Privacy Policy
Revised as of September 14, 2021
Privacy Policy
Marin Benefits, Inc. (“Company”, “we”, “us” or “our”) is committed to respecting your privacy. The following Privacy Policy describes how we collect, protect, use and share information we receive, including in person, by phone, through mail or email or through our website https://www.marinbenefits.com/, any other Company-owned and/or operated website, mobile sites, or social media accounts (collectively, our “Sites”). By accessing or using our Sites or otherwise disclosing information to Company, you consent to our collection, use, and sharing of your information in accordance with this Privacy Policy.
If you have questions about our Privacy Policy, our use of your information, or if you would like to change how we communicate with you, email support@marinbenefits.com.
WHAT INFORMATION DOES COMPANY COLLECT?
Information You Provide Directly to Us
We collect personal information you provide directly to us, for example, when you fill out a form on our site, pay a bill, request to be contacted by us or apply for employment. The types of information we may collect include:
-
Account Information. When you register for an account on the Sites, you will need to provide information through the WealthCare website portal. You will need to provide certain personal information to complete the registration, which may include your name, email address, mailing address, username, password, and phone number. Other information you provide as part of the registration process and the administration and personalization of your user experience, including information such as your gender, height, weight, age, and additional questions about your lifestyle, may be collected.
-
Transaction Information. We may collect and store information about the services you engage us for and your billing information, including transaction records and correspondence with you. We may also collect limited payment information from you, such as payment method and direct deposit bank account information.
-
Your Requests. We may collect personal information from you when you fill out a form for a specific request or otherwise choose to provide information through a “contact us” feature, for example, your name, address, email and phone number.
-
Online Forms. We may collect personal information from you when you fill out and submit an online form related to your account, including your name, address, email, phone number and additional details related to your account.
We may keep records and copies of your correspondence if you fill out a form or otherwise contact us through the Sites.
We may also collect from you your Protected Health Information, which is specifically regulated by Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). “Protected Health Information” is a subset of personal information that is information about you that may identify you and relates to your past, present or future physical or mental health or condition, related health care services or related to the past, present or future payment for the provision of health care to you. For a description of how we may use and disclose your Protected Health Information to carry out treatment, payment or health care operations and for other purposes that are permitted or required by law, including HIPAA, please refer to our HIPAA Notice of Privacy Practices (“HIPAA Notice”). Any conflict between this Privacy Policy and the HIPAA Notice with respect to such submitted Protected Health Information shall be governed by the HIPAA Notice.
Information We Collect Automatically
When you access or use the Sites, the types of information we may automatically collect about you include:
-
Usage Information. We may collect information about your usage of, and interaction with the Sites. For example, we may collect and store statistics and other information about the online activities of our users on an aggregated (collective) basis, including tracking the number of people who view each page to learn which features are the most popular.
-
Mobile Device Information. We collect information about the mobile device you use to access or use the Sites, including the hardware model, operating system and version, mobile network information and information about your use of our mobile applications. With your consent, we may access and collect information from certain native applications on your device (such as your device’s camera, photo album and phonebook applications) to facilitate your use of certain features of the Sites.
-
Location Information. With your permission, we may also collect information about the precise location of your device using methods that may include GPS, wireless networks, cell towers, and Wi-Fi access points.
-
Log Information. When you access or use the Sites, our servers may automatically record certain log file information, such as your Internet Protocol (“IP”) address, operating system, browser type and language, referring URLs, access times, pages viewed, links clicked and other information about your activities on the Site.
-
Information Collected by Cookies. We and our service providers use various tracking technologies, including cookies, to collect information about you when you interact with our Sites, including information about your browsing and purchasing behavior. Cookies are small data files stored on your hard drive or in device memory that help us improve the Sites and your experience, see which areas and features of the Sites are popular and count visits. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Sites.
Information We Collect From Third Parties
We may receive information that third parties provide us, which may include information about you. For example, we may collect information about you when you post content to our pages or feeds on third party social media sites. We may also receive information from your employer or insurance plan. This Privacy Policy does not apply to information collected through or by any third party. If you have any questions about such third parties’ privacy practices, you should review their privacy policies.
HOW DO WE USE COLLECTED INFORMATION?
We may use your information for various purposes related to our operations and your use of the Sites. For example, we may use your information to:
-
Provide, maintain and improve our Sites and provide you with relevant information and content, including subscriptions to our email list and newsletters.
-
Send you technical notices, updates, security alerts and support and administrative messages.
-
Respond to your comments, questions and requests and provide customer service.
-
Monitor and analyze trends, usage and activities in connection with our Sites.
-
Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Company and others.
-
Maintain appropriate records for internal administrative purposes.
-
To comply with legal and regulatory requirements, required disclosures and choices and controls that may be available.
-
To personalize online content and user experiences.
-
To perform operational functions in connection with our business, including data analysis, audits, developing and improving products and services, enhancing the Sites and identifying usage trends.
