Privacy Policy for Covr Financial Technologies, LLC

Effective date: March 26, 2020

Your privacy is important to us. This Privacy Policy explains the types of personal information collected about you by Covr Financial Technologies, LLC, and its parents, subsidiaries and/or affiliated companies (collectively, “Covr,” “we,” “our,” or “us”),  as well as how we use the information we collect; how we may share the information we collect; the security we employ to protect the information we collect; and how you may contact us and opt out of certain uses or sharing of your personal information in connection with our platform, website, and services (collectively hereinafter, “Services”). Personal information is information that identifies, describes, or is reasonably capable of being associated with or linked to, directly or indirectly, an individual.

TABLE OF CONTENTS

This table of contents provides a summary of this Privacy Policy. It is for your convenience only and intended only to help guide you. It should not be read as a complete presentation of all of the terms and conditions contained herein. We encourage you to review the entire Privacy Policy.

Scope of this Privacy Policy. This Privacy Policy applies to our collection, use, disclosure, and security of personal information in connection with our Services.

U.S. Use Only and International Transfers. You may not access or use our Services, or provide information to us, from outside of the United States of America. If you do, you acknowledge that your personal information will be sent to the U.S., where data protection and other laws may provide a less comprehensive or protective standard of protection than those in your country, and (b) you consent to your personal information being collected, processed, and transferred as set forth in this Privacy Policy and under U.S. law.

Children’s Privacy. Our Services are not designed or intended for use by children under the age of eighteen (18).

Modification. We reserve the right to modify this Privacy Policy at any time to reflect changes to our practices or the law.

Information We Collect. We may collect certain information about you.

How We Use Your Information. How we may use the information we collect about you.

How We May Share Your Information.  How we may share the information we collect about you with others.

How We Protect Your Information.  We use reasonable physical, technical, and administrative safeguards designed to protect the security of personal information that we collect.

Cookies, Google Analytics. We use cookies and Google Analytics.

Communications with You. How we may communicate with you and your right to opt-out.

Linked Sites. Our Services may be accessed through certain websites.

Your Rights, Including Rights in California and Nevada. Depending on where you live, you may have certain rights with respect to your information.

How to Contact Us. You may contact us regarding the collection, use, disclosure, or security of your personal information by one of the means provided below. In contacting us, we may ask you to provide additional information.

 

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to our collection of personal information of individuals in the United States in connection with our Services, whether collected directly from you or shared with us by another person or organization like a financial adviser, bank, credit union, or insurance broker.

Please review this Privacy Policy carefully. By accessing and using our Services, and/or by otherwise submitting information to us – for instance, when you establish an account – you signal your consent to the terms of this Privacy Policy. If you do not agree with any part of this Policy, please do not use our Services. Please review our Terms of Use, posted here. The Terms of Use describes the terms and conditions for use of our platform in connection with our Services.

 

U.S. USE ONLY AND INTERNATIONAL TRANSFERS

Our Services, including access to our platform, are not appropriate or intended to be available for use outside the United States, its territories, possessions, and protectorates (“U.S.”). Our Services are governed by and operated in accordance with U.S. law. If you are located outside of the U.S., and you access or use our Services, you do so at your own risk. If you access our platform from outside the U.S., you do so in violation of its Terms of Use.

Covr operates in the U.S. If you are outside of the U.S. when accessing or using our Services, it is necessary to transfer your personal information to and process in the U.S., where our central databases operate. By using our Services, you (a) acknowledge that the data protection and other laws of the U.S. may provide a less comprehensive or protective standard of protection than those in your country, and (b) you consent to your personal information being collected, processed, and transferred as set forth in this Privacy Policy and under U.S. law.

 

CHILDREN’S PRIVACY

Our Services, including our platform, are not designed to attract children aged thirteen (13) and under. Further, you must be 18 or older to use our Services. We do not seek, or knowingly collect, personal information from children aged of 18 and under unless such information is provided by their parents or legal guardians in connection with our Services.

 

MODIFICATION

We reserve the right to modify this Privacy Policy at any time to reflect changes to our practices or the law. We will make the revised Privacy Policy accessible through access to our Services. Please check this Policy periodically for updates. The date at the top of the Privacy Policy also tells you when it was last updated.

If we make material changes to the way we collect or use your information, you will be provided with appropriate notice, including by, but not limited to, posting the updated Privacy Policy on our platform, providing notice when you access our platform, and providing notice in accordance with applicable legal requirements. Any changes to this Privacy Policy will become effective when the revised Privacy Policy is posted. By continuing to use our platform and/or other Services following notice of any changes to this Privacy Policy, you acknowledge you have read and understand the updated Privacy Policy, and you understand that we will collect, use, and share information as stated therein.

INFORMATION WE COLLECT

Information You Give to Us. We collect personal information you choose to share with us when you use our Services, including our platform, to evaluate or purchase insurance products.  We collect information from you when you establish an account with us. Such information includes contact information, like your name, e-mail address, residential address, telephone number, date of birth, as well as username and password. We also may collect medical information from you when you seek to purchase an insurance product, as well as certain financial information, such as credit card information, which we will route to our payment processors in connection with the purchase of an insurance product. If you employ our Services through an agent or representative, such as a financial advisor, we may collect information that you authorize your agent or representative to share. We may collect research and feedback information from you through online forms and social media platforms, by e-mail, over the phone, by mail, or in surveys.

Other Information We Collect. We may collect personal information about you when you visit our Website at covrtech.com, including contact information if you request a demo or employment-related information if you seek a job with us. We may collect connection and usage information, like domain names, browsing activity, forms or fields you complete or partially complete, search terms, whether you open an e-mail, content you view and the duration. We may collect your information from service providers to render our Services, including medical review, research, promotion of administration, and fraud prevention. Service providers may use such information for their operational purposes in order to provide their services to us to enable us to operate and provide our Services.

We may aggregate this data to help improve platform or website experience for users. If you apply for employment with us, we will collect your information for hiring-related purposes.

Information We Collect from Third Parties.  We may collect information from third parties whom you authorize to share information, such as your financial advisor, or from APS retrieval sources for medical records, in connection with our Services.

 

HOW WE USE YOUR INFORMATION

We use the personal information we collect about you in connection with our Services, such as and for your application and/or purchase of an insurance product. If you apply for employment with us, we will use your information for hiring-related purposes. If you request a demo from us on our website, we will use your information to fulfill your request. We may use your information to allow you to establish an account, and for us to confirm your account with us, and to help enable you to use our Services. We may use your information to deliver materials or information to you, or to give you notice of and/or resolve any problems that may arise in connection with our Services. We may use your information to respond to inquiries made by you, or for other customer service related reasons. We may use your information to provide you with information about our other Services to better understand your needs. We may use your information to improve the quality and/or your personal experience on our website or platform, and/or to analyze the success of our Services.

We may use your information to comply with applicable law; to detect or prevent fraud (financial or otherwise), infringement, potential misuse of our Services, or breach of our platform’s or website’s Terms of Use. We may use your information to manage third-party risks or other risks to our business, or to protect the reputation of our businesses. We may anonymize, aggregate or combine information we collect online or elsewhere for the above purposes or other purposes, to improve our Services, to develop new services, and/or to analyze statistics on usage and trends. Please note that aggregated or de-identified data may not constitute personal information.

 

HOW WE MAY SHARE YOUR INFORMATION

We may share the information we collect about you for business operations and in order to perform our Services for you. For instance, we may share your information with insurance carriers whose products you wish to purchase. We may obtain your information from service providers to render our Services, including medical review, research, promotion of administration, and fraud prevention. Service providers may use such information for their operational purposes in order to provide their services to us to enable us to operate and provide our Services.

We may share information we collect, as appropriate, with law enforcement to protect and enforce the legal rights, privacy, and safety of us or other users of our Services; to protect against possible fraud or other illegal activity; to respond to requests from government and other authorities; and/or to comply with legal processes.

In the event that Covr or an affiliate is involved in a merger, acquisition, transfer of control, bankruptcy, reorganization or sale of assets, or diligence associated with such matters, we may sell or transfer the information described in this Privacy Policy as part of that transaction.

 

HOW WE PROTECT YOUR INFORMATION

We employ reasonable physical, technical, and administrative safeguards designed to protect the security of personal information that we collect in connection with our Website and our Services. These safeguards vary depending upon a variety of factors including the sensitivity of the information we collect and use. Despite all reasonable practices, no security method is infallible. We cannot guarantee the security of the networks, systems, servers, devices, and databases we operate, that are operated on our behalf, or which you employ to access our Website and our Services. Nor can we guarantee the security of third-party networks, including cellular networks and storage servers, used in connection with our Website and our Services.

Your Passwords. You may be asked to generate a password when you create an account with us. You are responsible for maintaining the confidentiality of your password. We are not be liable for any loss that you may incur as a result of someone else using your password. You may not share your password. Please see our Terms of Use for requirements and prohibitions regarding your password.

If you believe that the security of any account you might have with us has been compromised, please e-mail us at [email protected].

