We, through our Services, connect you with services and products offered by third parties, including certain products or services that may qualify for reimbursement under applicable employer provided or sponsored benefit plans. This involves sharing personal information with third parties, retailers, pharmacies, and other care providers (collectively, “Service Partners”), and our affiliates and subsidiaries (collectively, “Group Companies”).
For more information about the information we share with third parties and the recipients of such information, please refer to the How We Share Your Information section of this Policy. Please note that this Policy does not otherwise cover the use of personal information by third parties or their services, and we do not take responsibility for their privacy practices.
You may have certain rights or choices that relate to your personal information, including choices about how we share your personal information with others. For more information, please refer to this Policy’s Your Choices and Rights section.
|Information We Collect and Use||When you use or visit our Services, we collect information directly from you. We may also generate information about you (e.g., information about your device while you use our mobile application). In some cases, we may also obtain personal information from third parties (e.g., our Group Companies, business partners, third-party websites, applications, and services, and others).|
|How We Use Your Information||We may use your information to provide our Services, tailor your experience, send you marketing communications, provide you with more relevant advertising and offers that may be of interest to you, and for other purposes described below.|
|How We Share Your Information||We may share your information with our Service Partners; with our Group Companies; with other business partners (including advertisers); with social networking services; with third-party services or applications you use to log into your service account; with service providers (including payment card processors); and others as described below. When we share information, we do so to provide and improve our Services, for our own marketing purposes, to facilitate offers and advertising from others that may interest you, and for other purposes as described below.|
|How We Store and Protect Your Information||We maintain technical, administrative, and physical security measures designed to protect your information. We may retain your information for as long as your account is active and for a period of time thereafter to allow you to re-activate your account without loss of information, and as necessary for purposes described below.|
|Your Choices and Rights||You have choices about your personal information, and in some circumstances, you may be able to opt out of receiving marketing communications, change your communication preferences, access and update your information, update location sharing options, exercise choices regarding cookies, and/or opt out of certain sharing of information with third parties (including our Group Companies, Service Partners, and other business partners). These choices and other rights you may have are described in more detail below.|
|Links to Other Websites||Our Services may contain links to other websites or services that are not owned or controlled by us, including links to websites of our Service Partners, our Group Companies, and other business partners (including advertisers).|
|Children||Our Services are not directed at or intended for use by children, nor do we knowingly collect information from children under 16 years of age.|
|Changes to This Policy||We update this Policy from time to time, and changes will be effective when posted (as identified in the Policy).|
|How to Contact Us||If you have any questions about this Policy or the way your personal information has been used, please contact us using our feedback form or at the contact details set out below.|
INFORMATION WE COLLECT AND USE
“Personal information” is data that identifies, relates to, describes, can be used to contact, or could reasonably be linked directly or indirectly to you. For purposes of this Policy, there is no meaningful distinction between the terms “personal information” and “personal data.”
Personal Information We Collect Directly From You.
As you visit or use our Services, we may collect the following categories of personal information directly from you:
- Personal details (such as your name, age, birthday, gender);
- Contact information (such as email address, address, phone number);
- Account information (such as login credentials, including email address, password, and account settings);
- Social media data (We may provide you an opportunity to link to a social media service. If you choose to link your service account with a social media account, we may collect personal information such as name, age, gender, photographs, and other personal information relating to your social media account);
- Billing information (such as credit, debit, or other payment card information and billing address);
- Your preferences (such as your brand preferences, communication preferences, and other preference information you provide us);
- Reviews you submit (including any screenname you publish under or any personal information you include about yourself or others in such review);
- Content you publish (including your service recommendations and any personal information you include about yourself or others, or in content you publish in any medium provided by us);
- Photographs of you (if we provide a feature that permits the uploading of photos, then when you add a photo of yourself to your profile, upload photos to a review, or link your social media account to your service account);
- Communications you send us (such as questions, conversations, complaints, or other information that you may submit to our support team);
- Promotion information (if you choose to participate in any promotion activity provided by us, we will collect any information you provide in relation to such activity, such as photographs, images, captions, or other content, in accordance with the terms provided at that time); and
- Other information you may provide (including other information you provide about yourself or others through our Services or to which you provide us with access via third-party platforms).
You may choose not to provide some of the personal information described above. Please note, however, that many of our Services require some personal information to operate, so if you choose not to provide the personal information necessary to operate and provide you with a particular Service or feature of that Service, you may not be able to use that Service or feature.
