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Notice of collection and privacy notice

This California Notice of Collection and Privacy Notice (the “Notice”) describes Wellabe Inc., and its affiliates’ (the “Company,” “we” or “us”) privacy practices with respect to personal information we collect or obtain about California residents that are covered by the California Consumer Privacy Act and California Privacy Rights Act (collectively, the “CCPA”). This Notice applies to California residents and is being provided to inform you of the categories of personal information we may collect and the purposes for which we collect that information. In this Notice, personal information has the meanings described below.

Personal information is defined as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, for example, information collected directly from you if you use certain services available on our sites or personal information that you voluntarily provide, such as information you provide to request a free quote, or if you apply for a job on our Careers site, or to do business with us. Personal information does not include publicly available information, information that has been de-identified or aggregated, or other information covered by certain sector-specific privacy laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Gramm-Leach-Bliley Act ("GLBA").

Personal information we collect

We may collect, use, or disclose the following categories of personal information:

Personal identifiers

This may include full name, date of birth, physical address, email address, phone number, emergency contact details, online account name and password, insurance policy number, Internet Protocol (IP) address, federal or state issued identification numbers including Social Security number, driver’s license number, passport number, or other government identification number, or financial account information.

Characteristics of protected classes

This may include age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Professional or employment-related information 

If you apply for a job on our Careers site or you are an employee who resides in California, this may include your employment and education history, position applied for, information relating to your compensation, benefits, information from background checks or references, information relating to your performance evaluations, and other information that may be provided on your resume.

Commercial information

This may include vehicle VIN number or vehicle license plate number.

Geolocation information 

This may include physical location or movements when using our website or mobile applications. For employees, this may include device location from your company-owned devices, or your mobile device when used to access company email.

Internet or other similar network activity

This may include browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement.

Sensory information

This may include audio, electronic, or visual information, such as call recordings, or audio-visual information when collected in the context of your employment relationship.

What we do with your personal information

We may collect, use, or disclose personal information about you for the following business purposes:

  • You direct us to collect, use, and/or disclose your personal information for a business purpose you request.
  • Marketing products and services to you, providing insurance product quote information, or information collected or used to determine what products and services you may be interested in, or conducting data analytics.
  • Enhancing your website experience with us, such as, identifying website visits, ad interaction and search history, recommending insurance products, tailoring your experience on our website and identify the products you may be interested in.
  • Applying for employment or an internship, including for screenings, processing employment applications, interviews, and performing background checks.
  • Administering pay and compensation activities, employee benefits, health insurance, training and education, or workforce management and planning. 
  • Supporting business operations, such as, product marketing and sales support, administering and processing product applications and policies, collecting financial information, providing customer service support, and other general business processes in the context of our relationship.
  • Managing vendors, contractors, and business partners, such as, administering proposals, conducting due diligence, monitoring contract compliance, communicating about projects, systems, problems, and other matters relevant to the relationship.
  • IT and systems operations, maintenance, security, risk management, audits, and legal and regulatory compliance.
  • Fulfilling financial reporting, tax and other government filing requirements.
  • Conducting, managing, maintaining, and improving our products and services, business operations, systems and databases, and security and privacy practices.

We do not sell your personal information for any purpose.

Sources and recipients of personal information

We may collect and/or disclose your personal information from or to one or more of the following parties:

  • California residents directly, or other individuals acting on their behalf, through physical (e.g., paper application), audible (e.g., phone), or electronic (e.g., website, social media) sources.
  • Public records or widely available sources, including information from the media, and other records and information that are made available by federal, state, or local government entities.
  • Government agencies including to support regulatory and legal requirements.
  • Data providers, digital marketing providers, or other marketing providers, such as, data/lead generators and aggregators.
  • Business partners, service providers, and other third parties that perform services for us or for you, or to market our products and services to you.
  • Sales agents, brokers, producers, funeral homes, marketers, prospective recruits, and other similar business partners.
  • Human resource vendors for background checks, recruiting, insurance benefits, travel companies, and other similar vendors,
  • California residents who are employees, job applicants, and/or independent contractors.

All information disclosed for business purposes is subject to appropriate confidentiality and use restrictions.

Your personal information rights

Subject to legal limitations and exceptions, you may be able to exercise some or all of the following rights:

  • Request disclosure of the personal information we have collected, used, and disclosed about you covering the 12-month period prior to your request.
  • Request we correct inaccurate personal information. 
  • Request deletion of personal information. 
  • Opt out of the sale of personal information.
  • Not receive discriminatory treatment for exercising your privacy rights.

How to submit a disclosure, correction, or deletion request

You can make a request by emailing privacy@wellabe.comor calling 800-228-6080.

Please describe your request and provide your full name, physical address, mailing address (if different than your physical address), email address, and phone number. If you are an applicant or current employee, please provide the recruiter’s name, or supervisor and/or manager’s name. 

We will review the information provided and may request additional information to respond to your request or to verify your identity. To verify your identity, we will attempt to match information that you provide in your request with sources of information we have collected to reasonably verify your identity.

Responding to requests

We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. We In some instances, we may decline all or part of a disclosure or deletion request related to personal information exempt from CCPA.  We will describe the basis for the denial, including any conflict with federal or state law, or exception to the CCPA, unless prohibited from doing do by law. 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Opt-out

We do not offer an opt out from the sale of personal information because we do not and have not within the last 12 months sold personal information that is subject to CCPA. 

Authorized agent requests

You are allowed to designate an authorized agent to make a rights request on your behalf. Your authorized agent may submit such a request by following the same method described above. We may require verification of your authorized agent in addition to the information for verification above.

Children

We do not knowingly collect or sell personal information from children under the age of 16. If you learn that a child has provided us with personal information, you may contact us at the email address provided in the Contact us section.

Changes to this notice

We may change or update this Notice periodically. When we do, we will post the revised Notice on this webpage indicating when the Notice was last updated.

Retention of personal information

We will retain your personal information collected as long as is reasonably necessary to fulfill the purposes for which it was collected. In doing so, we will consider the type of products and services requested by or provided to you, the nature and length of our relationship with you or the business entity you are associated with, and mandatory retention periods under applicable law. We will also retain your information, including after your relationship with us ends, as long as necessary to enforce or comply with our legal or contractual rights and obligations, to resolve disputes and defend claims, and to reserve our legal rights.

Contacting us

If you have any questions about our Notice, you may contact us by phone at 800-228-6080, or by sending a letter via U.S. mail to:

Wellabe, Inc.

Attn: Privacy Officer
 P.O. Box 10386
 Des Moines, IA 50306-0386
800-228-6080

 

Last published June 2023