Effective January 2020
Strategic Enrollment Services (including our affiliates and subsidiaries) (“we”, “us” or “our”) respects your privacy and takes our privacy responsibility very seriously and is committed to protecting it in a manner consistent with applicable law and this statement.
This Policy and notice applies to your Personal Information that we may collect, use, receive, and disclose and describes our practices for collecting, using, maintaining, protecting and disclosing that information in the course of providing our services.
2. Personal Information We Collect
“Personal Information” is information that identifies you as an individual or relates to you, an identifiable individual.
The Personal Information we may collect about you from our clients (or receive directly from you) will depend on the type of service we have been engaged to provide. The following provides a general overview of the categories of Personal Information we may collect. Such Personal Information include, but are is not limited to:
- Name, contact information, and other identifiers (real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number, or other similar identifiers);
- Personal identification documentation (Social Security Number, driver’s license number, passport number, employee identification numbers, insurance policy number, bank account number, etc.);
- Assets and income, occupation and employment status, dependent information and other relevant financial information;
- Information related to the provision of services to you, such as policy information, claims information, and information relating to any of your past claims and related losses;
- Information relating to your account activity and premium payment history;
- Information from reporting agencies and state and federal government agencies, such as state motor vehicle departments;
- Information from other sources, such as medical or health care providers and other third parties with which you or we maintain a relationship;
- Statements made by or about you;
- Records of communications; and
- Usage data (internet or other electronic network activity information including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with our websites, or with the Internet, application, or advertisement, including information obtained through the use of internet “cookies”.
Some of the categories of Personal Information that we may collect are special categories of information protected by federal law including your health records (such as your medical history and reports on medical diagnoses, injuries, and treatment) and information about your personal characteristics and circumstances of a sensitive nature such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.
3. How We Collect Personal Information
We generally collect your Personal Information only to the extent that is required for us to perform services on your behalf. In performing such services we collect, use and disclose your Personal Information in a variety of ways. The Personal Information we collect about you or from our clients (or directly from you) will depend on the type of service we are providing and the nature of the service.
We may collect your Personal Information in a variety of ways, including:
- By you directly within insurance applications or in connection with other communications;
- From public sources;
- We may receive Personal Information from third parties, including insurance carriers and other industry service providers, and other third parties with which you maintain a relationship (i.e., your employer, financial service, or medical or health providers);
- Through our websites and use of tracking technologies; and
4. Purpose for Collecting Your Personal Information
We collect your Personal Information for everyday business purposes in order to perform services on your behalf. We would generally be unable to perform our services on your behalf without collecting, using or disclosing such Personal Information.
5. Use and Disclosure of Your Personal Information
We use the Personal Information that we collect about you to perform services on your behalf and to provide you with the insurance products and services you expect from us.
From time to time, we may share your Personal Information. We share such information for the following reasons:
- To fulfill any purpose for which you provided your Personal Information;
- To fulfill our everyday business purposes;
- To present our website and its contents to you;
- For legal responses;
- For any other purpose with your consent; and
- For other purposes as may be permitted by law.
We may disclose aggregated information that does not identify any individual, without restriction.
We may disclose Personal Information that we collect, or that you provided as described in this Policy for the following reasons:
- To our subsidiaries and affiliates;
- To a buyer or other successor in the event of 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 website users is among the assets transferred;
- To third parties to market their products or services to you if you have consented to these disclosures (for example, for an insurance quote);
- For any other purpose disclosed by us when you provide the information;
- With your consent.
We may also disclose your Personal Information for the following reasons:
To comply with any court order, law or legal process, including to respond to any government or regulatory request;
- To comply with any court order, law or legal process, including to respond to any government or regulatory request;
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Strategic Enrollment Services, our customers or others.
We do not sell your personal information to third parties, other than in connection with a merger, sale, or other transfer of organizational assets where Personal Information held by us about our clients is among the assets transferred.
6. Data Security and Retention
We have implemented measures reasonably designed to protect and secure your Personal Information from accidental loss, misuse, and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the Internet is not completely secure, and although we do our best to safeguard such Personal Information using reasonably designed measures, the security of information cannot be guaranteed. Please immediately notify us using the contact details provided below if you have reason to believe that your Personal Information maintained by us is no longer secure.