Thank you for your interest in Better Plan Benefits, Inc. (“BPB,” “we,” “us,” or “our”). This Privacy Policy outlines our privacy practices in connection with the users of BPB’s website and related apps (the “Website”), and its networks, applications, insurance agent and representative services, and communication channels (including online chat and telephone call centers), and other services provided by us (collectively, including the Website, the “Service”).

We are committed to protecting the privacy of those with whom we interact. This Privacy Policy (the “Policy”) contains details about how we collect, use, and share Personal Information about you (defined below) that we obtain from you when you interact with us via our Service, from other online and offline interactions, and from other sources. Please read this Policy carefully before deciding whether to use the Services we offer.

1. Applicability

This Policy, which only applies to the Service, explains how we collect, use, and disclose information. It does not apply to any third-party actions, websites, content, or conduct (collectively, “Third-Party Websites”), regardless of whether those Third-Party Websites are linked to, redirected from, or accessible from the Website. We do not control and Third-Party Websites. We are not an insurance company, and we do not own or provide our own health care plans. Third-Party Websites, including those owned and operated by insurance companies, have separate privacy practices and policies, which may include separate third-party “cookies” or similar technologies.

BPB does not control how Third-Party Websites use or store your information. Information, including personal identifying information (“PII”) and health-related information, shared by us with Third-Party Websites pursuant to the terms of this Policy may be disclosed by the recipient and may not be protected from disclosure by federal or state law. If you choose to visit or use Third-Party Websites, including by clicking on health plan-related links and getting redirected to Third-Party Websites, you assume all risk of doing so.

2. Policy Changes

We may update this Policy from time to time. The current Policy will be effective when posted. Please check this Policy periodically for updates. If any of the changes are unacceptable to you, you should cease interacting with us. When required under applicable law, we will notify you of any changes to this Policy by posting an update on this website. When required under applicable law, we will seek affirmative consent from you before making material changes to the way we handle Personal Information previously collected from you. If you do not provide such consent, Personal Information will continue to be used in a manner that is consistent with the version of this Policy that was in effect when the information was collected.

3. Collection of Personal Information

We collect information about you and how you interact with us in several ways, including:

1. Information you provide to us directly. We collect information that you provide to us directly, such as when you register with us through our Services or when you apply for a health insurance or other products using our Services.
2. Information automatically collected or inferred from your online interaction with us. We automatically collect technical information about your online interactions with us (such as IP address and browsing preferences).
3. Information from public sources, such as information from public records maintained by government entities, and information you submit in public forums.
4. Information from third parties. We receive information about you and your interactions with us from third parties, such as pharmacies, healthcare providers, insurance companies, credit reporting agencies, marketing and advertising providers, social network services, data brokers, and companies that provide or sell lists of potential purchasers. We also may receive information about you from friends and family members (such as other people insured under the same policy as you).

We may combine information that we receive from the various sources described in this Policy, including third party sources and public sources, and use or disclose it for the purposes identified below.

4. Types of Personal Information We Collect

The types of information that we may collect about you (collectively, the “Personal Information”) may include:

1. Identifiers, such as your name, alias, postal address, country of residence, unique personal identifier, online identifier, internet protocol address, email address, username, phone number, social media identifiers (e.g., Twitter handle, Instagram name, etc.), Social Security number, driver’s license number, or other similar identifiers, including identifiers for family members who may be insured under an insurance policy.
2. Customer records, such as your name, signature, address, telephone number, bank account number, credit card number, or other payment information.
3. Application and eligibility informationfor you and family members who may be insured under an insurance policy, such as age, date of birth, gender, health status, disability, medical history, military or veteran status, date of birth, and financial and tax information (for government subsidies).
4. Commercial information and preferences, including product preferences, advertising preferences, products or services purchased, obtained, or considered, or other preferences or interests.
5. Internet or other electronic network activity information, such as your browsing history, search history, IP address, and information regarding your interactions with us (including interacting with us online, by the mobile application, and through advertisements).
6. Geolocation information, such as approximate location based on your IP address.
7. Audio, electronic, visual, or similar information, such as call center recordings, or customer support chat logs.
8. Professional or employment information, such as job title, employer, business address and contact information.
9. Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

5. How We Use Your Personal Information

The types of information that we may collect about you (collectively, the “Personal Information”) may include:

