This Privacy Notice describes the information Presidio Interactive Corporation, d/b/a TopHealthPlans (“TopHealthPlans”, “we”, “our”, or “us”) collects, how we use this information, with whom we share it, and the choices you have in connection with this. This Privacy Notice applies to TopHealthPlans-owned websites (the “Website”), and any other electronic or digital products or services made available by TopHealthPlans that link to this Notice (collectively, the “Services”).
INFORMATION COLLECTION AND USE
Through your use of the Services, we will collect personal information, which is information that identifies you or relates to you as an identifiable individual. We collect personal information directly and automatically as outlined below.
1) Information Collected Directly From You
When you engage with certain Services, we will collect your personal information. Except as otherwise indicated, the personal information we collect is such that we need to carry out the requested action. If you do not provide us with your personal information, we would not be able to do so. We collect personal information when you:
- Complete the “Get Started” form on our Website: When you complete the “Get Started” form on our Website, we collect from you, your personal identifiers (name, email address, telephone number, physical address, gender, DOB), type of insurance, and any other information you choose to include. We use this personal information to communicate with you regarding your request and other services that may be of interest to you, and share your information with relevant third parties that can help you with your project. If you consent (opt in) to receive promotional text messages to your cellular telephone number, we will use your cellular telephone number to send you automated promotional text messages. Message and data rates may apply. You may reply “STOP” to any promotional text message to stop us from sending you future promotional text messages, or “HELP” for further assistance. Your agreement to receive promotional text messages is not a condition of any purchase from us. If you provide your postal address to us through our Website, you may receive periodic mailings from us. You may also receive mailings from other reputable companies.
- Utilize the Search function on the Website: When you use the search functionality on the Website, we will collect any information you decide to include in the search field. We will use this information to query our internal library of resources to identify relevant articles to your search term(s).
- Contact Us: When you contact us through the Services, we collect from you, your personal identifiers (name, email address, telephone number) and any other information you choose to include in your correspondence. We use this personal information to respond to your questions or inquiries, troubleshoot where necessary, and address any issues you may have.
- Subscribe to marketing emails: If you subscribe to our marketing emails, we will collect from you, your email address to fulfill your request to receive information we feel may be of interest to you. You can unsubscribe at any time by clicking on the “unsubscribe” link in each email. Please note that we will continue to send you notifications necessary to the Services or requested products or services. Our communications may contain email tracking technologies to gain valuable insight into behavior of recipients. With the help of these technologies, we can analyze whether a predefined action took place by a recipient, such as opening our communications, in order to better adapt and distribute our communications. When you opt-in to our marketing communications, you are opting into the use of these technologies. You can disable tracking by disabling the display of images by default in your email program. If you provide your postal address to us through our Website, you may receive periodic mailings from us. You may also receive mailings from other reputable companies.
- Participate in a survey, promotion, or contest: If applicable, when you complete a form to participate in a survey, promotion, or contest, we collect your personal identifiers (name, physical address, telephone number, and email address). We use this personal information to communicate with you regarding the promotion or contest, or analyze your feedback or survey responses to improve our Services. If you have not opted out of this when submitting your information, we also use your name and email address to send you marketing communications we feel may be of interest to you. You may unsubscribe at any time by clicking on the “unsubscribe” link at the bottom of each email.
TopHealthPlans.com may also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.
2) Information Collected Automatically
In addition to the personal information you provide, we also collect information automatically via cookies or other tracking technologies as you use the Services.
We may automatically capture information concerning your interaction with the Services using third-party software embedded in the script of the Services to better understand your interactions with the Services and/or for our compliance verification purposes. Specifically, we will automatically collect from you your internet and other electronic network activity information, including IP address, device type (i.e. make and model), unique device identification numbers, browser-type, time zone settings, broad geographic location (e.g. country or city-level location) and other technical information as well as keystrokes, mouse movements, and your interactions with the Services.
The information collected via cookies includes the following internet and other electronic network activity information:
- Usage information: We use essential, performance, and analytics cookies to collect information about your interaction with our Services, such as what you access, what you click on, the frequency of access, and how much time you spend on the Services. We use this information to: (i) track you within the Services; (ii) enhance user experience; (iii) conduct analytics to improve the Services; (iv) prevent fraudulent use of the Services; and (v) diagnosis and repair Services errors, and, in cases of abuse, track and mitigate the abuse.
- Device information: We use essential, performance, and analytics cookies to collect certain information about the device you use to access the Services, such as hardware model, operating system, and device preferences. We use this information to: (i) track you within the Services; (ii) enhance user experience; (iii) conduct analytics to improve the Services; (iv) prevent fraudulent use of the Services; and (v) diagnosis and repair Services errors, and, in cases of abuse, track and mitigate the abuse.
