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PRIVACY POLICY

Effective June 30, 2018

 Introduction

This Privacy Policy explains how the PlanSurity family of companies, including PlanSurity Dental Designs, LLC and PlanSurity Directories, LLC (collectively, “PlanSurity”) collects, uses, shares and safeguards Personal Data and Non-Personal Data on the www.plansurity.com website, the website’s portals and any other digital services and platforms officially operated or used by PlanSurity from time to time (the “Site”), as well as by phone or by paper.  Except as explained under the heading “Exclusions” below, this Privacy Policy applies to all Users and data collected, processed, analyzed, stored or transmitted via the Site or any of its portals.  

Our Site and its portals are designed to make it easier for users of our Site (“Users” or “you”) to learn about us and about our services and programs and, in certain cases, to use our services.  The nature and extent of the Personal Data and Non-Personal Data that may be collected by or shared with PlanSurity on the Site will depend on whether a User is within a publicly-accessible section of the Site, or the User has registered for access to a portal in accordance with and subject to PlanSurity’s policies in effect from time to time. A “portal” is a website within the Site that allows two-way interaction and where PlanSurity can collect information from a User and transmit it to another User. Access to and the type of Personal Data and Non-Personal Data collected in certain portals may be restricted based on whether or not you are paying customer at the time such access is granted. Access to certain portals may also be restricted, even if you are not a paying customer, based on whether you are dental provider, employer, third-party administrator (“TPAs”) or broker doing business or considering doing business with us. Access to portals may be made subject to additional requirements and policies of PlanSurity in its sole discretion, including your acceptance of more limited rights or incurrence of additional obligations.

This Privacy Policy describes policies applicable to the collection, processing, analysis, use, storage or transmission of Personal Data and Non-Personal Data in publicly-accessible sections of the Site. While this Privacy Policy applies as the default policy for Personal Data and Non-Personal Data collected by PlanSurity in portals, as explained under the heading “Exclusions” below, the rules applicable to the collection, processing, analysis, use, storage or transmission of Personal Data and Non-Personal Data in portals may be different in certain situations.

Changes to the Privacy Policy

As PlanSurity’s products and services change from time to time, this Privacy Policy is expected to change as well. We reserve the right to amend the Privacy Policy at any time, for any reason. The date of the last revision to the Privacy Policy will be indicated by the “Effective Date” at the top of this page.

Types of Data We Collect

Personal Data

We collect information (whether online, by phone, or by paper) that enables PlanSurity to identify or contact you (“Personal Data”) to carry out its business purposes.

The types of Personal Data we may collect include, but are not limited to:

  • General data (e.g., names, dates of birth, home and business addresses, email addresses, Internet protocol addresses and mobile/landline business/personal telephone numbers that are provided by visitors to our Site).
  • Government-issued identification numbers (e.g., social security numbers, national identification numbers and tax identification numbers).
  • Other identification information.
  • Financial information (e.g., passwords and PIN numbers).
  • Sensitive personal data (e.g., gender, age).
  • If you are a customer, information that you provide for delivery to a customer of another class with which you wish to contract or have contracted for the purpose of providing or obtaining services.

PlanSurity may also receive Personal Data from third parties for PlanSurity’s use in marketing to potential new customers.

Non-Personal Data

We collect information (whether online, by phone, or by paper) that does not directly identify you as you interact with our Site (“Non-Personal Data”). The types of Non-Personal Data we may collect includes, but is not limited to:

  • Site usage (e.g., browsing history, search terms, number of clicks, referring/exit pages, date/time stamp, time on Site).
  • Products and services viewed, including advertisements for such products and services.
  • Computer type, operating system and platform type.
  • Internet service provider.
  • Your industry and business (e.g., company size and location, job functions and seniority).
  • If you are a customer, the volume of data that you share with another User.

How We Use Your Data

Personal Data

In addition to the uses described above, we may use your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the below, in order to:

  • Identify you when you visit our Site.
  • Provide products, information or services you request or we think you may be interested in.
  • Respond to your emails or online requests for products, services, or information.
  • Deliver and process surveys.
  • Personalize and improve the usability of the Site.
  • Fulfill and/or deliver PlanSurity products and services.
  • Tailor content, advertising and marketing to you.
  • Publish directories and registration lists on the Site to allow certain other Users to individually contract with you.

