC client or customer, you will receive notification of any significant changes, as required by law.
Our Collection of Non-Public Personal Information
In order to accurately and safely provide the many services EHBC offers, we may obtain and maintain certain of your non-public personal information. We collect NPPI about you from the following sources:
- Information we receive from you on applications or other forms;
- Information about your transactions with our clients, our client customers or others; and
- Information we may receive from consumer reporting agencies (“credit bureaus”), information clearing houses and/or governmental agencies.
Examples of information that we may ask you to provide may include (but not necessarily be limited to) the following:
- Date of Birth
- Mailing Address
- Social Security Number
- E-Mail address
- Employment Information
To help the government fight identity theft, the funding of terrorism and money laundering activities, EHBC may obtain, verify, and record information that identifies each person and/or entity with whom the company conducts business, as deemed necessary and appropriate. EHBC may ask for names, social security numbers, addresses, dates of birth and other important information that will allow us to properly identify with whom we are transacting business. During this process, EHBC may also ask that a copy of your driver's license or other identifying documentation be provided.
We may ask for additional information so that we may confirm an identity. This additional personal information may be necessary to prevent fraud, and to ensure that only the proper person(s) have access to your personal information. It is your responsibility to provide us with truthful and accurate non-public personal information, and it is not the responsibility of EHBC or its clients to rectify any loss or damage that occurs if you fail to do so. It is also your responsibility to immediately notify EHBC if someone else has obtained unauthorized access to your NPPI, or has stolen a relevant username or password. EHBC may deny access to its products and/or services if any identity is or becomes suspect.
Collection and Use of Anonymous Data
Visitors can log on to the EHBC websites to learn about our companies, our products and services, and find out how to contact us without providing any non-public personal information. EHBC reserves the right to collect anonymous information when users access our websites. The types of information that is gathered may include, but is not limited to: the date, time of day, which web pages are visited, and how much time is spent on the websites. We only collect and use such information about our users in the aggregate. The general information we collect enables EHBC to serve our clients and client customers better, by continually improving our site(s) based upon usage patterns.
Credit Bureau Reports
EHBC may utilize credit bureau reports in order to evaluate “credit worthiness” and to protect all parties concerned from fraudulent activities. Therefore, with your specific knowledge and permission, we may obtain a credit bureau report about you when you seek to procure any financial products and/or services through EHBC or from our clients.
Sharing of Non-Public Personal Information
EHBC does not disclose non-public personal information about our clients or client customers (or our former client or client customers) to anyone, except as permitted by law or as otherwise disclosed in this Statement.
In order to provide you with access to a full range of EHBC services, we may share certain of your NPPI, including information about our transactions and experiences with you, with our affiliates. An “affiliate” means any company that controls, is controlled by, or is under common control within EHBC.
We may disclose all of your NPPI to unaffiliated third parties who perform services for us, and/or to unaffiliated third parties who perform services related to products and services that you already have or request from us. EHBC contractually requires that all such third parties maintain the confidentiality of any such non-public personal information.
EHBC will disclose NPPI to non-affiliated third parties in response to a court order, or any other lawful request by a governmental or regulatory agency, to protect against the misuse or unauthorized use of our web site(s), and/or as EHBC, in its sole discretion, believes necessary or appropriate to defend our interests and protect our business assets; to limit our legal liability; to enforce our rights and agreements; to comply with our legal and regulatory obligations; or as otherwise permitted or required by law.
In addition, we may transfer your non-public personal information in the event of a change of control of one or more of our companies, or a transfer of the business assets to which specific non-public personal information relates.
EHBC is not responsible for the privacy practices of any third parties or their web sites which may differ from this Privacy Statement. We encourage all interested persons to thoroughly review the Privacy Statement of each and every website that collects information from you, in order to be informed of their privacy and security practices.
Security and Safeguarding of Non-Public Personal Information
EHBC restricts access to your non-public personal information to only those authorized and trained employees and agents who have a need to know such information in order to provide products or services to our clients and/or client customers. We continually maintain and monitor physical, electronic and procedural safeguards that comply with applicable law and regulatory compliance requirements in order to safely guard all non-public personal information in our possession.
Other steps you may choose to take to enhance your security whenever you are online include the following non-exclusive steps:
- Use an internet firewall (hardware or software).
- Use current software and operating system versions; get updates and security patches regularly.
- Use anti-virus software and download updates frequently.
- Use only your own personal computer.
- Choose a hard-to-guess password, and change it regularly.
- Use a unique Username/Password (not one that you use on other websites).
- Use strong 128-bit encryption available in the latest version of your browser.
- When finished, log-off the website and close your browser.
- For additional security, clear your browser’s cache and temporary internet files.
EHBC cares about the safety and security of your non-public personal information, and offers these suggestions with your best interests and protection in mind. This Privacy Statement is not intended to dispense legal advice, and nothing herein should be construed as such. All information set forth within this EHBC Privacy Statement is subject to change without notification.
If you should have any questions about this Privacy Statement, please contact Employer Healthcare Benefits Council at 888-714-4947, or you may submit a written request to: [email protected].