1. To enable interactions between you and us, such as to facilitate online quoting, applications for, and purchases of our products; to register and administer your account, to support your interactions with us; to provide information about insurance plans; to communicate with you about your policy or our data practices; to install and configure changes and updates to programs and technologies related to interactions with us; to authenticate those who interact with us; and to respond to your requests, complaints, and inquiries.
2. For our own internal business purposes, such as to evaluate or audit the usage and performance of programs and technologies related to interactions with us; to evaluate and improve the quality of your interactions with us and the quality of programs and technologies related to interactions with us; to design new services and products; to process and catalog your responses to surveys or questionnaires (e.g., customer satisfaction reviews); to perform internal research for technological development and demonstration; to conduct data analysis and testing; and to maintain proper business records.
3. For legal, safety, or security reasons, such as to comply with laws and other legal requirements; to protect our safety, our property or the rights of those who interact with us, or others; and to detect, prevent, and respond to security incidents or other malicious, deceptive, fraudulent, or illegal activity.
4. In a de-identified, anonymized, or aggregated format. We may convert Personal Information into a de-identified, anonymized, or aggregated format, and use such information for any legal purpose.
5. For marketing. We may use your Personal Information to market our products or services or those of third parties, such as our business partners. We may use your Personal Information to invite you to participate in marketing surveys, questionnaires, promotions, events or contests. We may audit aspects of our ad impressions. We may use your Personal Information for short-term transient use, including for contextual ad customization. We may use your Personal Information to enhance our content and to deliver advertisements to you, including in commercial emails. For more information about online marketing activity, see Section 6 below.
6. Other disclosed or required purposes. To fulfill other purposes disclosed at the time you provide Personal Information or otherwise where we are legally permitted or are required to do so.
7. Other purposes by consent. For any other purposes for which you provide consent.

6. With Whom We Share Your Personal Information

We may share your Personal Information with the categories of recipients described below:

1. Affiliates and subsidiaries: We may share your Personal Information our corporate affiliates, subsidiaries, and other companies that share common ownership for the purposes described above.
2. Insurance providers, government health care exchanges, and related entities:In order to provide you with insurance you request, we may share your information with insurance companies, Federally-facilitated Exchanges or State-based Exchanges, HSA Trustees or Administrators, and similar entities.
3. Service providers and other third parties that help fulfill requests: We may share your Personal Information with third parties and service providers that facilitate and support us in processing a request or transaction on your behalf; to provide you with quotes, products, and services; and to process payments. We may share your Personal Information with an insurance agent when you request to be contacted by an agent, or when you request information about or an application for insurance that is offered through an insurance agent with whom we associate. If you are contacted by a third-party, any additional information that you subsequently choose to provide to any third-party entity will be governed by that entity’s privacy policy.
4. Third parties that provide business and professional services to us, such as web hosting service providers, IT providers, operating systems and platforms, internet service providers, analytics companies, and marketing providers (e.g., we may share your email address with our outbound email marketing providers), our attorneys, accountants, and auditors. We take reasonable efforts to provide these companies with only the information they need to perform services on our behalf and to limit their use and disclosure of Personal Information.
5. Business partners: We may also provide your Personal Information or provide access to your Personal Information to our business partners, including for third party marketing.
6. For legal, security and safety purposes: We may share your Personal Information with third parties such as law enforcement, regulators, or others to comply with federal, state, or local laws, a subpoena or other legal process, and other applicable legal requirements; to protect the confidentiality and security of our records; to protect against or prevent fraud; for claims administration; to enforce or apply our Terms of Use and other agreements; and to protect our rights and our property or safety of our users or third parties.
7. In connection with a corporate transaction: We may transfer any information we have about you in connection with a change in corporate control, including but not limited to a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Better Plan Benefits, Inc. and its business, or as part of a corporate reorganization or stock sale.
8. Organizations with which you have a relationship: We may disclose Personal information to an affinity group, employer, provider group, benefits administrator or consultant, healthcare system, pharmacy, financial services provider, or other entity with which you may have a relationship when such entity referred you to us or when you use our website or call center in connection with your relationship to such entity.
9. To others with your consent.

We may also de-identity, anonymize, or aggregate Personal Information to share with third parties for any purpose.