Non-Personal Data

We may use Non-Personal Data to improve the usability of our Site and for other business reasons. We or other third-party companies may also use the Non-Personal Data to provide advertisements and targeted advertisements to you (ads based on the Non-Personal Data). Please note that, when you select an advertising link or other link that takes you to sites not operated by PlanSurity, you may be subject to the privacy policies of these third-party sites.

How We Share Your Data

We may share your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the below:

  • Share data with third parties to fulfill service requests and to perform business functions.
  • Share data with third parties as required by law or to protect PlanSurity in the good-faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process served on PlanSurity; (b) protect and defend PlanSurity’s rights or property; or (c) protect the personal safety of PlanSurity personnel or members of the public in appropriate circumstances.
  • Share data with third parties if PlanSurity and/or its assets (or a portion of its assets) are sold, assigned, transferred, or merged, or if PlanSurity undergoes some other change including a change to its corporate form as part of a bankruptcy proceeding or otherwise; information may be transferred as part of that transaction or change.
  • Share data with third parties to offer you products and services that may be of interest to you professionally or personally.  Users can request their information be removed from such lists by contacting us, as set forth in the “Contact Information” section below.
  • Share data with third parties under other unanticipated situations, but only with your consent.
  • Share your email address, but only as permitted by the PlanSurity Email Policy, as follows:

Your email address will be used only by PlanSurity and PlanSurity vendors performing services, or offering products on PlanSurity’s behalf.    PlanSurity also shares your email address with third parties to enable PlanSurity to take security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data.  Finally, PlanSurity shares email addresses with third parties as necessary for PlanSurity to perform certain services on our or your behalf, such as mailing and delivering products and processing registrations and to respond to your service requests.  PlanSurity does not currently sell or rent email addresses to anyone outside PlanSurity, nor does PlanSurity share email addresses with unrelated third-parties; provided, however, PlanSurity reserves the right to change such policy at any time without notice to you.

 How you Can Manage the Processing of Your Data

 If the Site allows you to create a profile and email preferences, you can manage your profile and email preferences, including “opting out” of email for marketing purposes by contacting us using the information in the “Contact Information” section below. If you prefer to receive hard copy mailings only from PlanSurity, you can contact us and request to have your name and address removed from the list we provide to third parties. Additional rights may be afforded to you under state law.  Some of those laws that may apply to you are briefly summarized below.

Our processing of your data, if any, is based upon your consent, contract performance (e.g., your purchase of products), legitimate business interest (e.g., direct marketing of goods and services), or compliance with law.  You have the right to object to our processing of your data or to restrict our processing of your data. In addition, if you have consented to the processing of your Personal Data, you have the right to withdraw your consent at any time.

California Residents Privacy Rights

In addition to the rights as explained in this Privacy Policy, under California’s “Shine the Light” law, California residents who provide personal information (as defined in the statute) to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the personal information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g., requests made in the current year will receive information about the prior year). To obtain this information please write to us at: PlanSurity, _________________, Attn: ____________ — California Privacy Law. Please include your full name and address.

Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. Currently, the Site does not respond to the Do Not Track settings.

Nevada Privacy Notice

Nevada law requires that we also provide Nevada residents with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E Washington St., Suite 3900, Las Vegas, NV 89101; phone: 702.486.3132; e-mail: BCPINFO@ag.state.nv.us.

Children

We do not knowingly collect Personal Data from or market to children under the age of 13.

How We Protect Personal Data

PlanSurity implements commercially reasonable security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. Except for directories and registration lists available to customers and the sharing of information as set forth in this Privacy Policy, we restrict access to Personal Data to certain companies who need the data to operate, develop, or improve our services. These individuals or partner organizations are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Unfortunately, no data transmission over the Internet or electronic storage is fully secure. Accordingly, and despite our reasonable efforts to protect your Personal Data from unauthorized access, use, or disclosure, PlanSurity cannot guarantee or warrant the security of the Personal Data you transmit to us, or to or from our online Site. If you have questions about this Privacy Policy, please contact us by clicking here https://www.plansurity.com/contact/.

Linking to Other Internet Sites

You should be aware that other Internet sites that are linked from the Site or from a PlanSurity email message may contain privacy provisions that differ from the provisions of this Privacy Policy. To ensure your privacy is protected, we recommend that you review the privacy statements of these other linked sites, applications, or other digital platforms.