- Location information: We use essential, performance, and analytics cookies to collect information about your location, which may be determined through your IP address. We use this information to: (i) track you within the Services; (ii) enhance user experience; (iii) conduct analytics to improve the Services; (iv) prevent fraudulent use of the Services; and (v) diagnosis and repair Services errors, and, in cases of abuse, track and mitigate the abuse.
Particular cookies to note on the Services include:
- Facebook Pixel: We use Facebook Pixel to customize our advertising and to serve you ads on your social media based on your browsing behavior. This allows your behavior to be tracked after you have been redirected to our Website by clicking on the Facebook ad. The Facebook Pixel stores a cookie on your device to enable us to measure the effectiveness of Facebook ads for statistical and market research purposes. We do not have access to the information collected through the Facebook Pixel. However, the information collected via the Facebook Pixel is also stored and processed by Facebook. Facebook may link this information to your Facebook account and also use it for its own promotional purposes in accordance with Facebook’s Data Usage Policy. The Facebook Pixel also allows Facebook and its partners to show you advertisements on and outside of Facebook. You can opt-out of displaying Facebook ads and sharing by visiting your Facebook Ad Settings, and you can clear and control the information third parties share with Facebook in your Off-Facebook Activity If you do not have a Facebook account, you can opt-out of Facebook ads through the Digital Advertising Alliance. To opt out of this cookie, follow the instructions in the YOUR INFORMATION CHOICES section or visit Do Not Sell My Personal Information.
- Google Tag Manager: Google Tag Manager is a tag management system to manage tags used for tracking and analytics on our Website. Tags are small code elements that, among other things, are used to manage traffic and visitor behavior and to test and optimize websites. We utilize Google Tag Manager to manage and organize all third-party tags on our Website and to control when those tags are triggered. You can view more information about Google Tag Manager’s privacy practices.
- TUNE Pixel: We may use TUNE for pixel or server postback tracking to collect certain performance marketing information about you. This enables us to measure the performance of marketing and advertising campaigns. Pixel tracking methods store a TUNE session identifier in a user’s browser cookie on click. In postback tracking (also called “server-side tracking”), TUNE directly sends a session identifier to the advertiser on click. On conversion, the advertiser then communicates that identifier to TUNE for validation. To opt out of this cookie, follow the instructions in the YOUR INFORMATION CHOICES section or visit Do Not Sell My Personal Information.
HOW WE SHARE YOUR PERSONAL INFORMATION
TopHealthPlans will make the personal information identified in this Privacy Notice available within TopHealthPlans’s corporate family, with service providers, or with other third parties as set forth below. We also share non-personally identifiable, aggregated, and/or public information with third parties. TopHealthPlans may share the personal information identified in this Privacy Notice in the following instances:
- With service providers: We share your personal information with our service providers that assist us in providing the Services, such as our IT support, marketing provider, software service provider, telephony software provider, communications provider, cloud and hosting provider, and email provider.
- With Customers: We share lead information with our customers so they can contact you regarding the products and services they provide relevant to your project. We share this information to provide our services and connect you to businesses that can help you with your project.
- Within TopHealthPlans’s Corporate Family: Where necessary, we share your personal information within TopHealthPlans’s corporate family for legitimate business purposes in order to efficiently carry out our business and to the extent permitted by law.
- In the event of a corporate reorganization: In the event that we enter into, or intend to enter into, a transaction that alters the structure of our organization, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our assets, we would share your personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We would also share your personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
- With your consent: Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time.
Sharing in the Last Twelve (12) Months
1) For a Business Purpose: In the preceding twelve (12) months, TopHealthPlans has disclosed the following categories of personal information for a business purpose to the following categories of third parties:
- We have disclosed your personal identifiers, internet and other network activity information, and customer records information to service providers that perform services on our behalf. These service providers include our software service provider, telephony software provider, hosting service provider, communications service provider, website development service provider, and cloud and hosting provider.
- We have disclosed your internet or other electronic network information to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair website errors that impair functionality.
- We have disclosed your internet or other electronic network information and location information to our IT support and data analytics provider to maintain, improve, and upgrade TopHealthPlans Services.
2) For a Sale:
- TopHealthPlans uses analytics, marketing, consent tracking, and marketing email cookies and other tracking technologies on its Services. These tracking technologies collect your internet and other electronic network activity and shares it with the company that placed the tracking technology on our Services, e.g. Facebook, Google, Jornaya, SendGrid, and Active Prospect. This use of your personal information may be considered a sale under the California Consumer Privacy Act. To opt out of this cookie, follow the instructions in the YOUR INFORMATION CHOICES section or visit Do Not Sell My Personal Information.
