PRIVACY POLICY
COCO Development, LLC, DBA Benaissance
COBRApoint
General Statement
COCO Development, LLC, DBA Benaissance, (“Benaissance” or “COBRApoint”) has created this privacy statement in order to demonstrate our commitment to your privacy. Privacy on the www.cobrapoint.com and www.benaissance.com public web sites (the "Public Site") and the cobrapoint.benaissance.com or private labeled URL customer web sites (the “Customer Sites”) is of great importance to us. Because we gather important information from our visitors and customers, we have established this Statement as a means to communicate our information collection and dissemination practices. Benaissance hereby notifies you of the following:
1. What personally identifiable information of yours is collected from you through these web sites and how the information is used.
2. How the information may be shared.
3. How we protect your information.
4. How you can correct any inaccuracies in the information.
5. Consent and effective date
1. WHAT PERSONALLY IDENTIFIABLE INFORMATION OF YOURS IS COLLECTED AND HOW IT IS USED.
a. Information Collection and Use
Benaissance is the sole owner of the information collected on the Public Site. We will not sell, share, transfer or rent this information to others in ways different from what is disclosed in this statement. Benaissance only collects personally identifiable information from visitors on the Public Site who explicitly provide this information to us when they request more information about the services we provide. This personally identifiable information includes their contact information (such as name and e-mail address). This information is used to contact the visitors about the services on our site for which they have expressed interest.
The Customer Sites are web portals that facilitate our customers’ administration of their or their clients’ compliance with the Consolidated Omnibus Budget Reconciliation Act regulations (“COBRA”). The Customer Sites are comprised of four web sites intended for four user types– COBRA compliance administrators, insurance brokers, employers, and COBRA and other continuation of benefits participants.
The users of the Customer Sites are solely responsible for the data, modification, management and/or deletion of any and all files and data used in conjunction with our Customer Sites. Benaissance will not sell, share, transfer or rent information collected on our Customer Sites to others in ways different from what is disclosed in this statement.
b. Registration
Users of the Customer Sites are granted access solely by our customers. Users of the Customer Sites who are not employees of our customers are required to complete a registration process to verify their identity. The information collected during the registration process may include the user’s name, email address, mailing address, SSN, or company EIN. This information is used by COBRApoint primarily to confirm the identity of the user, and all information transmitted by the user is over a secure connection (see Section 3.a.). Unique registration codes are also generated for each user and required at the time of registration to further confirm the identity of the user and ensure that users are only provided access to their own Information. Any other use of the personally identifiable information collected during the registration processed is governed by the terms of the COBRApoint User Agreement. Our customers have sole control of access to the Customer Sites by their employees, and these users are not required to complete the registration process so no personally identifiable information is collected from these users. All users of the Customer Sites select their own unique user name and password which they may change at any time.
c. Information
Users of the Customer Sites use the Customer Sites to host data and information ("Information"). Benaissance will not review or disseminate any such Information except as provided in the COBRApoint Application Services Provider Agreement, the Service Agreement, the COBRApoint User Agreement, or as may be required by law. Individual records may at times be viewed or accessed only for the purpose of providing a solution to a customer, resolving a problem or support issue, or as may be required by law. Users of the Customer Sites are responsible for maintaining the confidentiality and security of their user name and password.
d. Personal Health Information
Limited Personal Health Information may be collected and stored as part of the Information in the Customer Sites to the extent necessary for our customers to administer their own or their clients’ COBRA compliance. Access to these sites is password protected, and our customers have sole responsibility for providing access to these sites.
e. Payment Information
COBRA or other continuation of benefits participants who use our Customer Sites may be offered the opportunity to make their continuation premium payments through our Customer Sites using their credit card or bank account. If a user elects to do so, the payment information collected by COBRApoint may include the user’s name, billing address, credit card information, or bank account information (the “Payment Information.”) This Payment Information is not stored by COBRApoint and is used only for the purposes of processing the user’s payment. The Payment Information is encrypted and provided to our third-party payment processing provider, Sage Payment Solutions. Details about the Sage Payment Solutions Privacy Policy may be found on the Sage Payment Solutions website http://www.sagepayments.com.
f. Cookies
A cookie is a piece of data stored on the user’s computer. Use of a cookie by our Public Site is in no way linked to any personally identifiable information while on our site. Cookies may be used by our Customer Sites to track a registered user’s permission level for access to pages or information within a site. Cookies can also enable us to track the interests of our users to enhance the experience of our site.
g. Log Files
We may use IP addresses to analyze trends, administer the sites, track user’s movement, and gather broad demographic information for aggregate use.
