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Notice of collection and privacy notice

This Notice of Collection and Privacy Notice (the “Notice”), together with our Online Services Privacy and Security Practices (“Privacy Policy”), describes Wellabe Inc., and its affiliates’ (the “Company,” “we” or “us”) privacy practices with respect to personal information we collect, use, disclose, and share through both online and offline interactions with residents of Colorado, Delaware, New Jersey, Oregon, and Washington. This Notice also describes how you can exercise your privacy rights and provides additional details about our privacy practices related to your personal information as required by the applicable U.S. Privacy Laws in your state of residence. 

For residents in Oregon, the controller for purposes of this Notice are the following affiliated entities registered with the Oregon Secretary of State: American Republic Insurance Company, American Republic Corp Insurance Company, Medico Insurance Company, Medico Life and Health Insurance Company, Medico Corp Life Insurance Company, and Great Western Insurance Company.

For residents in Washington, we have also included additional disclosures about our privacy practices related to your health data at the end of this Notice. 

In this Notice, personal information has the meanings described below. You may be familiar with different terms that are used to describe materially similar concepts by the privacy laws in your state of residence. You can treat them as the same for the purpose of our Notice. For example, we intend the term “personal information” here to have the same definition as “personal data” used in specific U.S. Privacy Laws.

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 protected health information covered by the Health Insurance Portability and Accountability Act (“HIPAA”), nonpublic personal information under the Gramm-Leach-Bliley Act (“GLBA”), or any other information which is exempt from state or federal privacy rights. Personal information also does not include publicly available information or information that has been de-identified or aggregated.

Personal information we collect

We may collect, use, disclose, or share 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, Internet Protocol (IP) address, online account name and password, federal or state issued identification numbers including social security number, driver’s license number, passport number, or other government identification number, or other similar identifiers.

Financial information

This may include bank account number, credit card number, debit card number, or any other financial information.

Insurance information

This may include insurance policy number or health insurance 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).

Commercial information

This may include products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Geolocation information 

This may include physical location or movements when using our website or mobile applications. It may also include precise geolocation that is used or intended to be used to locate you within a small geographic area.

Internet or other similar network activity

This may include online identifiers, 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.

Inferences

This may include information drawn from any of the personal information listed above to create a profile or summary about an individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

Collection and purposes for processing your personal information

We, including our service providers and third parties, may collect, use, disclose, or share personal information about you for the following business purposes:

  • You direct us to collect, use, disclose, or share your personal information for a business purpose you request.
  • To verify your identity.
  • Supporting business operations, such as, administering and processing product applications and policies, paying claims, making policy changes, providing customer service support, product marketing and sales support, collecting financial information, processing transactions you have requested, are legally required, or that are necessary to administer our business, and other general business processes in the context of our relationship.
  • 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.
  • To administer surveys and promotions, conduct research, analytics, or data analysis.
  • 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.
  • 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, detect and prevent fraud, comply with law, legal process, and other 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.
  • As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law or for any other purpose with your consent.

We do not sell your personal information for any purpose.

We may have disclosed or shared the following categories of personal information to service providers and third parties for the business purposes listed above in the past twelve months:

  • Personal identifiers;
  • Insurance information;
  • Commercial information;
  • Internet or other similar network activity;
  • Sensory information; or

We only disclose or share your personal information with trusted service providers and third parties with whom we have a contractual relationship with and are obligated to safeguard and protect your personal information, subject to appropriate confidentiality and use restrictions.

Sources and recipients of personal information

We may collect from or use, disclose, or share your personal information to one or more of the following parties:

  • You directly, or other individuals acting on your 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.

Your personal information rights

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

  • Right to know: You have the right to request disclosure of the categories of personal information we have collected, used, disclosed, and shared about you covering the last 12-month period, including the categories of sources from which the personal information is collected, used, disclosed, or shared, and the business purpose.
  • Right to deletion: You may request that we delete any personal information we have about you.
  • Right to correction: You may request that we correct any inaccurate personal information we have about you. 
  • Right to an appeal: You may request an appeal to our decision of a consumer privacy rights request you have previously submitted.

We will not discriminate against you for exercising your privacy rights.

How to submit a consumer privacy rights request

You can exercise your privacy rights by submitting a consumer privacy rights request or by calling 800-228-6080. You may also authorize an agent to make a consumer privacy rights request on your behalf. In such instances, authorized agents may use the same methods as you to submit the request on your behalf. To be an authorized agent, the individual must be a natural person or business entity that you have authorized to act on your behalf, such as a power of attorney. For verification purposes, we will contact you for documentation showing they have permission to submit a request on your behalf. If we do not receive sufficient documentation, we will not accept the request.

Upon receipt of a request, we may require 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 privacy rights 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. In some instances, we may decline all or part of a consumer privacy rights request related to personal information exempt from the privacy laws.  We will describe the basis for the denial, including any conflict with federal or state law, unless prohibited from doing do by law. 

We do not charge a fee to process or respond to your verifiable consumer privacy rights 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 about you. 

Children

We do not knowingly collect or process personal information from children under the age of 18. If you learn that a child has provided us with personal information, you may contact us and ask us to remove content or data. Please note that your request does not ensure complete or comprehensive removal of the content or data as, for example, some of your content or data may have been reposted by another user.

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.

Washington health data disclosures

This section only applies to residents of Washington. We collect and share the below categories of health data from you, and we process such categories of health data for the purposes and in the manners listed below:

  • Individual health conditions, treatment, diseases, or diagnosis; 
  • Social, psychological, behavioral, and medical interventions; 
  • Health-related surgeries or procedures; 
  • Use or purchase of prescribed medication; 
  • Bodily functions, vital signs, symptoms, or measurements of health information; 
  • Diagnoses or diagnostic testing, treatment, or medication; 
  • Gender-affirming care information;
  • Reproductive or sexual health information; 
  • Genetic data; 
  • Precise location information that could reasonably indicate a resident’s attempt to acquire or receive health services or supplies; 
  • Data that identifies a resident seeking health care services; and 
  • Any inferences of the above categories of health data derived or extrapolated from nonhealthy information.

We may collect and share these categories of health data from the following sources and entities:

  • From you directly, or other individuals acting on your behalf, through physical, audible, or electronic sources. For example, information you have provided in your application for insurance coverage, during conversations with us or our representatives, or health coverage claim forms;
  • The Company’s legal representatives, sales agents, brokers, producers, funeral homes, and other similar business partners;
  • Health care providers, doctors, medical practitioners, hospitals, clinics, or other medical or medically related facilities or professionals;
  • Health plans, reinsurers, Pharmacy Benefit Managers (PBM), or the Medical Information Bureau (MIB);
  • 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; or
  • Business partners, service providers, and other third parties that perform services for us or for you.

You may exercise your data subject rights, including obtaining access to and requesting changes to your health data by contacting us via the methods listed in the Contacting us section of this Notice.

Contacting us

If you have any questions about our Notice, you may contact us by phone at 800-228-6080, email at customerservice@wellabe.com, 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 February 2025