7. How We Use Cookies and Automatic Data Collection Tools

We also collect information, via cookies, web beacons, pixels, tags, or other tracking technologies, such as your Internet Service Provider and IP address, the date and time you access our website, the pages you access while visiting our website, and the Internet address from which you access our website. Some cookies exist only during a single session and some are persistent over multiple sessions over time. We use these technologies to remember user preferences, maximize the performance of our website and services, provide you with offers that may be of interest to you, measure the effectiveness of our email campaigns and to personalize online content. These cookies and other technologies may be used to track you across devices.

To provide you with more relevant and interesting experience, we may work with third party companies to display ads or customize the content on the website and on other websites. These companies may use cookies and similar tracking technologies as described in this Policy to gather information about your visits to the website, as well as your visits elsewhere on the Internet. These companies use this information to provide you with more relevant advertising known as interest-based advertising. You may choose whether to receive some interest-based advertising by submitting opt-outs. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives. Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your browser-based opt-out may not, or may no longer, be effective.

Some browsers have incorporated Do Not Track (“DNT”) preferences. Most of these features, when turned on, send signals to the website you are visiting that you do not wish to have information about your online searching and browsing activities collected and used. As there is not yet a common agreement about how to interpret DNT signals, we do not honor DNT signals from website browsers at this time. However, you may refuse or delete cookies. If you refuse or delete cookies, some of our website functionality may be impaired. If you change computers, devices, or browsers, or use multiple computers, devices, or browsers, and delete your cookies, you may need to repeat this process for each computer, device, or browser. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies.

8. Security and Retention

We maintain reasonable security procedures and technical and organizational measures to protect your Personal Information and PHI against accidental or unlawful destruction, loss, disclosure, access, alteration, or use. Nevertheless, transmission via the Internet and online digital storage are not completely secure and we do not guarantee the security of your information collected through the Service.

9. Social Security Number Protection Policy

BPB may collect a user’s Social Security Number (“SSN”) in the course of business. It is BPB’s policy to protect the confidentiality of SSNs by implementing administrative, physical and technical safeguards that are designed to guard against unauthorized access to SSNs. It is also BPB’s policy to limit access to SSNs to that which is allowed by applicable law and to prohibit the unlawful disclosure of SSNs.

10. Children’s Privacy

Interactions with us are intended for individuals 16 years of age and older. Our interactions are not directed at, marketed to, nor intended for, children under 16 years of age. We do not knowingly collect any information, including Personal Information, from children under 16 years of age. If you believe that we have inadvertently collected Personal Information from a child under the age of 16, please contact us at the address below and we will use reasonable efforts to delete the child’s information from our databases.

11. External Links

When interacting with us you may encounter links to external sites or other online services, including those embedded in third party advertisements or sponsored content which we do not control. We are not responsible for the privacy practices and data collection policies for such third-party services. You should consult the privacy statements of those third-party services for details.

12. Your Rights

Upon request, BPB will provide you with information about whether we hold any of your Personal Information. If your Personal Information changes, or if you otherwise want to correct, update, delete, or make other requests regarding your data (such as limiting sharing with non-affiliates), you may contact us at the addresses given below.

Additionally, you may update your name, email address and password by clicking on the “Sign in” or “My Account” link on this Website and signing in using your email address and password. We will respond to your request to access within a reasonable timeframe.

We will make reasonable efforts to respond to your request but cannot guarantee that we will be able to honor your request. For example, we generally will retain your information for as long as your account is active, as needed to provide you services, or for other business purposes. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Please note that once your application has been submitted to your chosen health insurance company or any other relevant party (such as the federal government in the case of an application involving certain tax credits) you may have to contact the insurance company or such other party directly to update your application and/or exercise your individual rights under The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).

13. Contact

If you have questions regarding this Policy or our privacy practices, please contact us at:

Better Plan Benefits
822 North A1A Highway
Suite 310
Ponte Vedra Beach, FL 32082

Email: Contact@betterplanbenefits.com

Telephone: (877) 914-2135

To opt-out of receiving promotional email messages from us, please click on the “Unsubscribe” link contained at the bottom of each email or by contacting us using the information above. To opt-out of receiving satisfaction surveys and/or information on additional products and services from us, you may contact us at the information above. Please note that you will still receive communications from us regarding your insurance quote, application, policy, or advanced premium tax credit even if you opt-out of receiving our surveys and/or notices of additional products or services.

14. Protected Health Information Privacy Notice

As part of helping you select the best plan for you, BPB may collect Personal Information, and create records, about your medical history. Such information, if so collected, is called Protected Health Information (“PHI”). We are committed to protecting the privacy of your PHI that we may collect as part of our services to you. When we use or disclose your PHI, we are bound by the terms of this PHI Privacy Notice. This PHI Privacy Notice applies to all electronic or paper records we create, obtain, and/or maintain that contain your PHI.

