Pro-Tier, Inc.

Website and Mobile App Privacy Policy

October 2023

Welcome to this website, a service of Pro-Tier, Inc. (“we” “us” or “our”). This Privacy Policy (“Privacy Policy”) explains how we collect, use, and disclose information about you or members of your household when you use this website or mobile application, or any other related service, website, mobile application, or interactive features (the “Services”).

The Websites and Services Covered by this Privacy Policy

This Privacy Policy applies to the Services, including, but not limited to:

Pro-Tier or Pro-Tier-branded websites, including www.pro-tier.com
Email or text messaging features, when you provide your email address or cell phone number to us, or consent to our use of your email address or cell phone number, in a website that links to this Privacy Policy.

We are not responsible for the privacy practices of any third-party service providers (such as health plans, health insurance marketplaces, internet service providers or cloud service providers) or other third parties operating websites or applications to which our Services link. The inclusion of a link in any Services does not imply that we endorse, or otherwise monitor the privacy practices of that linked third party website or application.

The Categories of Information We Collect When You Use Our Services

Information we collect directly from you includes data that is unique to an individual, like your name, address, social security number, e-mail address, telephone number and policy information. It can also include information which is not unique to you but which we’ve associated with your Pro-Tier account. For example, it may include demographic information (like income, age, gender, household composition, race or ethnicity) or health information (such as health condition or medical needs). Additionally we collect relevant business information including name, address, e-mail address, telephone number, Employer Identification Number (EIN), trade name, and owners’ information.

We collect the same or similar types of information when you shop for dental or vision benefits, or use our other services.

Information we collect through automated means includes usage data (such as web browser information, server log files, cookie technology, pixel tags or beacons, and other technologies) that we collect when you use our Services. See the Section “How We Use Tracking Technologies to Collect Usage Data” for more information.

Information we collect from others includes additional information such as demographic, eligibility, and statistical information from third parties and sources, such as business partners, marketers, researchers, analysts, public records, and others that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and provide more relevant experiences for you and improve our websites, analytics, and advertising.

How We Use Tracking Technologies to Collect Usage Data

When you visit or interact with our Services, we may collect data from you through a number of different automated technologies (“Tracking Technologies”) to help us improve our Services and present you with sponsored content on other service platforms. Examples of how we use Tracking Technologies include:

Browser and device information. We may automatically collect certain web browser information such as (a) IP addresses, unique device identifiers and other information about your computer or mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. Web browsers collect and store information about the type of device and operating system you are using to access our Services, as well as your device’s media access control (“MAC”) address for facilitating network communications. Accessing this information helps us to establish a secure and consistent connection to you and to customize experience and content when you use our Services.
"Cookie" technology. A "cookie" is an element of data that we can send to your web browser when you link to our Services. It is not a computer program and has no ability to read data residing on your computer or instruct it to perform any step or function. By assigning a unique data element to each visitor, we can recognize repeat users, track your usage patterns and better serve you when you return to our Services later. The cookie can also track your usage patterns as you visit other websites across the internet, to support marketing campaigns that deliver sponsored content about our Services on other websites and service platforms. Your browser may offer you a “Do Not Track” option, which allows you to prevent us from tracking your online activities over time and/or across different websites. Other than with respect to the global privacy signal discussed below in this Privacy Policy, our Services do not support Do Not Track requests at this time.
Client-side page tagging. This technology uses code on each web page to write certain information about the page and the visitor to a log when a page is rendered to you by our Services. "Tagging" does result in a JavaScript program running in your browser, but it is limited to providing information about the page that you are requesting and the configuration of your browser. It will not read any of your data files, nor execute any additional programs. It does not extract any information that identifies you. You can prevent tagging by disabling JavaScript in your browser, but that may prevent you from using all of our Services’ functions.
Tracking pixels or beacons. Tracking pixels (sometimes referred to as "web beacons") are tiny graphics with a unique identifier that are embedded invisibly on web pages and are about the size of the period at the end of this sentence. They perform a similar function to cookies, except that cookies are stored on a user's computer hard drive. We may use web beacons on our websites and mobile applications to help us collect data about user activity.
To opt out of our sales/sharing of personal information that are not based on cookies and similar online activities, email us at support@pro-tier.com.

How We Use the Data We Collect

We use your information to:

Verify your identity and authenticate access to your account
Provide, operate, administer, and troubleshoot the Services
Personalize your experience when using the Services
Provide you with customer service and technical support
Send you information about your relationship or transactions with us
Evaluate and improve our Services and develop new products and services
Notify you of new Service features or new Services that we provide
Allow us and our advertising partners to personalize the content and advertising that you see on the Services and on third-party platforms
Measure the effectiveness of our advertising and deliver relevant advertising to you
Engage in internal research, reporting and data analytics
Notify you of other benefits that your plan or any of our Pro-Tier partners may provide
Bill and collect payment for any applicable premiums, fees or charges
Take action that helps us to maintain the security of our Services and the privacy of your information, obey laws and help prevent fraud and abuse
Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others
Update any hardware, software or other tools that we provide in conjunction with the Services
Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others

Aggregate/De-Identified Information. We may aggregate and/or de-identify any information collected through our Services so that such information can no longer be linked to you or your device ("De-Identified Information"). We may use such information for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties, including advertisers, partners, and sponsors.

