Information We Collect
How We Collect Information
How We Use and Disclose Information
Compliance with Laws and Law Enforcement
Additional Consumer Privacy Rights
Additional Nevada Consumer Rights
Conflict Between This Policy and Local Laws and Regulations
We may collect information that personally identifies, relates to, describes, or is capable of being associated with you ("Personal Information"), including:
The types of Personal Information we collect about you may vary based on how you use our Sites and/or Services, and your relationship with us.
Some of the Personal Information we collect may be considered "Sensitive Personal Information" under applicable law. We collect the following types of Sensitive Personal Information:
We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, "Business Information"). This information is generally not considered Personal Information because it relates to a business.
Usage Data and Sites Activity
We automatically collect information in connection with the actions you take on our Sites or when using our Services ("Usage Data"). For example, each time you use our Sites, we automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within our Sites, and the duration of your visits to our Sites. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information under the category Internet or other electronic network information. If this information is not capable of being individually associated with you, we treat it as anonymous Usage Data. We may collect, use, and disclose Usage Data for any purpose without restriction.
We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.
We may anonymize or aggregate Personal Information so that it is no longer capable of being associated with you in which case it will be considered "Deidentified Information". We will not attempt to reidentify you or any other person from Deidentified Information. We may use and disclose Deidentified Information for any purpose without restriction.
We may ask you to provide us with Personal Information when you communicate with us online or offline, including events, surveys, and marketing or promotional programs. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services or we may not be able to fulfill your requested interaction.
Third-Party Data Sources
We may collect Personal Information from third-party data sources such as data brokers, consumer reporting agencies, marketing partners, analytics firms, dental plans, discount plans, dental or healthcare providers, insurers, and government agencies.
Cookies and Other Automated Tools
We use the following types of cookies:
We employ software technology that enables us to track certain aspects of a user's visit to our Sites. This technology helps us better manage content on our Sites by informing us what content is effective, how consumers engage with our Sites, and how consumers arrive at and/or depart from our Sites. The software typically uses two methods to track user activity: (1) "tracking pixels" and (2) "clear gifs." Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether a user views a web page or email message. User activity information may be associated with additional information about a user's session and Personal Information, if provided by the user.
Cross-Context Behavioral and Targeted Advertising
Information from Advertisements
If you arrive at our Sites via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time).
Social Media Widgets
The Sites may include social media features, such as the Facebook, YouTube, Pinterest, LinkedIn, Instagram, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with features are governed by the privacy policies of the companies that provide them.
When you use our Mobile App, we may collect your geolocation data to the zip code level and other information. This is so that we can provide you with a list of participating providers nearest to you.
We may use Personal Information for the following business purposes:
|Processing Purpose||Personal Information That May Be Used|
Account creation, fulfillment, servicing and customer support: for example, to process applications, create customer accounts, allow customers to create online accounts and profiles, provide goods or services, keep customers informed about the status of their goods or services, respond to questions and addressing customers concerns, deliver updates, upgrades and product improvement information
Marketing and market research: for example, to send communications and offers for our or third parties' products and services, including offers based on consumers' interests, personal and business characteristics and location; perform analytics for market and consumer research, trend analysis, financial analysis, and anonymization of personal information
Surveys, promotional events, contests: for example, to administer surveys, polls, sweepstakes, contests, loyalty programs and other promotional events and contests
Other company communications: for example, to provide consumers with information that may be of interest such as company newsletters, announcements, reminders and technical service bulletins
Website use and analytics: for example, to provide you with access to and use of our Sites and Services; analyze consumers' use of our websites, including the use of third-party web analytics services, which may utilize automated technologies to collect data (such as email and IP addresses)
Eligibility and pricing: for example, to determine if consumers are eligible for certain products, services or offers and the pricing related to such offers
Product research: for example, to conduct research and analysis for maintaining, protecting, and developing services, increase and maintain the safety of our products and services
Business operations: for example, to evaluate, develop, and improve business operations, products and services offered; business administration and other normal business activities
Compliance: for example, to comply with applicable legal requirements, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others, prevent misuse
Information security and fraud prevention: for example, to operate information security and anti-fraud programs
We do not use Personal Information to engage in profiling with legal or similarly significant effects.
We also use Sensitive Personal Information specifically for the following purposes:
|Sensitive Personal Information Type||Purpose(s) of Processing|
|Social Security Number||Confirm your identity
Verify eligibility for services
Prevent and investigate fraud
|Account log-in information||Provide access to our services to you through our online systems|
|Racial or ethnic origin||Received and used in connection with providing our health-related services to you|
|Religious or philosophical beliefs||Received and used in connection with providing our health-related services to you|
|Union membership||Membership in a union could be inferred if you receive our services via union; however, we do not use the fact that a person is a union member for any purpose other than to indicate the affiliation with the service provided via a union.|
|Personal Information collected and analyzed concerning your health||Necessary to provide our health-related services to you
Prevent and investigate fraud
If you are a California resident, we do not use your Sensitive Personal Information for any purpose beyond those permitted by 11 Cal. Code of Regs. § 7027(m).
Reviews and Testimonials
If you provide a review or testimonial, we may post it publicly on our Sites or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.
We may provide your Personal Information to other businesses ("Service Providers") to provide services to us or on our behalf. Categories of service providers we use include:
Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information that we provide to them other than as specified by us. In the past twelve months we have disclosed each category of Personal Information to one or more Service Providers and have disclosed the following categories of Sensitive Personal Information to Service Providers for the purposes stated above: Social Security, driver's license, state identification card, or passport numbers; account log-in information; racial or ethnic origin; union membership; Personal Information collected and analyzed concerning your health.
Third-Party Selling and Sharing
|Third Party Type(s)||Sell or Share||Categories of Personal Information Disclosed in Last 12 Months||Purpose of Disclosure|
|Ad networks and social media companies||Share||
||To market and advertise our goods and services.|
Other Third-Party Disclosures
In the past twelve months, we have disclosed Personal Information to Third Parties for a business purpose that is not a sale or sharing (for cross-context behavioral or targeted advertising purposes) in the following scenarios:
|Type of Third Party||Personal Information Disclosed|
|Courts and governmental agencies||
|Parties in litigation||None|
|Purchasers or potential purchasers of our business assets||None|
|Parties or potential parties to a merger or other business combination with us||None|
We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Sites or Services, you do so at your own risk.
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to: respond to legal requests (including court orders, investigative demands and subpoenas); protect the safety, property, or rights of ourselves, consumers, or any other third party; prevent or stop any illegal, unethical, or legally actionable activity; or comply with laws.
The Sites may contain links to third party websites including social media platforms. Please be aware that if you access these links, you will be leaving our site. We encourage users to read the privacy policies of those sites, as we are not responsible for their content, links, or privacy procedures.
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
Except with authorization from a parent or legal guardian, or as otherwise permitted by law, or as set forth below, the Sites and Services are not intended for children under the age of 16 and we do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16 without valid authorization or legally-permitted purpose, we will delete such information from our records.
Certain of our Services may be offered to individuals under the age of 16, including DialCare Dialogue, a virtual student counseling program to provide mental health counseling to students of enrolled educational institutions. Any such programs are operated with the participation of the individual's educational institution, and as permitted by law. Any personal information collected from children will be used solely in furtherance of the applicable Services and will only be shared with third parties to the extent it is integral to the provision of such Services (for example, to mental health providers providing counseling services or the student's educational institution). If you are a parent of a child enrolled in our Services, you may request access to your child's personal information, request that it be deleted, or prevent the further use or online collection of your child's personal information through the contact information listed at "Contact Us" below. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations.
Right to Know
You have the right to request twice per 12-month period that we provide you (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose for which we collected your Personal Information; (iv) the categories of Third Parties with whom we sold or shared your Personal Information; and (v) the business or commercial purpose for which we sold or shared your Personal Information. We are not permitted to provide access to specific pieces of Personal Information if the Personal Information is sensitive or creates a high risk of potential harm from disclosure to an unauthorized person such as financial information, social security numbers, and driver's license numbers. In that instance we will provide you with an indication of the type of information we have on file or redacted information.
Right to Deletion
You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations.
Right to Correction
You may request that we correct Personal Information we have on file that you believe is inaccurate. When you make your request, please be sure to provide us the specific information that you believe is inaccurate and the correct information. You should also provide us with any documentation you believe supports your proposed correction, and we will take that documentation into consideration. We will only correct the information if we determine, based on the totality of the circumstances, that your correction is more likely than not accurate. We may also choose to delete the allegedly inaccurate information instead of correcting it.
Right to Opt Out from the Sale or Sharing of Personal Information
You have the right to direct us not to sell your Personal Information to Third Parties or share it with Third Parties for targeted or cross-context behavioral advertising purposes.
We will recognize and process Global Privacy Control and, to the extent required by law, other generally accepted browser-based opt-out signals. If we are able to reasonably associate a browser-based opt-out signal with an identifiable consumer, we will treat it as a request to opt-out of the sale or sharing of that consumer's Personal Information as if the consumer made the request using a method below. If we are not able to reasonably associate a browser-based opt-out signal with an identifiable consumer, we will treat it as a request to opt-out of the sale or sharing of that Site visitor's Personal Information collected while the signal is present. While the signal is present, we will also disable any Third Party cookies or other tracking tools present on the Site.
Right to Limit Use of your Sensitive Personal Information
If you are a Colorado, Connecticut, Utah, or Virginia resident, and you make a request to limit the use of your Sensitive Personal Information as defined under your applicable state's law, we will treat that request as a revocation of your consent for us to collect and process your Sensitive Personal Information and will delete your Sensitive Personal Information subject to any exemptions available under applicable law.
Right to Appeal
If you are a Colorado resident and we deny your privacy request, in full or in part, you may appeal our decision. If we deny your appeal, you may also contact your state Attorney General to lodge a complaint and we will provide you with an online mechanism to do so. Appeals are unavailable to California residents.
Submitting a Request
If you submit a Right to Know, Deletion, or Correction request, we require you verify certain information in order to confirm your identity before acting on your request so please respond promptly to our requests. We will process verified Right to Know, Deletion, or Correction requests within 45 calendar days of receipt subject to the possibility of one 45-day extension. If we need to extend the time for our response, we will contact you and explain the need for the extension. If you submit a request to Opt Out of the Sale or Sharing of your Personal Information or to Limit the Use of your Sensitive Personal Information, we will require you to verify your identity only if we suspect potential fraud. We will process valid requests to opt out of the sale or sharing of Personal Information or to limit the use of your Sensitive Personal Information within 15 business days of receipt.
If you submit an Appeal request we will process your request within the timeframe required under your applicable state law, but generally within 45 calendar days of receipt.
We will give you the option between electronic and mail fulfillment. We will retain a copy of your request and any supporting documentation for at least two (2) years. We will not use any document you provide in support of your request for any purpose other than evaluating and processing your request.
California "Do Not Track" Disclosure
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user's activity not be tracked. Currently, our Sites and Services do not respond to do not track signals. You may, however, opt-out of interest-based advertising using the DAA website linked above or make a browser-specific CCPA opt-out request using the CCPA opt-out tool linked here.
If you are an authorized agent submitting a request for another person, you must provide a copy of a lawful power of attorney or written authorization from the person (along with proof of your identity). You may provide this documentation via our Privacy Choices request Form. We may contact you or the person on whose behalf you claim to act to verify your authorization.
If you are a resident of Nevada, you have the right to direct us not to sell your Personal Information to Third Parties. You may exercise these rights by sending an email to [email protected] with the subject line "Nevada Opt Out." Although Nevada law gives us 60 days to respond to your request, plus an additional 30 days in certain instances, we will strive to respond to your request as soon as reasonably possible. We may request additional information in order to verify your identity or locate your Personal Information.