How we protect your privacy

We understand the importance of protecting your PHI. Within BPB, we restrict access to data and materials that may contain your PHI, by allowing only authorized staff members who need access to that information or data in order to administer the operations and functions of our website and applications. We maintain technical, physical and administrative safeguards to ensure the privacy of your PHI.

Authorization to collect and disclose your PHI

Other than for certain specific purposes described below or as permitted by applicable law, we must obtain your written authorization to use or disclose your PHI.

By utilizing the Service, you are expressly authorizing us to collect, receive, store, and file your PHI and to transmit your PHI to each insurance company, insurance broker and other insurance-related entities for the sole purpose of soliciting quotes for your insurance coverage.

You may cancel (“revoke”) any written authorization you have previously given us. The cancellation, submitted to us in writing, will apply to future uses and disclosures of your PHI. It will not impact disclosures made previously, while your authorization was in effect.

Disclosures of PHI without your authorization

By law, we may disclose your PHI without your written authorization as follows:

• We may disclose your PHI to:
• A government agency that is legally responsible for oversight of the health care system or for ensuring compliance with the rules of government benefit programs, such as Medicare or Medicaid.
• Other regulatory programs that need health information to determine compliance.
• We may disclose your PHI for research purposes, but only according to and as allowed by law.
• We may use and disclose your PHI to comply with the law.
• We may disclose your PHI in a judicial or administrative proceeding or in response to a valid legal order.
• We may disclose your PHI to the police or other law enforcement officials, as required by law or in compliance with a court order or other process authorized by law.
• We may disclose your PHI to various departments of the government such as the U.S. military or the U.S. Department of State as required by law.
• We may disclose your PHI when necessary to comply with workers’ compensation laws and similar programs.

Your Rights regarding disclosures of PHI

You have certain rights regarding disclosures of your PHI:

• Upon your request, we will provide a list of the disclosures we have made of your PHI for a specified time period. However, the list will exclude:
• Disclosures you have authorized.
• Disclosures made earlier than six years before the date of your request (in the case of disclosures made from an electronic health record, this period may be limited to three years before the date of your request).
• Certain other disclosures that are excepted by law.

If you request an accounting more than once during any 12-month period, we will charge you a reasonable fee for each accounting report after the first one.

• You may name another person to act as your Personal Representative. Your representative will be allowed, on your behalf, to access your PHI and to exercise all other rights you may have under HIPAA. Depending on the authority you grant your representative, he or she may also have authority to make health care decisions for you.
• Upon your request, we will provide a paper copy of this Notice, even if you have already received one, as described below.

Actions you may take

You may:

• Contact us. If you have questions about your PHI privacy rights, believe that we may have violated your PHI privacy rights, or disagree with a decision that we made about access to your PHI, you may contact us in writing or by telephone.
Better Plan Benefits
822 North A1A Highway
Suite 310
Ponte Vedra Beach, FL 32082
• Telephone Number: (877) 914-2135
• Email: Contact@betterplanbenefits.com
• Contact a government agency. If you believe we may have violated your PHI privacy rights, you may also file a written complaint with the Secretary (the “Secretary”) of the U.S. Department of Health and Human Services (“HHS”). Your complaint can be sent by email, fax, or mail to the HHS’ Office for Civil Rights (“OCR”). For more information, go to the OCR website https://www.hhs.gov/hipaa/filing-a-complaint/complaint-process/index.html. We will not take any action against you if you exercise your right to file a complaint, either with us or with the Secretary.

Right to change terms of this Notice

We may change the terms of this PHI Privacy Notice at any time, and we may, at our discretion, make the new terms effective for all of your PHI in our possession, including any PHI we created or received before we issued the new Notice. If we change this Notice, we will update the PHI Privacy Notice on our Website. In addition, you can obtain a copy of the new PHI Privacy Notice upon request when you contact our offices at the addresses set forth above.

15. California Consumer Privacy Act

If you are a resident of the State of California, the following privacy policies may apply to you:

The following provisions apply to BetterPlanBenefits.com processing of information of California residents that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household [subject to the California Consumer Privacy Act] (California Personal Information). For such California residents, the provisions of this California Addendum prevail over any conflicting provisions of the Privacy Notice.