- We may share with our customers/partners and affiliates your personal identifiers (name, email address, telephone number, physical address), selected insurance type, selected timeframe, and any other information you choose to include. Please see the following link for a list of representative organizations to whom your personal information may be shared so they may send you marketing communications relevant to your interests, projects, or potential projects. If you are a California resident and wish to opt out, please follow the instructions in the YOUR INFORMATION CHOICES section or visit Do Not Sell My Personal Information.
- We may share with our session recording vendor your internet and other electronic network activity to help us analyze how you use our Services. This use of your personal information may be considered a sale under the California Consumer Privacy Act. To opt out of this cookie, follow the instructions in the YOUR INFORMATION CHOICES section or visit Do Not Sell My Personal Information.
The California Consumer Privacy Act (CCPA) entitles California residents to certain rights. To the extent that the CCPA applies to our processing of your personal information, you would be entitled to the following rights:
- Right to Access. You have the right to request what personal information we have collected, used, disclosed, and sold about you within the preceding twelve (12) months. You may only submit a request for access twice within a twelve-month period.
- Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions.
- Right to Opt Out. You have the right to opt out of the sale of your personal information to third parties. TopHealthPlans does not have actual knowledge that it sells personal information of minors under the age of sixteen (16) years.
- Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt out under the CCPA.
To exercise your right to access or delete your personal information, you may submit a request via email at [email protected] or via telephone by calling (904) 414-2850. To opt out of the sale of your personal information via cookies or for marketing purposes, please visit Do Not Sell My Personal Information.
For requests submitted via email and telephone, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. The interactive webform contains the information that we need to verify your identity and review your request.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.
If you are a consumer in the State of Nevada, you may request to review the personal information we maintain about you, make changes to the personal information we maintain about you, or opt-out of the current or future sale of your personal information by submitting a request by contacting us at [email protected] Please include “Request Under Nevada Law” in the subject line of your message.
YOUR INFORMATION CHOICES
All users of our Services have the following choices and rights:
- Marketing emails: You may opt-out of receiving marketing emails from us by clicking the “unsubscribe” link provided with each email. Please note that we will continue to send you emails necessary to the Services or any assistance you request.
- Opt Out of Email Tracking: You can disable this tracking by blocking automatic loading of images in your email.
- Marketing text messages: You may opt-out of receiving marketing text messages from us by responding “STOP” or “Opt-out” to any of our text messages.
- Opt Out of Google Analytics: To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser or visit Do Not Sell My Personal Information.
- Opt Out of Other Cookies: All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser’s directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/. Please note that each web browser is different. For information on reviewing or deleting cookies from specific browsers, click on the appropriate browser: Firefox, Firefox IOS, Firefox Android, Safari, Safari Mobile, Chrome, Internet Explorer, Microsoft Edge, Opera. To find information relating to other browsers, visit the browser developer’s Website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our website and mobile application may not function properly. If you choose to opt out, we will place an “opt-out cookie” on your computer. The “opt-out cookie” is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences.
- Opt Out of Online Advertising: Some of the companies that provide advertising services on our Services may participate in industry-developed programs designed to provide consumers with choices about whether to receive tailored ads that are based on your online activities. To learn more and to opt out of such targeted advertising from participating companies, please visit the websites of the Network Advertising Initiative, the Digital Advertising Alliance. To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt out only applies to the web browser you use, so you must opt out of each web browser on each device you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt out again.
- Opt out of Sharing with Partners: If you are a California resident and wish to opt out of us sharing your personal identifiers with our partners for marketing purposes, please follow the instructions in the CALIFORNIA RESIDENTS section to allow us to facilitate the opt-out.
DO NOT TRACK
We do not support Do Not Track (DNT). Do Not Track is a preference you can set to inform websites and applications that you do not want to be tracked.
We implement and maintain reasonable security measures, such as access controls and encryption, to protect the personal information we collect and maintain. However, no security measure or modality of data transmission over the Internet is 100% secure and we are unable to guarantee the absolute security of the information we have collected from you.
The Services are not intended for individuals under the age of eighteen (18). If we learn that we have collected or received personal information from a child under the age of eighteen (18), we will delete that information. If you believe we might have information from or about a child under the age of eighteen (18), please contact us at [email protected].
CHANGES TO THIS PRIVACY NOTICE
We may change this Privacy Notice from time to time. We will post the changes to this page and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you with a prominent post on our Services and obtain your consent, if required.
If you have any specific questions about this Privacy Statement, you can contact us via email below: