Assured Allies Privacy Policy

Collection and Use of Personal Information

Your privacy is important to us. This privacy policy (the “Privacy Policy”) describes how Assured Inc. and its affiliates (collectively, “us,” “we“, and “Assured Allies”) collect, use and disclose personal data that you submit through our various wellness programs (e.g., AgeAssured and NeverStop) and other offerings made available by Assured Allies (collectively, the “Offerings”).

This Privacy Policy operates in conjunction with Assured’s Terms of Service and the NeverStop Wellness Program Terms if applicable, which are incorporated herein by reference, and govern your use of the Offerings.

Personal information is data that can be used to identify or contact a single person.

You may be asked to provide your personal information anytime you are in contact with Assured Allies, and Assured Allies and its affiliates may share this personal information with each other and use it in a manner that is consistent with this Privacy Policy. We may also combine your information with other information to provide and improve our products, services and content. You are not required to provide the personal information that we have requested, but if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to queries you may have.

To better protect your privacy, we provide this notice explaining our privacy practices. If you do not agree to be bound by the terms in this Privacy Policy, you should cease submitting any personal data, and if necessary, cease use of our Offerings.

We may make changes to this Privacy Policy from time to time, and those changes will be posted on our Site. The amended Privacy Policy will be effective immediately upon posting, and your continued use of our Offerings will confirm your acceptance of the changes. If you do not agree to the amended Terms, you must stop accessing and using the Services. If any of these Terms shall be deemed invalid, void, or for any reason unenforceable, that Term shell be deemed severable and shall not affect the validity and enforceability of any remaining Term.

Here are some examples of the types of personal information Assured Allies may collect and how we may use it:

What personal information we collect and how we collect it

When you participate in our Offerings we may collect a variety of information from you, including without limitation, your name, mailing address, phone number, email address, contact preferences, device identifiers, IP address, or location information.

When you share your content with family and friends or invite others to participate in Assured Allies services or forums, Assured Allies may collect the information you provide about those people such as their names, mailing addresses, email addresses, and phone numbers. Assured Allies will use such information to fulfill your requests, provide the relevant Offering, or for anti-fraud purposes.

As we explain below, we collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, application program interfaces and web beacons, when you utilize any of our Offerings, whether or not you are logged in or registered.

How we use your personal information

We may process and disclose your personal information:

for the purposes described in this Privacy Policy,
for any purpose that you approved,
for compliance with a legal obligation to which Assured Allies is subject,
for the performance of a contract to which you are party,
to protect your vital interests, or
when we have assessed it is necessary for the purposes of the legitimate interests pursued by Assured Allies or a third party to whom it may be necessary to disclose information.

If you have questions about any legal basis noted in this Privacy Policy, you can contact us at [email protected].

In addition:

We use personal information for internal purposes, which include helping us create, develop, operate, deliver and improve our Offerings and content, to provide you with personalized content and experiences, to send you offers and promotions related to our Offerings, for loss prevention and anti-fraud purposes. We limit our uses of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our Offerings.
From time to time, we may use your personal information to send important notices, such as communications about changes to our terms, conditions and policies. Because this information is important for your interaction with Assured Allies, you may not opt out of receiving these communications.
The personal information we collect allows us to keep you posted on Assured Allies’s latest product announcements, service, and upcoming events. If you don’t want to be on our mailing list, you can opt-out anytime by emailing us at [email protected].
For research and development purposes, we may use datasets. When acquiring such datasets, we do so in accordance with applicable law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to identify individuals who may appear therein.
If you enter into a sweepstakes, contest, or similar promotion we may use the information you provide to administer those sweepstakes and contests.
If you apply for a position at Assured Allies or we receive your information in connection with a potential role at Assured Allies, we may use your information to evaluate your candidacy and to contact you.

Source of your personal information where they are not collected from you

We will either receive your personal information directly from you or from your insurance carrier. We may also acquire data from third-party vendors. When we do so, we comply with all applicable laws and regulations. We primarily use such information for research and development purposes.

Collection and Use of Non-Personal Information

We also collect and process data in an anonymized and aggregated form that does not, on its own, identify or associate with any specific individual. We may collect, use, transfer and disclose non-personal, aggregated and anonymized information for any purpose at our sole discretion.

