healthsubsidyplan is here to protect and improve the personal and financial health of all consumers.

When you use, access or interact with our services, you are agreeing to our Terms of Service and also consenting to our information practices disclosed and hyperlinked herein.

Definitions

“healthsubsidyplan” or “us” or “our” or “we” refers to healthsubsidyplan.com and its affiliates, and not to our parent company or any of its other subsidiaries.

“California Resident Privacy Disclosure” or “Disclosure” refers to the combination of California Privacy Policy and California Privacy Notice at Collection.

“Information practices” refers to the collection, use, disclosure, sale, share, and retention of personal information.

“Personal Information” or “information” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or device.

“You” and “your” means the California resident using our Websites and Services.

Other terms throughout this Disclosure, such as “share”, “sell”, and “sensitive personal information”, are referenced according to their definitions under the California Privacy Rights Act of 2020.

Scope

This Disclosure covers the online and offline information practices and your choices in connection with the California Consumer Privacy Act of 2018 as amended under the October 2022 draft revisions of California Privacy Rights Act of 2020 (referred to as “CPRA”).

Certain information is subject to certain state and federal privacy laws, like the Gramm-Leach-Bliley Act (“GLBA”), California Financial Information Privacy Act, the Health Insurance Portability and Accountability Act (“HIPAA”). That information is not subject to CPRA and therefore, this Disclosure does not apply to information practices subject to such laws. For example, information practices in connection with requesting or obtaining our financial products and services for personal, family, or household purposes, or for long-term care, or individual health products.

This Disclosure does not include deidentified or aggregate consumer information (such as demographic-level data or data that can no longer be tied to a single identifiable individual), or information that is publicly available (such as information from public records).

Regulations

Our U.S. Consumer Privacy Notice applies to our information practices in connection with seeking, applying, or obtaining a financial product or service pursuant to Gramm-Leach-Bliley Act (GLBA). Please review the U.S. Consumer Privacy Notice.

Our Privacy Policy applies to our information practices in connection with our Services. Please review the Privacy Policy.

External Parties

This Disclosure does not cover the privacy practices of third parties or service providers that we do not own or control, nor of our parent company or its other subsidiaries. Certain Services affiliates may contain different privacy statements, which supplement this Policy.

We are not responsible for the information practices of third parties, including any third party operating a website or service to which our Services link. The inclusion of a link to a third-party feature does not imply endorsement of the linked website or service by us or by our affiliates. When you leave our Services or interact with a third-party feature, you should also read the applicable party’s privacy policies and Terms of Service to make sure you understand their information practices.

In addition, we are not responsible for the information practices of other organizations, such as Facebook, Apple, Google, Microsoft, Bing, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose directly to other organizations or which you enable to be disclosed to other organizations as a result of your device or browser preferences through or in connection with your use of the Apps or social media pages.

Our Information Practices Regarding Personal Information

The specific Personal Information that we collect, use, disclose, sell, share, or retain about you will depend on your relationship and interactions with us.

Information Collection

Depending on your relationship with us, there are three primary ways we may collect information about you:

• 1. When you provide it to us. You may provide us information in various ways such as through online forms, over the phone, or other means offered through our Service like applications and interactions with our Website.
• 2. Through automated technologies. This includes information from your device or computer regarding how you access and interact with our Services. This is a critical part of how we improve your experience on our Websites and, more importantly, provide you with more personalized insights and recommendations, which is the core of what we aim to do at Assurance.
• 3. Through external parties. We may collect information about you from third-parties and other sources such as contracted parties, government data sources, and public data sources. This includes insurance companies, data brokers, companies that provide or sell lists of potential purchasers, other contracted service providers, government data sources, and public data sources, or an authorized proxy. This also includes when you provide a third-party information and consent to share that information with us to help generate a personalized quote for you.

The list below outlines the information we may have collected in the past 12 months. We do not necessarily collect all information listed in a particular category, nor do we collect all categories of information for all individuals.

The categories of Personal Information collected include:

• 1. Personal Identifiers such as name, address, email address, online identifiers, IP address, and Social Security number;
• 2. Personal Data , such as contact information, health and financial information;
• 3. Protected Class Information under California or federal law, such as age, sex, marital status, veteran or military status;
• 4. Commercial/Transaction information such as transaction and account information;
• 5. Internet or other Electronic Network Activity information such as browsing history, interactions with our Websites, and click and mouse movements;
• 6. Geolocation Information such as device location;
• 7. Audio, Video, Electronic or Similar Information such as audio and electronic recording;
• 8. Professional/Employment Information such as title, work history, prior employer, and other information necessary for verifying employment eligibility;
• 9. Education Information such as school, degrees earned, and graduation data;
• 10. Inferences drawn from other Personal Information to create a profile/summary about, an individual’s preferences and characteristics; and
• 11. Sensitive Personal information, which is personal information that reveals certain personal identifiers such as:
• 1. social security, driver's license;
• 2. account log-in or financial information in combination with password, security code, or similar credentials;
• 3. race, ethnic origin; and
• 4. information collected and analyzed concerning one’s health.

Information Use

Most of our information practices are in the context of providing financial products and services that are not subject to the CPRA. Some of our information practices are subject to CPRA such as marketing, advertising, and certain improvements to your experience and our Services.

We may use Personal Information relating to California Residents for one or more of the following business and commercial purposes:

• To provide personalized Services to you. We use the information we collect to provide Services to you in a personalized way including offering a quote, processing transactions, maintaining and servicing your account or policy, and providing customer service. We also may collect information in our capacity as a service provider on behalf of financial service providers (e.g., insurance carriers, financial institutions). Many of the products we offer are complex, and consumers look to us to guide them to find the one that best fits their needs and goals. The information we collect gives us a more detailed picture of who you are so we can help you find the right product.
• To improve and debug our Services. We are constantly trying to improve our Services. The information we collect may be used to conduct internal research and analysis including data analytics, modeling, and recommendation Services. The information we collect also helps us improve the experience we provide to consumers, the intended functionality of our Services, and the way we match consumers to product recommendations in real time. For example, in some instances, we may use information you have provided, even if you have not completed the web flow, so that if you return to the Website this information will be pre-loaded for your convenience.
• To detect, investigate, and prevent fraud, misuse, or malicious activities. We respect your privacy and safety and therefore may use the information we collect to detect, investigate, prevent, or take action regarding incidents, threats, and misuse of your natural persons, your information, or our systems. This includes suspected theft, fraud, malicious, deceptive or illegal activities, or violations of our policies. As a result, we may also use the information we collect to verify your identity.
• To communicate with you and advertise to you. Part of providing personalized service is quickly connecting you with real people who can help walk you through your Service options, communicating to you about potential topics of interest, marketing and advertising to you, and responding to your requests and inquiries. For example, if you provide your phone number and email and then consent to being contacted by us, we may call you to connect you with one of our licensed insurance agents. We may also text and email you information about how to contact us, personalized marketing messages, information about your shopping journey, offers, and other information pertinent to your financial services inquiry.
• As required by governing law and for legal reasons. We operate in a regulated industry and therefore reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, information related to your use of our Services as reasonably necessary to do any of the following: comply with applicable law; respond to complaints, legal actions or governmental requests; enforce our Terms of Service; protect our rights, privacy, safety, or property; or respond to other similar matters. We may also use third-party services to record your actions on our Websites to help meet our compliance and legal obligations.
• As part of a corporate change. We may use, disclose, and transfer information about you to a third party as part of, or in preparation for, a change of control, restructuring, corporate change, or sale or transfer of assets.

healthsubsidyplan does not knowingly use, share, or disclose Sensitive Personal Information as defined in CPRA for purposes other than those permitted under CPRA.

Information Sale, Share, and Disclosure

We work with a number of partners to deliver financial products and services and therefore share information with those partners.

The following list represents: (i) who we may sell, share for cross-context behavioral advertising, or disclose with; and (ii) the purposes in connection with your use of our Services:

• Disclose information with our business and financial service partners to provide and improve our personalized Services. This includes business partners such as software and internet service providers, communication services, data brokers, data analytic providers, marketing companies, fraud prevention services; and financial service partners such as insurance carriers and agencies, financial service providers, and payment processors.
• Disclose information with third-party service providers acting on our behalf. This includes, insurance agencies, Agents and financial professionals, legal and compliance service providers, and process outsourcing companies.
• Sell or Share information with advertising networks, social media networks, and marketing affiliates. We sell and share your information with these parties to communicate to you about our Services, including joint marketing, behavioral advertising, and search engine optimization. In most cases this information is de-identified or aggregated to protect the personal information of our consumers. We also share information with these parties to communicate your consents and preferences.
• Sell information to third-party partners, with your permission, to provide you or communicate to you about their products and services. Although we aim to directly meet all our consumers’ needs, we also—with your permission—may sell and share, information you provide us, to select third parties, to market their financial products and services, and to select insurers, financial institutions, and their Agents who may make insurance, credit, and other offers. These third parties, or the entities they work with, may contact you based on the consent you have provided. We also share information with these parties to communicate your consents and preferences.
• Disclose information to a third party as part of a Corporate Change. We may disclose and transfer information about you to a third party such as our parent company, or its partners as part of, or in preparation for, a change of control, restructuring, corporate change, or sale or transfer of assets.
• Disclose information to a third-party for legal reasons. We reserve the right to transfer or disclose information about you to third parties for certain legal purposes as described above.