 

COOKIES, USE OF GOOGLE ANALYTICS, “DO NOT TRACK”

Our platform and website do not use cookies, which are small data files sent to your computer on the basis of the information that we have collected about your visit.

Our Website employs Google Analytics, a web analytics tool provided by Google, Inc. (“Google”) that helps website owners understand how visitors engage with their websites. We can view a variety of reports about how visitors interact with our Website so we can improve it. Google Analytics collects information anonymously. Google uses cookies, and IP addresses, and it reports website trends without identifying individual visitors. In the event a visitor to the Website voluntarily submits contact information to Google, Google may then associate such information with the applicable IP address to enable us to see that visitor’s specific interactions with our Website.

You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-On. For information about and to install Google Analytics Opt-out Browser Add-on, click here.

Do Not Track Signals

Certain web browsers provide users with an option by which you may have your browser send a “Do Not Track” signal to websites that you are visiting, advising the recipient websites that you do not want to have your online activity tracked. However, the way browsers communicate such “Do Not Track” signals is not yet uniform and, accordingly, our website does not take any action in response to such signals. In the event a final standard is developed and accepted, we may reassess how we should respond to such signals.

 

COMMUNICATIONS WITH YOU

Our Communications with You

We may use your personal information to contact you via direct postal mail and/or electronically to the extent such activity is permitted by law. This information may be used to help us and our commercial partners, co-sponsors and service providers deliver information to you, and for other purposes as are reasonably necessary to provide the services requested by you. You may opt out of receiving future mailings or other messages from us by following the instructions in the e-mail or other message you receive from us or by following the instructions set forth in the Opting In and Opting Out of Electronic Communications immediately below.

Opting In and Opting Out of Electronic Communications

At certain points where Personal Information is collected on our Website, there may be a box to indicate that you wish to receive certain information or communications from Covr. You may opt out of receiving electronic communications, such as e-mails from Covr at any time. In all of our electronic communications you will be given the opportunity to opt-out of receiving future communications.

You may also opt out or change your preferences by providing opt-out instructions – e.g. sending an e-mail to our Privacy Officer or by postal mail as provided below:

• Postal Mail: 401 W Front Street, Ste. 500, Boise ID 83702
• E-mail Privacy: [email protected]

Be sure to include the contact information we are using to communicate with you, such as your e-mail address, and let us know the specific types of communications you no longer wish to receive.

 

LINKED WEBSITES

You may access our platform from a third-party website (i.e., a website owned or operated by another entity, such as a bank or credit union) (“Linked Sites”). Any such linking should not be construed as an endorsement by Covr. Linked Sites are not controlled by Covr; nor are they governed by this Privacy Policy. This Privacy Policy governs only personal information collected by Covr in connection with its Services. When visiting third-party websites, including Linked Sites, we encourage users to review the privacy policy governing such site.

 

YOUR RIGHTS, INCLUDING RIGHTS IN CALIFORNIA AND NEVADA

If you have a question or would like to access and correct your personal information that you submitted to us when establishing your account, you may access, change, or delete the personal information in your account at any time by accessing your account.

If you prefer that we do not share personal information about you with our affiliates, or to nonaffiliated third parties, for marketing purposes, except as otherwise permitted or required by law, you may direct us not to do so by contacting us in the manners provided below. If you prefer that we do not direct market to you via our affiliates and nonaffiliated third parties through e-mail, postal mail, and/or telemarketing, you may direct us not to do so by contacting us in the manners provided below, or by sending a request by mail to the address below.

• Postal Mail: 401 W Front Street, Ste 500, Boise ID 83702
• E-mail Privacy: [email protected]
• Toll-free Number 844-430-2687

Depending on where you live, you may have certain rights with respect to your information. Please note that you may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request.  In such a case, your request may not be fulfilled.

Rights of California Residents.  California residents with rights under the California Consumer Privacy Act (“CCPA”), or their authorized agents, may click here to learn those rights and make for access or deletion requests.

Do Not Sell My Personal Information. California residents may opt out of the “sale” of their personal information. Covr does not sell your information.

Rights of Nevada Residents.  Residents of Nevada may learn about their rights here.

 

CONTACT US

For any questions or complaints about this Privacy Policy or our privacy practices, please contact us at:

Postal Mail: 401 W Front Street, Ste 500, Boise ID 83702

E-mail Privacy: [email protected]

 

 

Privacy Policy for California Residents

This Privacy Policy is for California Residents (the “California Policy”) and supplements the information contained in our main Policy. This California Policy explains the personal information we collect or process about California residents in connection with our Website and our Services, how we use, share, and protect that personal information, and what your rights are with respect to your personal information that we gather and process. This policy only applies to consumers who access or use our Website and/or our Services and who are California residents.  We adopt this California Policy to comply with the California Consumer Privacy Act of 2018 (CCPA) and other California privacy laws. Any terms defined in CCPA have the same meaning when used in this Policy, including the term “personal information,” which means “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 does not include information that has been de-identified or aggregated.”