Disclosure to Third Parties/Service Providers

While the majority of our usage of personal data is internal, from time to time Assured Allies may provide third parties with certain personal information to deliver our Offerings, to provide or improve upon our products and services, to carry out one or more of our programs, or to help Assured Allies market to consumers. When we do so, we require those third parties to process such personal data in accordance with applicable laws and regulations.

Without limiting the generality of the foregoing, Assured Allies also shares personal information with companies that provide services such as information processing, fulfilling customer orders, delivering products or information to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your personal information at all times.

More specifically, in the case of Assured’s NeverStop Wellness Program, Assured reserves the right to share data with insurance carriers and third party administrators to ensure that the credits you accrue while participating in the program are transmitted to such parties.

It may also be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities − for Assured Allies to disclose your personal information. We may also disclose information about you if we determine that for purposes of your safety, the safety of others, national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant purchaser/surviving entity.

Mobile Communications

By providing us with your mobile phone number, or by sending an SMS (containing a pre-designated number or word) to a phone number that we indicate, you are expressly opting-in to receive telephone calls to your mobile phone or text messages from us, some of which may be considered marketing and may be delivered by us using autodialer systems/technologies. You represent that you are the owner or authorized user of the mobile phone number that you supplied to us, and that you are authorized to approve the applicable charges and rates resulting from such SMS and/or MMS messages incurred by such device. Message and data rates may apply. You (and not Assured Allies) will be responsible for all messaging and data charges that may apply. Standard messaging rates apply to your entry or submission message to any Assured Allies text message service, our confirmation and all subsequent text message correspondence. Please contact your wireless carrier for information about your messaging and data plans. Your consent to receive text messages is not a condition of purchase. Carriers are not liable for delayed or undelivered messages. Message frequency may vary.

Data obtained from you in connection with our mobile marketing programs may include your cell phone number, your carrier’s name and the date/time/content of any text messages that you send us. We reserve the right to use this data in the same manner and for the same purpose(s) as other data that we may collect in accordance with this Privacy Policy, including without limitation, in order to provide the services you request of us, and to otherwise operate, develop and improve our products and services.

You can opt-out of receiving marketing-related text messages from us at any time by texting “STOP” (or some other SMS message designated by us) from the mobile device receiving the messages. If you choose to opt-out, you will be unsubscribed from our marketing text messaging program. You will receive one SMS that confirms you have successfully opted-out. After that you will receive no further messages for this system unless/until you opt-in again. For additional help, see our communication instructions below.

Please know that even if you opt-out of receiving marketing-oriented text messages from us, we may still contact you via text message or phone call for transactional or informational purposes regarding your enrollment and use of our Offerings. Some examples are contacts for customer service, product information, service or reminder notices. Moreover, we reserve the right, at all times, to disclose any mobile messaging data you share with us as necessary to satisfy any law, regulation or governmental requests, to avoid liability and/or to protect our rights or property.

Communications; Privacy Questions

You acknowledge and agree that Assured may communicate with you regarding your use of any of our Offerings by regular mail, electronic communications (email / SMS), telephone and any other means of communication described in our policy holder materials. The communications that we send you may include information regarding your participation as well as commercial advertisements and promotions. In addition to our unsubscribing instructions above regarding SMS messages, you may also opt-out of receiving marketing communications (via email or otherwise) by clicking on the unsubscribe link located the footer of each email message, by writing to us at [email protected], or by calling us at 1-866-727-7833. Even after you’ve opted out, you will continue to receive certain email communications that are not of an advertising or promotional nature.

If you have any questions or concerns about Assured Allies’ Privacy Policy or data processing and you would like to contact our Privacy Officer, or if you would like to file a complaint about a possible breach of local privacy laws, please contact us either by sending an email to [email protected] or by sending a letter to Assured Inc. 160 Gould Street, Suite 207, Needham, MA 02494, Attention: Chief Privacy Officer

When a privacy question or question about personal information received in response to an access/download request is received, we have a team which will address your issue. Where your issue may be more substantive in nature, we may request more information from you. All such substantive contacts will receive a response within seven (7) days wherever possible – providing a response on the issue raised, requesting additional information where necessary or indicating that a response will require additional time.