The table below outlines the categories of Personal Information related to sale, share, and disclosure practices in the past 12 months that may be subject to CPRA.

Information Retention

We retain personal information in compliance with our records retention policies and for as long as needed based on the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

• Length of time we have an ongoing relationship with you and provide you with the products and services requests;
• Whether there is a legal obligation we are subject to
• If there is a contractual obligation we are subject to; and
• Whether retention is advisable in light of our legal position.

Your Consumer Rights

California residents interacting with us have certain consumer rights. These rights are limited to the personal information subject to CPRA and do not apply with respect to information that we collect about you in connection with providing financial products or services for personal, family, or household purposes or for long-term care or individual health products. That information is governed under certain state and federal laws defined in the Scope section of this Disclosure.

Nonetheless, you have the right to be free from unlawful discrimination or retaliation for exercising your rights under CPRA.

Right to Know & Right to Delete

Request to Know:

You may request to know what personal information we have collected since January 1, 2022, that is subject to CPRA. This includes the:

categories of personal information;

• the categories of sources from which the personal information was collected;
• the business or commercial purpose for collecting, selling, or sharing personal information;
• the categories of third parties to whom we disclosed personal information; and
• the specific pieces of certain personal information we have collected.

Please note that to protect the privacy of our consumers, we will never disclose specific pieces of Sensitive Personal Information (as defined above in the Categories of Personal Information collected).

Request to Delete

: You may request that we delete personal information we have collected that is subject to CPRA.

You can submit either of these requests through the following:

• Contact us at: [email protected]

Once you submit your request, we will review the information you submitted in the Form in comparison to the information we have in our systems to verify your identity and relationship with us.

In some cases, we may contact you to request additional information to verify the request, or to notify you that it will take more than 45 days to respond. In that case, we will respond within 90 days of receiving your request.

Right to Correct Inaccurate Information

You may request that we correct inaccurate information maintained about you. We support this for all consumers, not just California residents.

You can submit this request through the following:

California residents may contact us at: [email protected]

All other consumers may contact us at: [email protected]

Once you submit your request, we will review and verify your identity, relationship with us, and the accuracy of the information submitted for the change. We may deny a request to correct if we determine that the contested Personal Information is more likely than not accurate based on the totality of the circumstances

Right to Opt-out of Sale and Sharing

You may request that we no longer sell or share for cross-contextual behavioral advertising (data sharing that exists to provide more targeted advertising across websites and over time).

You can submit this request through the following:

• Contact us at: [email protected]

Set your browser or device settings to send an opt-out preference signal known as the Global Privacy Control (“Global Privacy Signal”). To learn more about the GPC and download browsers and extensions that will notify us of your privacy preferences, visit: https://globalprivacycontrol.org/

When processing a Global Privacy Signal, we honor the request with respect to the information collected on that device during your session. As a result, we may not be able to tie a browser or device-based preference signal request to all Personal Information we have about you.

We will not call or email you for authentication or verification related to this request.

Requests by Authorized Agents

A California resident may authorize an agent to make a CPRA rights request on behalf of the California resident. A California resident’s authorized agent may make a request on behalf of the California resident by contacting us at:

Contact us at: [email protected]

In general, if an authorized agent makes a request on behalf of a California resident, we may:

• 1. verify that the authorized agent is registered with the California Secretary of State to conduct business in California;
• 2. require that the California resident provide the authorized agent with written permission signed by the California resident authorizing the agent to make the request on the individual’s behalf (“Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.);
• 3. verify the identity of the California resident as we would if the California resident were making the request directly; or
• 4. obtain verification from the California resident that the individual gave the authorized agent permission to make the request.

Limiting or Declining Requests

We may decline to honor your request, in full or part, for certain reasons such as:

• the information is subject to certain state and federal laws outside the scope of the CPRA rights requests such as GLBA or HIPAA;
• we cannot identify you within our systems;
• we cannot confirm that the Personal Information that we maintain relates to you;
• we cannot verify your identity or verify that you have the authority to make a request on behalf of another individual (this is specific to access, deletion, and correction requests);
• we are required to retain the information under record retention requirements or compliance with other legal obligations; and
• disclosure of personal information would adversely affect the rights and freedoms of another consumer.

Changes to this Disclosure

This Disclosure is effective as of July 2023. We reserve the right to change this Disclosure at any time. We will note when it was last updated. Any changes will be effective as of the day they are posted. Use of our Services following these changes signifies acceptance.

Contact Us

We appreciate you taking the time to read this. If you have questions regarding this disclosure or information practices, you can email us at [email protected].