2. HOW INFORMATION MAY BE SHARED.
a. Sharing
We may share aggregated demographic information with other third parties. This is not linked to any personal information that can identify any individual person.
We may partner with another party to provide specific services such as payment processing or mail fulfillment. When a customer or user elects to use these services, we will share information that is necessary for the third party to provide these services. Per our contractual arrangements with third party partners, these parties are not allowed to use personally identifiable information except for the explicit purpose of providing these services.
Benaissance shall not be liable for the transfer of any personal identification information resulting from loss or distribution of data, the delineation or corruption of storage media, power failures, natural phenomena, riots, acts of vandalism, sabotage, terrorism or any other event beyond Benaissance’s control.
b. Legal Requests
Benaissance cooperates with law enforcement inquiries, as well as other third parties, to enforce laws and third party rights, such as intellectual property rights and laws relating to fraud. Therefore, in response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, or other activity that may expose us or you to legal liability, we can (and you authorize us to) disclose your personal data and other information about you as we, in our sole discretion, believe necessary or appropriate.
c. Sale of Assets, Merger, Acquisition, Bankruptcy
Benaissance reserves the right to transfer information collected through the sites to an acquiring company should Benaissance or its assets be acquired as a result of a sale, merger or corporate transfer.
3. HOW WE PROTECT YOUR INFORMATION.
a. Confidentiality and Security
Benaissance employs commercially reasonable precautions to protect users’ personal information both online and off-line. When the Customer Sites are accessed by a user utilizing recent browsers (for example Microsoft Internet Explorer version 7.0 or later or Mozilla Firefox 3.0 or later), the Customer Sites use SSL encryption to ensure that the Information is secure and available only to the user. The Information stored in the Customer Sites is hosted on secure servers in a restricted access data center, and firewalls, third-party vulnerability scanning, and other sophisticated technologies are employed to help ensure the security of the Information. Finally, each user of the Customer Sites has their own unique user name and password to ensure that each user only has access to their own Information.
We protect your personal information off-line. Access to your personal information is limited to employees who Benaissance reasonably believes will need that information to provide services to you and to our customers.
However, Benaissance is not responsible for the confidentiality, security or distribution of your own personal information by our customers, partners and third parties outside the scope of our agreement with such customers, partners and third parties.
b. Links
The Public Site and Customer Sites may contain links to other sites. The linked sites are not necessarily under the control of Benaissance. Please be aware that Benaissance is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our sites and to read the privacy statements of each and every web site that collects personally identifiable information. If you decide to access any of the third-party sites linked to our sites, you do this entirely at your own risk.
4. CORRECTING INACCURACIES
a. Correction/Updating Personal Information
For our Public Site, if users’ personally identifiable information changes, or if users no longer desire to receive information about our services, they can contact us at webmaster@cobrapoint.com. We will endeavor to correct, update or remove the users’ personal data provided to us. For our Customer Sites, users should contact our customer who provided them access to the Customer Sites for any issues related to correcting or removing personally identifiable information. Benaissance does not have any responsibility for the accuracy or updating of the Information stored on our Customer Sites.
b. Notification of Changes
If we decide to change our privacy policy, we will post those changes on our Public Site at http://www.cobrapoint.com and/or http://www.benaissance.com so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
c. Site and Service Updates
As necessary, we may send the users of the Customer Sites service announcement updates. Users are not able to un-subscribe from service announcements, which contain important information about the service.
d. Opt Out Procedures
Users of the Public Site may opt-out of receiving communications from COBRApoint at the point where COBRApoint requests personally identifiable information about the user. Contact webmaster@cobrapoint.com to be removed from an e-mail list. If you are using an e-mail forwarding service or other similar service please make sure to include the correct e-mail address or addresses.
5. CONSENT AND EFFECTIVE DATE
a. Consent
By using the Public or Customer Sites, the user consents to the collection and use of information as specified in this Privacy Policy.
b. Effective Date
The Effective Date of this Privacy Policy is January 21, 2009.
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