We do not proactively collect sensitive personal information, such as health-related information related to any condition, diagnosis, treatment, prognosis, and the like. However, certain reimbursable items are medical in nature. Our Services include text boxes that are designed for you to describe certain details about your preferences or special requests that you want us or our Service Partners to know. Please be aware that information you freely submit in these boxes may reveal to us or to the Service Partners or third parties with whom we share information certain information that may be considered sensitive personal information under applicable law. Sensitive personal information you voluntarily submit is processed on the basis of your consent.
Personal Information Generated by Us.
As you use our Services, we generate certain personal information about you, including through automatic data collection and by inferences based on the information we collect about you and your activity. We may automatically collect information about your interactions with the Services or communications you receive (such as email) using certain technologies, such as cookies, web beacons, and other technologies (See, Cookies and Cookies and Internet-Based Advertising sections below for more details). We generate the following categories of personal information about you:
- Device information. When you visit or use our Services, we may automatically collect certain information about your device (e.g., your mobile device, computer, or tablet), including information about your hardware and software, device configuration, and nearby networks. Such data may include data about your device operating systems, browsers, and other software installed on your device; IP address or other device identifier; country of origin, region and language settings; and information about domain servers and wireless or network access points near your device.
- Usage and performance information. We may also automatically collect personal information about your usage of the Services, including information about your searches, statistics about the purchases you share with us, how you interact with the features of our Services and the links you click, your preferences, access times, referring URL, and performance of our Services.
- Location information. If you use our Services, we may automatically collect approximate location information about you (such as your city) or, with your consent, precise geographic location. The technologies we use to determine your location may include IP address mapping, cell tower position, Wi-Fi position, and GPS signals. We may use and store this information to provide and improve features of our Services, for example, to tailor our Services on a needs-based manner to better facilitate your requests (such as helping you find a service partner closer or closest to you). We do not have control over your device settings, but we do recommend enabling location services on your device so you can take advantage of any location-based features and functionality offered. Please see the Your Rights and Choices section below for more information about how to adjust your preferences, including those related to location information.
- Inferences about you. We may combine the information we collect, generate, or otherwise obtain to draw inferences about your preferences and interests in order to provide and personalize our Services and tailor the advertising we and our partners display or offer to you.
- Personal Information We Obtain from Third Parties. We may also receive certain categories of personal information from third parties, including our Service Partners. The categories of personal information we may obtain from third parties include:
- Your name;
- Email address or other contact information;
- Social media data, if we provide the opportunity to connect to our services using a social media third party platform then when you connect to our Services using a social media third-party platform or interact with us by liking or commenting on our social media pages or content, we may receive information from that social media third-party platform about those interactions and from your social media profile (e.g., name, age, gender, photographs, and other personal information related to that account); and
- Browsing, purchase, usage and advertising details, including information about purchases you make through our service; how you use third-party websites, applications, and services; information relating to your interactions with our advertising and marketing materials; and demographic information about users of our Services.
HOW WE USE YOUR INFORMATION
We use your personal information for the following purposes (“Purposes”), to:
- Provide the Services, which includes providing you with the services, products, and functionality offered through our Services and fulfilling your requests, including, but not limited to, facilitating purchase of products and services through our Service Partners;
- Authenticate your account credentials and identify you, as necessary to log you in to the Services and ensure the security of your service account;
- Show your purchases made through the websites, applications, and Services in your service account;
- Communicate with you about your account or use of our Services, products, and/or functionality (e.g., soliciting reviews and feedback, sending alerts and notifications you have subscribed to, providing updates and administrative emails or other notices required by law); respond to, or follow up on, your comments and questions; and otherwise provide customer service (see below for more detail on Electronic Communications);
- Send you marketing communications, including communicating with you about services or products offered by us or our Service Partners;
- Operate and improve our Services and develop new products and services, including using analytics to better understand how you use our Services for purposes of product, website, application, and service development and to enhance the user experience;
- Process promotional events;
- Process your payment information;
- Provide services and information to our Service Partners, such as providing user feedback and usage details;
- Tailor your experience with our Services, such as by making inferences or combining different pieces of information we have collected about you to offer better search results or otherwise tailor our Services to you according to your preferences or restrictions. For example, aligning or organizing search results with previously search or purchased items or stated brand or partner preferences;
- Protect against, investigate, and deter fraudulent, unauthorized, or illegal activity;
- Comply with our policies, procedures, and legal obligations, including complying with law enforcement or government authority requests, addressing litigation-related issues, and exercising rights or obligations conferred by law; and
- As otherwise consented to by you and as required or permitted by applicable law.If you give your consent to any further use of personal information, you can withdraw that consent at any time by contacting us using the details set out below.