You may review a .pdf version of this California Policy here.

 

Personal Information We Collect and Share, and for What Purpose

In the past 12 months, we may have collected and shared the following categories of personal information from or about users of our Website or Services.

We may also use or share de-identified information that is not reasonably likely to identify you for commercially legitimate business purposes.

 

Personal Information We Collect and Have Sold – Do Not Sell My Personal Information

California residents may opt out of the “sale” of their personal information. We do not sell your information under CCPA.

We obtain information from third parties, such as paramedical examiners, who in turn received such information from you, in connection with the application process for life insurance. Carriers may review lab results and APSs to determine eligibility for life insurance – disclosures that you have authorized as part of the application process.

Your Rights as a California Resident

Under CCPA, California residents have specific rights regarding their personal information as described below. These rights are subject to certain exceptions. We explain how you may exercise this right below.

1. The Right to Disclosure of Information. You have the right to request that we disclose certain information regarding our practices with respect to personal information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction: (i) the categories of personal information we have collected about you in the last 12 months, (ii) the categories of sources for the personal information we have collected about you in the last 12 months, (iii) our business or commercial purpose for collecting that personal information, (iv) the categories of third parties with whom we share that personal information, and (v) the specific pieces of personal information we collected about you. In addition, if we sold your personal information or disclosed it to a third party for a business purpose, we will provide a list of the personal information types that each category of recipient purchased. We explain how you may exercise this right below.
2. Right to Deletion. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will determine if retaining the information is necessary for us or our service providers to:
   • Complete a transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you
   • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
   • Debug products to identify and repair errors that impair existing intended functionality.
   • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
   • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
   • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
   • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
   • Comply with a legal obligation; and/or
   • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If none of the above retention conditions apply, we will delete your personal information from our records and direct our service providers to do the same. We explain how you may exercise this right below. Please note that deletion of your information may affect your experience accessing or using our Website or Services.

3. Right to Opt-Out of the Sale of Your Personal Information. As a California resident, you have the right to direct a business that sells your personal information to third parties not to sell your personal information. This right is referred to as “the right to opt-out.” We explain how you may exercise this right below.
4. Right Against Discrimination. You may exercise your rights under the CCPA without discrimination. For example, unless the CCPA provides an exception, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or 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.

We may offer you financial incentives to provide us with personal information that is reasonably related to the information’s value. This could result in different prices, rates, or quality levels for our products or services. Any financial incentive we offer will be described in written terms that explain the material aspects of the financial incentive program. You must opt-in to any financial incentive program and may revoke your consent at any time by contacting us as indicated below.

 

How To Exercise Your Rights Under the CCPA

To submit general questions or requests regarding this Privacy Notice or our privacy practices, please contact us at [email protected].

To submit a verifiable request under the CCPA to access or delete your information, please visit our online request portal and fill in the form by visiting here.

Alternatively, you may call us at this number: 844-430-2687

Please note that you if you choose to make a CCPA request, we will require certain information in order to verify who you are, including your name, account information, address, and telephone number. This information will be requested via the webform.

 

Direct Marketing Lists – California Shine the Light Law

California residents can also request a list of all the third parties to which we have disclosed certain personal information (as defined by California’s Shine the Light law) during the preceding year for those third parties’ direct marketing purposes. California residents may contact us at 401 W Front Street, Ste. 500, Boise ID 83702

In the body of your request, you must include: “California Shine the Light Request”, your name, a current California address including, street address, city, state, and zip code, as well as sufficient information for us to determine if the law applies to you. You will need to attest to the fact that you are a California resident. We will not accept requests by telephone, e-mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

 

 

Nevada Residents

Covr does not engage in the following activity, however Nevada law requires us to post the following: Nevada consumers may opt out of the sale of “covered information” for monetary consideration to a person for that person to license or sell such information.  “Covered information” includes first and last name, address, e-mail address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.

If you are a Nevada resident who has purchased goods or services from Covr, You may submit a request to opt-out of any potential future sales under Nevada law by e-mailing us at [email protected]. Please use “Nevada Do Not Sell” in the subject line. Note we will take reasonable steps to verify your identity and the authenticity of the request.  Once verified, we will maintain your request in the event our practices change.