-
To process an employment application upon submission, or otherwise in connection with your interest in a career opportunity or your employment with us.
-
To deliver marketing materials or other advertising content to you.
-
Link or combine with information we get from others to help understand your needs and provide you with a better experience.
-
To diagnose problems with our services.
-
Carry out any other purpose described to you at the time the information was collected.
Aggregated and de-identified information that cannot reasonably be used to identify an individual, does not constitute personal information. Such de-identified and/or aggregated information which does not identify individuals is not subject to this Privacy Policy.
We may keep your information for as long as is necessary for our business purposes and to protect ourselves in the event of a legal claim.
WHO DO WE SHARE INFORMATION WITH?
We may share information about you as follows or as otherwise described in this Privacy Policy:
-
When you participate in the interactive areas of the Sites, certain information that you provide may be displayed to your health care providers, such as your name, content, health information and other information you choose to provide.
-
With partners, vendors, consultants and other service providers who need access to such information to carry out work or perform services on our behalf (including our third-party payment processor).
-
If you use the Sites as part of your relationship with your insurance provider or employer, certain information about your use of the Sites may be shared with your employer or insurance provider. For example, we may share personal information, eligibility information, and other information with your employer or insurance provider.
-
With third party businesses to provide you with information about products and services that may be useful to you.
-
In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, rule, regulation or legal process.
-
If we believe your actions are inconsistent with our Terms of Use or other policies, or to protect the rights, property or safety of Company or others.
-
In connection with, or during negotiations of, any merger, acquisition, sale of assets or any business, other change of control transaction or financing.
-
To comply with any court order, law or legal process, including to respond to any government or regulatory request.
-
To enforce any agreement we may have with you.
-
Between and among Company and any current or future parent, subsidiary and/or affiliated company.
-
With your consent or at your direction.
We also may share aggregated or de-identified information, which cannot reasonably be used to identify you and is not subject to this Privacy Policy.
THIRD-PARTY LINKS
In an attempt to provide you with increased value, we may include third-party links on our site. If you click on a third-party link, you will be directed to that third-party’s website. We have no control over these linked sites. Each of third-party site has its own separate and independent privacy policies and practices, including in connection with their use or disclosure of information you disclose to them. Company is not responsible or liable for the content of any third-party site, even if these sites reflect our branding. We encourage you to check the privacy policies of third-party sites before providing your information to them. The fact that we may link to a third-party site or present a banner ad or other type of advertisement from a third party is not an endorsement, authorization, or representation of any affiliation by us with that third-party, nor is it an endorsement of their privacy or information security policies or practices.
THIRD-PARTY ANALYTICS SERVICES
We may work with certain third parties to collect, analyze, and use some of the information described above. For example, we may allow third parties to set cookies or use web beacons on the Sites or in email communications from us. The information collected by third parties using these technologies may be used to engage in analysis and reporting. These third parties may set and access cookies on your computer or other device and may collect information about your online activities across different websites or services over time, including on websites and mobile applications that are not owned or operated by Company. In particular, the Sites may use Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt-out of the use of cookies in web browsers by Google Analytics by visiting Google’s website.
CHILDREN UNDER THE AGE OF 13
Our Site is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Site. We do not knowingly collect personal information from children under 13.
SECURITY
We use reasonable security measures designed to safeguard the personal information under our control from unauthorized access, use, and disclosure. Despite these measures, the confidentiality of any communication or material transmitted to or from us via the Sites by Internet or email cannot be guaranteed. Company encourages you to learn as much as you can about your privacy on the Internet.
Although we will take reasonable security precautions regarding your personal information collected from and stored on the Sites, because of the open nature of the Internet, we cannot guarantee that any of your personal information stored on our services or on those of our third parties, or transmitted to or from us, will be free from unauthorized access or disclosure. Accordingly, we disclaim any liability for any unauthorized access to, disclosure or damage to, interception of, theft, or loss of any data communications and/or personal information. By using the Sites, you acknowledge that you understand and agree to assume these risks.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) log-in credentials (including, but not limited to, passwords) for access to certain parts of the Sites, you are responsible for keeping these log-in credentials confidential. We ask you not to share your log-in credentials with anyone.
NOTICE TO INTERNATIONAL USERS
The Sites are hosted in the United States and are subject to U.S. law, and are intended for users located only in the U.S. If you are accessing the Sites from outside the United States, please be advised that U.S. law may not offer the same privacy protections as the laws of your jurisdiction. By accessing and using the Sites, you consent to the transfer to and processing of your personal information in the U.S.
CHANGES TO OUR PRIVACY POLICY
We will change, amend and update this Privacy Policy from time to time to reflect changes in our privacy practices, technology, products and services, general business operations and industry. In the event of any change to our policies, we will post a revised policy on our Sites with a revised date. We reserve the right to change, amend and update this Privacy Policy at any time in our sole and absolute discretion, and such changes will be effective upon posting of the revised policy. In the event of a material change in our information collection and use practices, we will provide more prominent notice of such change. You should check this Privacy Policy on a regular basis to ensure you have reviewed and are familiar with the most current policy.