You have choices about your personal information, and in some circumstances, you may have the right to opt out or object to our uses of your personal information for these Purposes. For more information, or to exercise these or other rights (where available), see the Your Choices and Rights section below.
- Electronic Communications.Consistent with the above Purposes and as permitted by applicable law, we may communicate with you via electronic messages, including email, text message, or mobile push notification to:
- Send you information relating to our products and Services.This may include confirmations, updates, receipts, technical notices, updates, security alerts, and support and administrative messages.
- Send you marketing communications. In other situations, subject to the Your Choices and Rights section below and applicable law, we may communicate with you about offers, promotions, upcoming events, and other news about products and Services offered by us or our Service Partners.
With your consent, where required, we may contact you at the mobile phone number that you provide to us by way of direct dial calls, autodialed and prerecorded message calls, and text messages in connection with the above Purposes.
- Processing Bases and Consequences.When we process your personal information, we rely on the following legal bases:
- Performance of the contract we have with you (for example, if you use our Services to purchase a product, we will process your information in order to allow the relevant service partner to complete and administer any purchase).
- Compliance with legal obligations to which we are subject (such as when we are obliged to comply with lawful requests from competent authorities such as law enforcement).
- To serve our legitimate interests (such as tailoring your experience with our Services, carrying out online advertising, and for fraud detection), provided that such processing does not outweigh your rights and freedoms. The processing must also be pursuant to other applicable legal bases for data processing, especially provisions set out under local law.
When we use personal information to meet our legitimate interests, we take steps to ensure that your rights to your personal information are not infringed. You can contact us using the details set out in the How to Contact Us section below for more information about the steps we take to ensure these rights are not infringed. You may also have the right to object to such processing as described in the Your Choices and Rights section below.
- To the extent that a legal ground described above would not apply to processing of your personal information by us, and for which we do not then have your current consent, we will seek your consent for such specific purpose in accordance with applicable law.
We aggregate personal information collected directly from you, information generated about you by us, and information obtained from third parties (with your consent, where required) with personal information collected about other users in order to produce general statistics that cannot be linked to you or any other specific user. Information that has been aggregated and de-identified is no longer considered “personal information” and may be subsequently used for any purpose.
We may process information that cannot be linked to you or any other specific user using any means available to us, either because it was collected anonymously or has been subsequently anonymized. Information that is anonymous or has been anonymized is no longer considered “personal information” and may be subsequently used for any purpose.
HOW WE SHARE YOUR INFORMATION
We disclose the personal information we collect (or otherwise generate or obtain) as follows:
- With our Service Partners. We share your information with our Service Partners to provide the Services (such as connecting users, products, or services, and sharing personal details, contact information, preferences, requests, and other information) and for our Service Partners’ own purposes, which may include marketing or advertising purposes (see below for more detail on Sharing with Service Partners).
- With our Group Companies in our corporate family. We may share your information with our Group Companies within our corporate family, including but not limited to for the Purposes described above, to provide you with integrated products and services, and for our and their marketing purposes (see below for more detail on Sharing with Our Group Companies).
- With social networking services. We may share (or facilitate your sharing of) your information with social networking services when you use our Services to connect and share your information publicly or with friends or when you use our Services to connect with us on, share on, or use third-party social networking platforms and services (see below for more detail on Sharing with Social Networking Services).
- Third-party services or applications you use to log into your account. If we offer you the ability to use a third-party service or application (e.g., Google, Facebook, etc.) to log into your service account, we share (or facilitate your sharing of) certain personal information with that third party.
- Reviews you submit.If you provide us with a review of your service, you authorize us to publish it on all our Services under the screenname you provided and to share it with Service Partners. You also authorize us to aggregate your review with other reviews.
- Content you publish.If you publish service or product recommendations on mediums provided by us, you authorize us to publish it on all our Services.
- To process payments. Credit or debit card information may be required to process certain transactions, including to purchase other products or services from Service Partners, in which case we may share your payment information with Service Partners, and other third-party service providers such as fraud detection services (see below for more detail and additional terms regarding Sharing to Process Payment Information).
- With other service providers.We share information with third-party vendors, consultants, and other service providers who perform services or functions on our behalf (see below for more detail on Sharing with Other Service Providers).
- In the event of a corporate transaction.We may disclose or transfer your information to a third party if we sell, transfer, divest, or disclose all or a portion of our business or assets to another company in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding.
