Last Updated and Effective: January 1, 2020
Table of Contents:
-Personal Information We Collect and How
-How We Use Personal Information
-How We Share Personal Information
-“Do Not Track;” Other Tracking
-Notice to Non-U.S. Residents
-Notice to California Residents
-Notice to Nevada Residents
We generally collect Personal Information in two ways: 1) information you provide to us, and 2) information we collect automatically, as described further below.
We collect your name, email address, phone number, state and zip code when you request a quote through the Site or use the “Contact” feature on the Site for purposes of obtaining insurance coverage. We may collect some or all of the same information if you speak to or otherwise interact with (e.g., by email or text) with one of our customer service representatives. In order to match you with available insurance options, we may further collect your full address, birth date, social security number, Medicare/Medicaid coverage status, and names of your dependents. We do not collect payment card or bank account information; any payments for insurance are made directly to the insurance carrier. It is not necessary to disclose personal medical information to seek insurance coverage and we do not intend to collect or retain any such information that you may bring to our attention.
We may also obtain personal information about you from third parties, including, service providers and lead sellers. This information may include name, address/location (state and/or zip code), email address, phone number, gender, birth date, Medicare/Medicaid coverage status, IP address, and/or lead identification number.
Whenever you interact with the Site, we, as well as our service providers, may use assorted technologies, such as cookies and other technologies, that automatically or passively collect data about how the Site is being accessed and used. This data may include browser type, unique number assigned to identify the device, operating system, application version used to access the Site, click path taken through the Site, your use of features or applications within the Site, and other usage information (“Use Data”). This information helps us manage, improve and customize our Services, including the Site’s features and functionality, and may be used to identify you like personal information.
HOW WE USE PERSONAL INFORMATION.
We may use your Personal Information for one or more of the following purposes:
-provide you with insurance coverage options and sell you insurance coverage;
-provide you with Services and customer support; deliver service update notices and promotional offers, answer questions and respond to your requests, and otherwise to communicate with you;
-determine your location and the location of insurers, and correlate your location with available coverage for the purpose of providing you with insurance coverage options and Services;
-maintain the security and integrity of the Services, our technology, assets, data and business; engage in detection and prevention of fraud or other illegal activities and debugging;
-enforce our website Terms, including to prevent potential breaches;
-respond to law enforcement requests and as required by applicable law, court order, or governmental regulations, or comply with subpoena, court order, legal process or obligations;
-test, personalize, develop and improve the Services;
-advertise and market our products and services, and the products and services of our marketing partners, to you, including by presenting tailored content and advertisements through our Site, third-party sites, email or text message (with your consent, where required by law);
-detect or prevent security incidents or other illegal activity; for debugging and fraud prevention;
-use the information as reasonably necessary and proportionate to achieve our operational or notified purpose for collecting personal information and as compatible with the context in which it was collected; and
-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 users, online visitors, business contacts or employees is among the assets transferred.
HOW WE SHARE PERSONAL INFORMATION.
We share personal information with third parties, as follows:
-Insurance Industry. We may disclose your personal information to third parties to assist with our fulfilling your requests to us to obtain insurance coverage or quotes for insurance coverage, including to insurance carriers, call centers and marketing partners.
-Other Parties. As further described in the “HOW WE USE PERSONAL INFORMATION” section above, we may share your information when we have reason to believe that disclosing the information is necessary to prevent fraud, damage to person or property, investigate, protect and secure our business, assets, user accounts or enforce legal rights or comply with subpoena, court order, legal process or obligations. We reserve the right to disclose any personal information as needed if that information is requested by law enforcement agencies or if we are required to do so by law or court order.
-Successor Entities. We reserve the right to sell, disclose or transfer your Personal Information to a successor entity in the event of a corporate merger, consolidation, sale of assets or other corporate changes respecting ASP.
“DO NOT TRACK”; OTHER TRACKING.
We do not honor “do not track” requests for the Site sent from a browser, but third parties (other than our service providers assisting with making the Services available) do not have authorization from us to track your use of the Services or track what other activities a user may have engaged in before or after using the Services (for example, using a different website).
SECURITY. We use reasonable administrative, technical, and physical security measures to protect personal information against loss, misuse, and unauthorized access, but no online or mobile communication is guaranteed to be 100% secure.
THIRD-PARTY LINKS. The Site and Services may make available links to the websites of our marketing partners, advertisers, social media sites, and other third parties. If you follow a link to any of these websites, please note that these third parties have their own privacy policies, and that ASPdoes not accept any responsibility or liability for such third party privacy policies or practices. Please check the individual policies before you submit any information to or through any linked third party website.
YOUR PREFERENCES. You can update your preferences regarding how we contact you. If you receive a text message from us to coordinate follow-up, you may always text STOP to opt out. If you receive emails with products or offers that may be of interest to you, you may opt out of marketing communications by unsubscribing within the email. Please note that you may continue to receive emails with information about requested insurance coverage, even if you opt-out of marketing emails. Feel free to contact us with any other requests or preferences, including to update or change your personal information. See “CONTACT US” below.
California residents exercising their rights described under the NOTICE TO CALIFORNIA RESIDENTS section below may call us at 888-271-3092 or access our web form here or contact us through the “Contact” link on www.americanselecthealth.com.