Children

Assured Allies does not knowingly collect Personal Data from children under the age of 18. If you are under the age of 18, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission.

Protection of Personal Information

The security, integrity, and confidentiality of your information are extremely important to us, and we take appropriate precautions to protect your personal data by implementing technical, administrative and physical security measures that are designed to protect your personal information from unauthorized access, disclosure, use and modification, and to comply with applicable laws and regulations. Although we have invested in leading-edge security software, systems and procedures, no security system is impenetrable. Accordingly, we will continually monitor the effectiveness of our security system and refine and upgrade our security technology as new tools become available. To make sure your personal information is secure, we communicate our privacy and security guidelines to Assured Allies employees and enforce privacy safeguards within the company. If you have any questions about the security measures we employ, please contact us by sending an email to [email protected].

Retention of Personal Information

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and/or as required by applicable law. When assessing these periods we carefully examine our need to collect personal information at all and if we establish a relevant need we only retain it for the period to realize the purpose of collection, unless a longer retention period is required by applicable law.

PHI

It is very likely that if you enroll in any of our programs and/or utilize any of our Offerings, Assured Allies will collect protected health information (aka, PHI), as defined under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and/or under appliable state laws. PHI is information that may identify you and that relates to your past, present, or future physical or mental health or condition, the provision of health care products and services to you or payment for such services. Set forth below is a summary of our assumed duties and privacy practices regarding PHI, namely, your rights with respect to your PHI, how we may use and disclose PHI about you, as well as how you obtain access to such PHI.

Treatment. We may use and disclose your PHI to provide and coordinate the treatment and services you receive. For example, we may disclose PHI to pharmacists, doctors, nurses, optometrists, and other personnel involved in your health care. This helps to coordinate your care and make sure that everyone who is involved in your care has the information that they need about you to meet your health care needs.

Healthcare Operations. We may use PHI to improve the Site, for marketing activities permitted under HIPAA (such as suggesting a health-related product that we make available to our Users, either on our Site or through personalized advertising based on your past purchases), and for our customer service activities, quality improvement, performance evaluation, and other internal business management purposes. We may use your PHI to create de-identified data, which is stripped of your identifiable data and no longer identifies you.

Business Associates. We may contract with third parties to perform certain services for us, such as billing services or consulting services. These third party service providers, referred to as Business Associates and/or Business Associate Subcontractors, may need to access your PHI to perform services for us and in such case we will use our best efforts to ensure they are required by contract and law to protect your PHI and only use and disclose it as necessary to perform their services for us.
To Communicate with Individuals Involved in Your Care or Payment for Your Care. We may disclose to a family member, other relative, close personal friend, or any other person you identify, PHI directly relevant to that person’s involvement in your care or payment related to your care. If a person has the authority by law to make health care decisions for you, we will generally regard that person as your “personal representative” and treat him or her the same way we would treat you with respect to your PHI.
Health Oversight Activities. We may disclose your PHI to an oversight agency for activities authorized by law. These oversight activities include audits, investigations, inspections, and credentialing, as necessary for licensure and for the government to monitor the health care system, government programs and compliance with civil rights laws.
Judicial and Administrative Proceedings. If you are involved in a lawsuit or a dispute, we may disclose your PHI in response to a court or administrative order. We may also disclose your PHI in response to a subpoena, discovery request, or other lawful process instituted by someone else involved in the dispute, but only if efforts have been made, either by the requesting party or us, to first tell you about the request or to obtain an order protecting the information requested.

Your Health Information Rights:

Inspect and obtain a copy of PHI. With a few exceptions, you have the right to access and obtain a copy of the PHI that we maintain about you. If we maintain an electronic health record containing your PHI, you have the right to request to obtain the PHI in an electronic format. To inspect or obtain a copy of your PHI, you must send a written request to [email protected]. You may ask us to send a copy of your PHI to other individuals or entities that you designate. We may deny your request to inspect and copy in certain limited circumstances. If you are denied access to your PHI, you may request that the denial be reviewed.

Request an amendment of PHI. If you feel that PHI we maintain about you is incomplete or incorrect, you may request that we amend it. To request an amendment, you must send a written request to [email protected]. You must include a reason that supports your request. If we deny your request for an amendment, we will provide you with a written explanation of why we denied it.