Combined Information. We may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

How We Disclose Information To Others

Third Party Service Providers. We use third party service providers to assist us in delivering our Services to you, including internet service hosting, payment processing, technical integration, marketing, analytics, customer service, application services providers, technical support services, and fraud protection providers. We disclose data to these third parties to the extent necessary for them to provide these services. These companies are acting on our behalf and are required, by contract with us, to keep our data confidential and are only authorized to use it for specific purposes. We always seek your approval before exchanging your information with certain third-party services that link your accounts with them to your Stride account.

Health Plans and Health Insurance Marketplaces. Our Services give workers the ability to seek coverage and determine eligibility for benefits offered by insurance carriers through the Health Insurance Marketplaces. The information we disclose to these entities is necessary for them to act on an application that you make through our Services. We always seek your approval before submitting an application or exchanging your information with an insurance carrier or Health Insurance Marketplace.

With Your Authorized Representatives. We deliver our Services to you and not to intermediaries that may offer assistance to you in managing your financial matters. We only disclose your information to an authorized representative if we verified the authority of a personal representative that contacts us at your request about your Pro-Tier account.

Sponsoring Partners. We partner with companies that promote our Services as a benefits platform for their permanent or independent workforce. These partners share a link with their workforce to our Services. If you visit our Services through a link like this, you will be presented with a branded marketplace of benefits. We do not disclose any of your information to these partners without your consent. We do not endorse or monitor the privacy practices of these sponsoring partners. You should read their privacy policies to understand how they may use your information when you access our Services through a branded marketplace.

Marketplace Partners. We augment our Services with benefits made available through our marketplace partners. We may disclose limited information to these partners such as unique identifiers to facilitate your enrollment in such benefits. We may also disclose De-Identified Information or aggregated reports with them to evaluate Service adoption and performance. We implement reasonable technical safeguards and business processes to prevent reidentification and receive contractual assurances that marketplace partners will not attempt to re-identify any De-Identified Information that we give them.

Legal Authorities. We may be required by law or legal process to disclose your information to our lawyers, to third parties in connection with litigation, or to law enforcement or regulatory personnel. We will disclose your information in good faith and when we deem such disclosure reasonably necessary for compliance with applicable laws. We may provide this information without your consent and without notice to you when we are required to do so in order to comply with a valid legal process such as a subpoena, court order, or search warrant.

Affiliates. We may disclose your information to any parent or subsidiaries, or other companies or entities which are controlled by or under common control with us. If we do so, they will be required to keep this information confidential and only for purposes that are permitted in this Privacy Policy.

Business Transfers. If we enter into a merger, acquisition, or the sale of all or part of our assets, or any diligence activities related thereto, your information may be part of the assets transferred. We will notify you if this happens if we have a way to contact you and we are required to provide you with notice.

Cross-Device Linking and Advertising. Some of our third-party service providers use different Tracking Technologies to predict or determine a likely association or relationship between two or more devices such as smartphones, tablets, desktop computers, etc. We may use analytics provided by these third parties to help us serve online content, including advertisements, about the Service across the internet on websites and social media platforms. We do not permit any third parties to serve advertisements on our Services.

Your Privacy Rights and Choices

Rights regarding your information
Depending on your jurisdiction, you may have the right, in accordance with applicable data protection laws, to make requests related to your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). The particular scope and nature of these rights vary in each state, so we have sought to explain these rights in the most transparent and uniform terms, below.

Specifically, you may have the right to ask us to:

Inform you about:

the categories of personal information we collect or disclose about you;
the categories of sources of such information;
the business or commercial purpose for collecting your personal information; and
the categories of third parties with whom we disclose personal information.

Provide you access to and/or a copy of certain personal information we hold about you.
Correct or update personal information we hold about you.
Restrict or object to certain uses of your information.
Delete certain personal information we have about you.
Provide you with information about the financial incentives that we offer to you, if any.
Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

Certain information may be exempt from such requests under applicable law. For example, we need certain information in order to provide the Services to you or for legal or tax reporting purposes. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify you, we may be unable to respond to your requests.

You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority.

To exercise these rights, send us an email at support@pro-tier.com or call us at (415) 857-5048. We do our best to acknowledge your request within 10 days and respond within 30 days. As provided in applicable law, you have the right to not be discriminated against for exercising your rights.