How you Can Access, Change and Delete your Personal Data

We rely on you to update and correct your Personal Data.  If you are a user of our Site, purchaser of PlanSurity products and services, or a PlanSurity member, you can review, update and correct your information directly on PlanSurity’s website or by contacting us using the information in the “Contact Information” section below. Typically, we retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.  This may include retaining your Personal Data indefinitely, even after you are no longer a PlanSurity member, in order to provide you with future marketing opportunities and other purposes, as well as to comply with our legal obligations, resolve disputes, or enforce any of our agreements.  Please note that you can request, at any time, that we delete your Personal Data.  All requests must be directed to the contact in the “Contact Information” section below.  We can decide to delete your Personal Data if we believe that the data is incomplete, inaccurate, or that our continued use and storage are contrary to our obligations to other members, individuals, or third parties.  When we delete your Personal Data, it will be removed from our active databases or anonymized so that the data is no longer identified with you, but the data may remain in our archives if PlanSurity determines that it is not practical or possible to delete it.

Cookies and Other Web Devices

Our website sends cookies (e.g., pieces of code or text placed on your computer by us or third-parties when you browse our Site) to your web browser (if your browser’s preferences allow it) to collect data when you browse our Site.  Cookie settings can be controlled in your Internet browser to automatically reject some forms of cookies.  If you view our website without changing your cookie settings, you are indicating your consent to receive all cookies from our Site.  If you do not allow cookies, some features and functionality of our Site may not operate as expected.  In addition to cookies, we place technological tools (and allow certain third parties to place technological tools) such as tags and beacons (e.g., code scripts that are primarily used to track visitors’ activities on our Site by web analytics software), Internet Protocol (IP) addresses, and other tools, to collect your data for the purposes listed in this Privacy Policy.

Transmission of Data to Other Countries

Your Personal Data is processed in the United States, where privacy laws may be less stringent than the laws in your country and where the government, courts, or law enforcement may be able to access your data.  By submitting your Personal Data to us, you agree to the transfer, storage and processing of your Personal Data in the United States.

Right to Complain to Supervisory Authority

You, as the data subject, have the right to lodge a complaint with a supervisory authority, in particular in the state of your habitual residence, place of work, or place of the alleged infringement, if you believe that our processing of your personal data does not comply with legal requirements.

Breach Notification

In the event we determine the occurrence of a data security incident, we will notify you by email, US mail, telephone, or other means as permitted by law.

Contact Information

If you have questions, comments, or complaints concerning the privacy practices covered by this Privacy Policy or if you wish to change, access, or remove your Personal Data, please contact us as indicated below.  We will attempt, where practical, to respond to your requests and to provide you with additional privacy related information.

PlanSurity

https://www.plansurity.com/contact/

support@plansurity.com

Exclusions

From time to time, PlanSurity may enter into agreements with certain of its customers that contemplate the collection, processing, analysis, storage or transmission of “individually identifiable health information” of individuals enrolled in a dental plan (“covered persons”) via select portals in this Site.  This Privacy Policy is not applicable to or describes PlanSurity’s policies and procedures with respect to “individually identifiable health information”, if collected, processed, analyzed, used, stored or transmitted via any such portal, and is distinct from the PlanSurity’s Notice of Privacy Practices (the “HIPPA Notice”), a special notice with respect to the use of any “individually identifiable health information” required by a federal privacy law and regulations known, collectively, as the “HIPAA Privacy Rule, that would be provided should PlanSurity were to collect, process, analyze, use, store or transmit any such “individually identifiable health information” at any time.  A summary of our policies, the rights and obligations related to and the protections afforded under the HIPAA Privacy Rule is available for review by our customers, prospective customers and our customers’ covered persons in those portals.   Customers, prospective customers and our customers’ covered persons are encouraged to review the HIPPA Notice, as in effect from time to time.

This Privacy Policy does not apply to Personal Data and Non-Personal Data of customers or covered persons of customers collected, processed, analyzed, used, stored or transmitted via or in connection with a portal in this Site established in furtherance of the performance by PlanSurity of its obligations under agreements entered into with them (or for their benefit) to the extent the application of this Privacy Policy would be contrary or inconsistent with or prevent or change the standards of performance by any person or duplicative of procedures established under or pursuant to those agreements.  The nature, extent and treatment of such Personal Data and Non-Personal Data, including that of covered persons, will depend on the terms and conditions of those agreements, and in the case of “individually identifiable health information”, if any, the HIPAA Privacy Rule, among other applicable laws.    Prospective and actual customers are encouraged to become familiar with the terms of those agreements, as set forth in our portals, before providing their Personal Data and Non-Personal Data.

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