BetterPlanBenefits.com, Inc has collected the following categories of personal information within the meaning of the California Consumer Privacy Act of 2018, within the last 12 months:

1. Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security numbers, driver’s license number, passport number, or other similar identifiers.
2. Any categories of personal information described in subdivision (e) of Section 1798.80 (California Customer Records statute). This means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, 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. Personal information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.
3. Characteristics of protected classifications under California or Federal law.
4. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
5. Biometric information.
6. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
7. Geolocation data.
8. Audio, electronic, visual, audio, thermal, olfactory, or similar information.
9. Professional or employment-related information.
10. Education, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
11. Inferences are drawn from any of the information identified in this subdivision to create a profile about the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitude.

BetterPlanBenefits.com has sold California Personal Information identified in the above categories (1)-(11) within the last 12 months.

We have disclosed California Personal Information identified in the above categories (1)-(11) for business purposes within the last 12 months. To learn more about the categories of third parties with whom we share such information, you can request a copy of our privacy policy by emailing Contact@betterplanbenefits.com

We obtain California Personal Information from various sources including but not limited to you, both online and offline interactions you may have with us or our service providers; other entities with whom you transact or to whom you provide information; the devices you use to access our websites, mobile applications, online services, and other web assets; credit bureaus; identify verification and fraud prevention services; marketing providers, analytics providers; public databases; social media platforms; and others consistent with this Privacy Notice. You can request a copy of our privacy policy by emailing Contact@betterplanbenefits.com

We use the California Personal Information we collect for the business purposes disclosed within this Privacy Notice. Note that the business purposes for which we use your information may include:

• Reporting and audits relating to transactions and interactions, including online interactions, you may have with us or others on our behalf;
• Protecting against and detecting security incidents, as well as, illegal, deceptive, malicious, or fraudulent activity, and prosecuting the same;
• Debugging to identify and repair errors that impair the intended functionality of our systems;
• Transient use including customization of ads;
• Providing services on our behalf or on behalf of another, including but not limited to servicing or maintaining accounts, verifying identity information, processing payments, and providing customer service;
• Conducting internal research to develop products or services;
• Demonstrating technology; and
• Conducting activity to verify, enhance, and maintain the quality or safety of products and services we provide and internal systems

BetterPlanBenefits.com may also use the information we collect for operational purposes, this includes our own use and sometimes for the use of our service providers. There are purposes for which we may provide you additional notice, for purposes compatible with the context in which the California Personal Information was collected.

16. Your California Rights

If you are a California resident, you have certain rights related to your California Personal Information. [You may exercise these rights free of charge except as otherwise permitted under applicable law.]

• Section 100 Rights. You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you.
• Section 105 Rights. You have the right to request that we delete any personal information about you which BetterPlanBenefits.com has collected from you.
• Section 110 Rights. You have the right to request that we disclose to you:
• • the categories of personal information we have collected about you;
  • the categories of sources from which the personal information is collected from;
  • our business and/or commercial purpose for collecting or selling your personal information;
  • the categories of third parties with whom we share your personal information; and
  • the specific pieces of personal information we have collected about you.
• Section 115 Rights. In the event that we sell your personal information or disclose that information for a business purpose, you may request that we disclose to you:
• • the categories of personal information that we have collected about you;
  • the categories of personal information about you that we have sold and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each category of third parties to whom the personal information was sold; and
  • the categories of personal information about you that we disclosed for a business purpose.
• Right to Opt-Out. We may sell your personal information to third parties. You have the right to opt-out of such sales here. Any opt-out request should be sent to Contact@betterplanbenefits.com.

You may request to exercise these rights by:

• By completing our rights request form available by emailing: Contact@betterplanbenefits.com; or
• Calling us toll-free at (877) 914-2135.

As required or permitted under applicable law, we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may limit our response to your exercise of the above rights as permitted by law.] We may not discriminate against you because of your exercise of any of the above rights, or any other rights under the California Consumer Privacy Act, including by:

• Denying you goods or services;
• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Providing you a different level of quality of goods or services; or
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

17. Do Not Sell My Personal Information

If you are a California resident, you have the right to opt-out of our sales of certain information relating to individuals and households subject to the California Consumer Privacy Act. To exercise this opt-out right, whether you have an account or not, please submit a request via Contact@betterplanbenefits.com. Include your name, account number (if applicable), and email address or mailing address.