Notice of right to opt out of sales of personal information and sharing or processing personal information for targeted advertising purposes

Depending on your jurisdiction of residence, you may also have the right to opt out of the “sale” of your personal information and “sharing” or processing of your personal information for targeted advertising.

As explained in the “How We Disclose Information to Others” section above, we sometimes disclose information to unaffiliated third parties we collaborate with or that provide offers that we think may be of value to you. We also provide information to third-party advertising providers for targeted advertising purposes or use advertising analytics partners to assist us in analyzing use of our services and our user/customer base. Under applicable law, the disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information or the “sharing” or processing of personal information for targeted advertising purposes.

If you would like to opt out of the disclosure of your personal information for purposes that could be considered “sales” for those third parties' own commercial purposes, or “sharing” or processing for targeted advertising purposes, please visit the following link, which is also available in the footer of our Service: "Your Privacy Choice" Note that you will need to opt out on each device you use to access the Services. If you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.

We do not knowingly sell the personal information of children under 16 years of age.

Retention of Your Information

We will retain your information for as long as your account is active or as needed to provide you with Services, or as otherwise necessary to help us improve our products and services, comply with our legal and contractual obligations, resolve disputes, and enforce our agreements with you. In determining how long to retain information, we may consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests.

Security

We have implemented technical, administrative and physical security measures based on generally accepted industry standards that are designed to protect your information from unauthorized access, disclosure, use and modification. We regularly review our security practices to consider appropriate new technological and other safeguards. However, no method of transmission over the Internet or method of electronic storage is entirely secure. Even so, we cannot guarantee in all cases that these measures will be sufficient to protect your information from unauthorized use.

Children

We do not knowingly collect personal data from anyone under the age of 13 through our Services, and our Services are not directed at children under the age of 13. If we discover we have received any “personal information” (as defined under the Children’s Online Privacy Protection Act) from a child under the age of 13 in violation of this Privacy Policy, we will take reasonable steps to delete that information as quickly as possible.

Users Outside of the United States

The Services that link to this Privacy Policy are for users located in the United States. If you use any of our Services from outside of the United States, then by providing us any of your data, you understand and consent to the collection, use, processing, sharing, and disclosure of your personal data as described in this Privacy Policy, and acknowledge that the United States may not provide the same level of protection to personal data as the country in which you reside, whether that country is in the European Economic Area or elsewhere outside of the United States.

Email and Text Messages

After you create a Pro-Tier account, we may send you emails or SMS text messages to remind you of opportunities to save money. You can opt out of receiving these communications at any time by following the “unsubscribe” or “opt out” prompts in these communications. Even though you may opt-out of receiving marketing-related communications from us, we may still send you important administrative and transactional messages related to the Service.

Because of how email and SMS text messaging technologies operate, these communications are not encrypted. In addition, we have no control over the electronic networks that are used to transmit email or text messages. While interception or alteration of these messages is illegal, it is possible.

Sometimes, we send you emails that include a secure link that allows you to securely upload your information. We recommend that you use these links wherever possible. If instead you choose to send or request information over unencrypted email or SMS text message, you agree that you understand and accept that the information could be read by third parties.

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy. When we change it, we will make a copy of it available to you by posting it on www.pro-tier.com and including a link to it in this Privacy Policy. If we make material changes to this Privacy Policy, we will make you aware of them where we post the updated policy and may also notify you by other reasonable methods that we select. You understand and agree that if you use this website after the effective date of the updated Privacy Policy, we consider your use as acceptance of it.

NOTICES FOR CALIFORNIA RESIDENTS

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your “personal information” as defined in the California Consumer Privacy Act (“CCPA”).

We describe the categories of information we collect, our business purposes for collecting such information, the sources and uses of such information and the entities with which we disclose such information in this Privacy Policy.

Opt Out of Sale/Sharing of Personal Information

The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for cross-context behavioral advertising purposes. Under the CCPA, “sale” and “sharing” are defined such that they may include allowing third parties to receive certain information for advertising purposes.

If you would like to opt out of our use of your information for such purposes that are considered a “sale” or “sharing” for cross-context behavioral advertising purposes under California law (as indicated in the chart above), please visit the "Your Privacy Choice" link in the footer of our website. If you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.

We do not knowingly sell the personal information of minors under 16 years of age.

Additional Privacy Rights

In addition to the opt out rights above, California residents may make certain requests about their personal information under the CCPA as set forth in “Your Privacy Rights and Choices” section above.

If you are a California resident and would like to exercise any of your legal rights under the CCPA, you can email at support@pro-tier.com or call us at (415) 857-5048.

If we ever offer any financial incentives in exchange for your personal information, we will provide you with appropriate information about such incentives.

In the limited circumstances that we process sensitive personal information as defined in the CCPA, we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA.

Shine the Light

California Law permits customers who are California residents to request certain information once per year regarding our disclosure of personal information to third parties for such third parties’ direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

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