California and Nevada residents who wish to opt out of the sale of their personal information may use the DO NOT SELL MY INFO button on www.americanselecthealth.com to submit the request, but please be aware that doing so may limit the insurance coverage options we may be able to present for your consideration.
A number of states are currently considering enacting laws similar to the California laws under “NOTICE TO CALIFORNIA RESIDENTS” below. If you are a resident of a state that enacts such a law, please use the contact information above to contact us with any questions, requests or comments.
CHILDREN. The Site and Services are not intended for use by children, and we do not knowingly collect personal information from children under 13 directly from such children. If we learn that we have collected the personal information of any such individual without having been provided the information from their parent or legal guardian as part of the process of obtaining insurance coverage for dependents, we will take steps to delete the information as soon as possible.
Collection and Use of Personal Information
-See chart immediately below for categories of personal information collected
-See “PERSONAL INFORMATION WE COLLECT AND HOW” for sources from which, or how, the personal information was collected (i.e., directly from you or from our service providers)
-See “HOW WE USE PERSONAL INFORMATION” for our business or commercial purposes for collecting personal information
-See “HOW WE SHARE PERSONAL INFORMATION” for third parties with whom we share personal information
In particular, as part of the Services, we have collected the following categories of personal information from California residents within the last twelve (12) months:
Category Examples Collected
1. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YES
3. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES
4. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
5. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
6. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
7. Geolocation data. Physical location or movements. YES
8. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
9. Professional or employment-related information. Current or past job history or performance evaluations. YES
10. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
11. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Your CCPA Rights and How to Exercise Them
If you are a California resident, you have certain rights, pursuant to the California Consumer Privacy Protection Act (“CCPA”). These CCPA rights may only apply in certain circumstances and are subject to certain exemptions. Please see the information below for a summary of your rights, how to exercise your rights and the information we require in order to respond to your requests. Please note that we may ask for certain information to verify the request in accordance with applicable law.
-Right to Know. You have the right to request that we disclose what personal information we collect, use, disclose and/or sell about you. To exercise your right to know, please refer to the CONTACT US section above to submit your request. You will be required to provide certain information which we will use to verify your request.
-Right to Delete. You have the right to delete personal information that we collect or maintain about you. To request deletion of your information, please refer to the CONTACT US section above to submit your request. You will be required to provide certain information which we will use to verify your request. Please note that certain exceptions apply to this right, such as when we must retain your information to comply with law. We will notify you of any such exceptions as applicable to your request.
-Right to Opt-Out of Sale. You have the right to opt-out or ask us not to sell your personal information. To exercise this right, click the DO NOT SELL MY INFO button below to open the web form or use the link located on the home page of our Site or other options available under CONTACT US above.
[DO NOT SELL MY INFO]
You are welcome to change your mind and opt back in at any time. We may not request that you change your mind for at least 12 months after you opt-out.
-Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of any of your CCPA rights. However, we may offer certain financial incentives, charge reasonable fees related to your requests, or deny your right to know, right to request deletion, or right to opt-out of sale in accordance with applicable law.
-Right to an Authorized Agent. You can exercise your CCPA rights yourself or you can designate an authorized agent to make a request on your behalf. Your authorized agent must be able to demonstrate authority to act on your behalf as further instructed when submitting a verifiable request.
Disclosure or Sale of Personal Information
Under the CCPA, a “sale” means providing to a third party personal information for valuable consideration. It does not necessarily mean money was exchanged for the transfer of personal information. In the last 12 months, we disclosed or sold personal information to third parties as follows:
-ASP is required to tell California residents that in the past 12 months, we sold the categories of Personal Information shown in the chart above in this “NOTICE TO CALIFORNIA RESIDENTS” section when we shared it with our service providers because of how broadly “sell” is defined under the CCPA.
-The same categories of Personal Information were also disclosed to our service providers for the business or commercial purposes described in “HOW WE USE PERSONAL INFORMATION” above.
-ASP sold personal information (limited to name, address or location (zip code and/or county), email address, IP address, gender, data of birth, Medicare/Medicaid coverage status, and/or lead identification number) to our marketing partners to be able to offer insurance coverage options. If you would like to have your information removed from such lists, please click the DO NOT SELL MY INFO button indicated above.
-We do not knowingly collect the personal information of minors under age 16 from such minors and do not sell such information. Insurance products are directed to the adult/legal guardian as the covered individual, who may name their dependents in the course of seeking coverage.
Third-Party Marketing Disclosure
Under California Civil Code Section 1798.83 (The “Shine the Light” law), California residents with whom we have a business relationship can request certain information regarding what types of personal information, if any, we shared with third parties for the direct marketing purposes of the third parties and the identities of the third parties with whom we shared such information in the immediately preceding 12 months. You may request this information by referring to the CONTACT US section above.
NOTICE TO NEVADA RESIDENTS. Please refer to the “NOTICE FOR CALIFORNIA RESIDENTS” section above for the categories of personal information we collect, including information about online activities, and with whom we share it. Please use the CONTACT US section above to opt out of the sale of your personal information if desired, or otherwise contact us regarding your personal information.