CALIFORNIA RESIDENT PRIVACY RIGHTS
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. Subject to certain exceptions under California law, including exceptions that apply to Protected Health Information governed by HIPAA, California residents may have the following rights with respect to their personal information collected by Company:
-
The right to know and access. California residents have the right to request Company disclose (i) a copy of the personal information that we collect about you; (ii) the categories of personal information that we collected about you in the preceding 12 months; (iii) the purposes for which such personal information was collected, disclosed or sold in the preceding 12 months; (iv) the categories of sources from which the personal information was collected; and (v) the categories of third parties with whom such personal information may have been shared.
-
The right to deletion. California residents have the right to request that Company delete the personal information that we or our vendors collected about you. There may be circumstances under which we will be unable to delete your personal information, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected. If we are unable to comply with your request for deletion, we will let you know the reason why.
-
The right to equal service. If a California resident chooses to exercise any of these rights, Company will not discriminate against the California resident in any way. If a California resident exercises certain rights, such California resident may be unable to use or access certain features of the Sites.
Exercising California Resident Rights
If you are a California resident, to exercise any of these rights, contact us at 844-947-3845 or send your request to support@marinbenefits.com. In connection with submitting a request, you must provide the following information: name, email, phone number, address and employer or insurance carrier associated with (if applicable) and you must state what type of request you are making. You must also certify that you are a California resident.
Only a California resident, or someone legally authorized to act on such California resident’s behalf, may make a request related to his or her personal information. Company will take steps to verify your identity prior to processing your request, and we may ask for additional information from you that helps us with this verification.
In general, Company has the right to require you to provide written permission granting authority to your representative and for your agent to verify its identity directly with us, and we may deny a request from your representative who does not submit proof of authorization as we request.
Company cannot respond to a request or provide personal information if we cannot verify the identity or authority to make the request.
A California resident may only make a request for access or data portability twice within a 12-month period.
Any disclosures we provide will only cover the 12-month period preceding the request receipt date. If we deny a request, we will provide a response explaining the reasons we cannot comply with a request, if applicable.
Sharing of California Resident Personal Information
Company may have collected and disclosed the following categories of personal information from a California resident for a business purpose in the preceding 12 months:
-
Various identifiers, including, name, address, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
-
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including, telephone number or financial information.
-
Commercial information, including, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
-
Biometric information, including, behavioral characteristics, or activity patterns used to extract a template or other identifier or identifying information.
-
Internet or other similar network activity, including, browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement, including protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data in order to analyze trends in the aggregate and administer our Site.
-
Geolocation data, including, physical location or movements.
-
Sensory data, including, audio, electronic, visual, or similar information.
-
Professional or employment-related information, including, current or past job history or performance evaluations.
-
Educational information, including, transcript, student records, grades and performance, activities, school name or school ID.
-
Inferences drawn from other personal information, including, profile reflecting a person’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
-
Protected classification characteristics, including, race, color, national origin, marital status, sex, veteran or military status.
-
Personal records, such as, power of attorney, family history or power of attorney.
-
Information received from a government entity or other third party.
Company may collect the above categories of personal information directly from you, indirectly as you interact with our Sites, from or through other third party sources, including our customers or your employer or insurance carrier, or through email or other electronic messages between you and our Sites.
In the prior 12 months, Company may have disclosed the categories of personal information set forth above for one or more of the purposes set forth in this Privacy Policy, including disclosure to your employer or insurance carrier in connection with your use of the Sites and disclosure to a service provider or other third party of Company’s for a business purpose.
Sale of California Resident Personal Information
In the prior 12 months, Company has not sold personal Information of a California resident.
How We Respond to “Do Not Track” Signals
Some web browsers have “Do Not Track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. At present, the Sites do not respond to “Do Not Track” signals and consequently, the Sites will continue to collect information about you even if your browser’s “Do Not Track” feature is activated.
“Shine the Light” Law
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@marinbenefits.com.
NEVADA RESIDENT PRIVACY RIGHTS
Nevada residents may have certain rights to opt-out of sales of their personal information under Nevada Revised Statutes Chapter 603A. However, please note that Company does not currently sell data triggering this Nevada statute’s opt-out requirements. If you have questions with respect to this right, please contact support@marinbenefits.com.
CONTACT US
Contact us for any questions or concerns you may have regarding this Privacy Policy and our information and data collection and use practices at support@marinbenefits.com.
ACCESSIBILITY
We are committed to facilitating the accessibility of our Sites for all people with disabilities. To access this Privacy Policy in an alternative format, please contact us at support@marinbenefits.com or 844-947-3845.