Receive an accounting of disclosures of PHI. With the exception of certain disclosures, you have a right to receive a list of the disclosures we have made of your PHI, in the six years prior to the date of your request, to entities or individuals other than you. To request an accounting, you must submit a request in writing to [email protected]. Your request must specify a time period.

Notification of a Breach. You have a right to be notified following a breach of your unsecured PHI, and we will notify you in accordance with applicable law.

Your Privacy Rights

We will provide you with access (including a copy) to the personal information we hold for any purpose including to request that we correct the data if it is inaccurate or to delete the data if Assured Allies is not required to retain it by law or for any legitimate business purpose. We may decline to process requests that are frivolous, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by law.

California / Delaware “Do Not Track Disclosures”

California and Delaware law require us to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. Assured Allies adheres to the standards set out in this Privacy Policy and does not monitor or respond to Do Not Track browser requests.

Third-Party Sites and Services

Assured Allies websites, products, applications, and services contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

International Transfers

We operate globally. As such, the information you provide us may be transferred to or accessed by our Israeli affiliate, which will comply fully with this Privacy Policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information.

Cookies

A cookie is a small text file that is stored in your web browser that allows Assured Allies or a third party (such as Assured Allies third party service providers) to recognize you. Cookies might be used for one or more of the following purposes: (1) to enable certain functions; (2) to provide analytics; (3) to store your preferences; and (4) to enable ad delivery and behavioral advertising. Cookies can either be session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or until you delete your cookies. Expiration dates are contained in the cookies themselves; some may expire after a few minutes while others may expire after multiple years. Cookies placed by the website you’re visiting are sometimes called “first party cookies,” while cookies placed by other companies are sometimes called “third party cookies.”

When you access and/or use the Site, Assured Allies or a third party may place a number of cookies in your browser. Some of the cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used.

Each cookie serves one of four different purposes:

Essential Cookies: These first party cookies allow users to use a feature of the Site such as: (i) staying logged in, or (ii) making purchases.
Analytics Cookies: These cookies track information about how the Site is being used so that we can make improvements and report on our performance. We may also use analytics cookies to test new ads, pages or features to see how users react to them. Analytics cookies may either be first party or third party cookies.
Preference Cookies: These first party cookies store your Site preferences.
Ad Targeting Cookies: These third party cookies (also known as “behavioral” or “targeted” advertising) are placed by advertising platforms or networks in order to: (i) deliver ads and tracks ad performance, and (ii) enable advertising networks to deliver ads that may be relevant based upon your activities.

We use additional technologies to help track user activities and preferences. For example, we use web beacons (also known as clear gifs, pixel tags or web bugs). Web beacons are tiny graphics (about the size of period) with a unique identifier that are embedded invisibly on web pages or emails. They are used to track user activities and communicate with cookies. You cannot opt out of web beacons used in webpages, but you can limit their use by opting out of the cookies they interact with. You can opt out of web beacons used in emails by setting your email client to render emails in text mode only.

We may set cookies that monitor links to our website that we send to you (if you have consented to receiving emails from us). These cookies are used to track visitors to our Site sourced from these emails. To avoid these type of cookies, please follow the explanation below on how to change your browser cookies settings.

We may also use a tracking technology (pixels) in emails to understand how often our emails are opened and clicked on by our customers. If you do not wish this tracking to be effected, please change your email software or service (such as outlook, Gmail etc.) settings to not automatically download images (to the extent it is not already your default). In some instances, depending on your email or browser settings, cookies in an email may be automatically accepted (for example, when you have added an email address to your address book or safe senders list). Please refer to your email browser or device instructions for more information on this.

In some of our email messages, we use a “click-through URL” linked to content on the Assured Allies Site. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our Site. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

Third party companies like analytics companies and ad networks generally use cookies to collect user information on an anonymous basis. They may use that information to build a profile of your activities on the Site and other websites that you have visited.

If you do not like the idea of cookies or certain types of cookies, you can change your browser’s settings to delete cookies that have already been set and to not accept new cookies. To learn more about how to do this, visit the help pages of your browser. Please note, however, that if you delete cookies or do not accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

Last Updated: November 2022