- To protect rights and property. We may disclose your information to third parties when we believe in good faith that disclosure is necessary to protect our rights, our property, the integrity of the Services, personal safety, or the interests of you or any other person, and to detect, prevent and/or otherwise address fraud, risk management, security, or technical issues.
- To comply with and as required by law.We may disclose your personal information to government authorities or other relevant third parties in order to comply with applicable legal requirements, judicial proceedings, court orders, legal process, or lawful requests from governmental authorities.
- Aggregate information.We share aggregate statistical data for the improvement of our Services. We may also share aggregate or de-identified information with third parties at our discretion.
- At your request.We also share your information as directed or requested by you, or subject to your consent.
In some circumstances, you may have the right to opt out or object to our sharing of your information with certain third parties. For more information, or to exercise these or other rights, see the Your Choices and Rights section below.
Sharing with Service Partners.
When you make a request for a product or service from one of our partners through our Services, we share your information with that service partner to facilitate providing you with the products or services you requested. Depending on the request, this may include your name, contact information, preference information, information or comments that you choose to submit (if any), and other information as required by the particular service partner. Your information is provided to the service partner, just as it would be if you contacted the service partner directly. If you provide a mobile phone number in connection with your request, Service Partners may send you text messages regarding your request. Some Service Partners also require you to provide credit or debit card account information to secure or complete you purchase.
Service Partners use this information for their own purposes, which may include to improve their products or services and to provide you with targeted advertising and marketing communications, where permitted under law.
Sharing with Our Group Companies. We may share your information with our affiliates and subsidiaries, or Group Companies. We may share your information with our Group Companies for the following reasons:
- Provide you with integrated services (including to administer and support Services across our affiliated platforms);
- Provide personalized offers or send you marketing communications with your consent or as otherwise permitted by applicable law;
- Enable “single sign-on”, i.e., if this feature is provided, we may allow you to log into a shared account using a single set of log-in credentials, which allows us to, for example, show your benefit details and/or available balances and purchases made through the websites, applications, and services of our Group Companies on your account page, and allow our Group Companies to show information in your respective account(s) with them;
- Provide customer support services;
- Detect, prevent, and investigate fraud and misuse of our services, other illegal activities, and data breaches;
- Analyze how users use our independent and affiliated platforms, including so that we may improve existing products and services and develop new features, products, and services that may be of interest to our users; and
- Ensure compliance with applicable law.
To learn more about your choices related to how we share your information with our Group Companies (including our subsidiaries, our parent company, and its other subsidiaries), please see the Your Choices and Rights section below.
Sharing with Social Networking Services.
Our Services may allow you to connect to social networking services and share your actions, comments, content, and information publicly or with friends. Our Services may also allow you to connect with us on, share on, and use third-party platforms, including those on which we have a presence. Please be mindful of your personal privacy needs and the privacy needs of others as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. We do not control the privacy practices of third-party platforms. Please contact those sites and services directly to learn about their privacy practices.
Sharing with Other Service Providers.
We share information with third-party vendors, consultants, and other service providers who perform services or functions on our behalf (e.g., hosting or operating our Services, data collection, reporting, ad response measurement, site analytics, data analysis, delivering marketing messages and advertisements, processing credit card payments, and providing fraud detection services). We do not authorize these third parties to use or disclose your information for purposes other than those for which it has been provided. We require these third parties to maintain and implement security measures to protect your information from unauthorized access or processing.
HOW WE STORE AND PROTECT YOUR INFORMATION
We maintain commercially-reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
When your payment information is being transmitted to or through our Services, it will be protected by cryptographic protocols. To be clear, we only store your payment information if you choose to save that information to your account. We may transfer your payment and other information to the applicable service partner to process the transaction. Our contracts with third parties that receive your payment information require them to keep it secure and confidential.
However, we cannot guarantee that transmissions of your payment information or your other information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by us or our third-party service providers. Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. You play an important role in keeping your information secure. You should not share your username, password, or other security information for your service account with anyone. If we receive instructions using your username and password, we will assume you have authorized the instructions. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately as detailed in the How to Contact Us section below.
Retention. We may retain your personal information for as long as your account is active and for a period of time thereafter to allow you to re-activate your account without loss of information. We may also retain your personal information as necessary to:
- Maintain logs and business records for analysis, security, and/or audit purposes;
- Comply with record retention requirements under the law;
- Deal with any complaints regarding the Services; and
- Comply with our legal obligations, protect or defend our rights, resolve disputes, and enforce our contracts.
When you use or visit the Services, we may collect information about your usage and activity using cookies, web beacons, and other technologies. Third parties may also view, edit, or set their own cookies. We and our third-party service providers, affiliates, and other business partners may also place web beacons for these third parties. The use of these technologies by third parties is subject to their own privacy policies and is not covered by this Policy, except as required by law.
YOUR CHOICES AND RIGHTS
Email. If you no longer want to receive marketing and promotional emails from us, you may click on the “unsubscribe” link in such emails to opt out of future marketing email communications. If you have a service account, you may also opt out of marketing emails in your account settings. Please note that even if you opt out of receiving marketing communications from one or all of our Services, we will still send you service-related communications, such as information related to service transactions.
Push Notifications (on Mobile Devices). You can use the settings on your mobile device to enable or turn off mobile push notifications from us.
Text Messages. If you no longer want to receive text messages from us, reply STOP (or as otherwise instructed) to the text message. If you have a service account, you may also adjust your account settings to opt out of text messages.
Application Location. As explained in more detail in the Information We Collect and Use section above, we may collect information about your location if you enable location services through the settings in your mobile device, or with your consent, as may be required by law. You can change the privacy settings of your device at any time to turn off the sharing of this location information with our Services. If you choose to turn off location services, this could affect certain features of our Services. If you have specific questions about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.
Sharing with third parties. As described above in the How We Share Your Information section, we share your information with third parties for their own purposes or work with those partners to support their own marketing purposes. We may provide you the opportunity to opt out of sharing your information with:
- Our Group Companies, for their own business purposes; and
- Service Partners, for their own marketing purposes (including sending marketing communications and providing targeted advertising, promotions, and other offers).
Access and Correction of Your Information. If you have created an online account with us and would like to update the information you have provided to us, you can access your account to view and update your information. You may also contact us as described in the How to Contact Us section below.
Legal Rights. Where applicable under local law, you may have the following rights regarding your personal information: the right to access personal information we hold, and in some situations, the right to have that personal information corrected or updated, erased, restricted, or delivered to you or a third party in a usable electronic format (the right to data portability). Where applicable, you may also object to how we use your personal information if the legal basis for processing that information is our legitimate interest. Where we are using your personal information on the basis of your consent, and where applicable under local law, you have the right to withdraw that consent at any time. Where you have granted consent to receive direct marketing communications from us, and where applicable under local law, you may withdraw that consent at any time.
If you wish to exercise the legal rights you may have under applicable law, please submit your request by emailing email@example.com. So that we can better process your request, please provide the email you use to log into your service account. If you do not have a service account, please provide the email you used to make requests or to use our Services.
We will not discriminate against you for exercising any of your rights under applicable law. Unless permitted under applicable law, we will not deny you any goods or services; charge you different prices or rates for goods or services; provide you a different quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that our denial of your rights for reasons mandated or permitted by applicable law is not considered discriminatory.
LINKS TO OTHER WEBSITES
Our Services contain links to other websites or services that are not owned or controlled by us, including links to websites of Service Partners and our advertisers, our Group Companies, and other business partners. This Policy only applies to information collected by our Services. We have no control over these third-party websites, and your use of third-party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our Services, including those of our Group Companies. Your use of third parties’ websites linked to our Services is at your own risk, so we encourage you to read the privacy policies of any linked third-party websites when you leave one of our Services.
We disclaim any and all rights and/or interest in any of the products, services, brands, descriptions, trademarks, and copyrighted material of third parties. Such information is that of the involved third party.
Our Services are not directed at or intended for use by children. We do not knowingly collect information from, children under 16 years of age. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at using the contact details listed in the How to Contact Us section below.
ADDITIONAL DISCLOSURES FOR CALIFORNIA CONSUMERS
Certain California consumers have enumerated rights pursuant to the California Consumer Privacy Act (CCPA). CCPA, and the rights such consumers have thereunder, applies to companies who meet certain criteria. The CCPA applies to for-profit businesses that do business in California and meet any of the following:
- Have a gross annual revenue of over $25 million;
- Buy, receive, or sell the personal information of 50,000 or more California residents, households, or devices; or
- Derive 50% or more of their annual revenue from selling California residents’ personal information.
CCPA does not apply to the business activities of Benfinity LLC or Beneshop.
CHANGES TO THIS POLICY
HOW TO CONTACT US
If you have any questions about this Policy or the way in which your personal information has been used, please contact us using the below email address at: