We recognize that the privacy of your personal information is important. The purpose of this policy is to let you know how we handle the information collected through the use of this Website. Portions of this Website may describe privacy practices applicable to specific types of information or to information provided on specific web pages.

As used in this policy, terms such as “we” or “our” and “Company” refer to eBenefits Network, LLC and its current and future affiliated entities.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.ebenefitsnetwork.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Website is intended for a United States audience. Any information you provide, including any personal information, will be transferred to and processed by a computer server located within the United States.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Cookies and Tracking

The Company uses various technologies, which may include “cookie” technology, to gather information from our website visitors such as pages visited and how often they are visited, and to enable certain features on this website. “Cookies” are small text files that may be placed on your computer when you visit a website or click on a URL. Cookies may include “single-session cookies” which generally record information during only a single visit to a website and then are erased, and “persistent” cookies which are generally stored on a computer unless or until they are deleted or are set to expire.

You may disable cookies and similar items by adjusting your browser preferences at any time; however, this may limit your ability to take advantage of all the features on this website. You may also manage the use of “flash” technologies, with the Flash management tools available at Adobe’s website. Note that we do not currently respond to web browser “Do Not Track” signals that provide a method to opt out of the collection of information about online activities over time and across third-party websites or online services because, among other reasons, there is no common definition of such signals and no industryaccepted standards for how such signals should be interpreted.

We may also allow third party service providers to use cookies and other technologies to collect information and to track browsing activity over time and across third party websites such as web browsers used to read our websites, which websites are referring traffic or linking to our websites, and to deliver targeted advertisements to you. We do not control these third party technologies and their use is governed by the privacy policies of third parties using such technologies.   choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising companies.

We may use analytics companies to gather information and aggregate data from our website visitors such as which pages are visited and how often they are visited, and to enable certain features on our websites. Information is captured using various technologies and may include cookies.

We may use and disclose your activity information unless restricted by this policy or by law. Some examples of the ways we use your activity information include:

• Customizing your experience on the website including managing and recording your preferences.
• Marketing, product development, and research purposes.
• Tracking resources and data accessed on the website.
• Developing reports regarding website usage, activity, and statistics.
• Assisting users experiencing website problems.
• Enabling certain functions and tools on this website.
• Tracking paths of visitors to this website and within this website.

Your personal information

This website may include web pages that give you the opportunity to provide us with personal information about yourself. You do not have to provide us with personal information if you do not want to; however, that may limit your ability to use certain functions of this website or to request certain services or information.

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, email address, telephone number, [social security number] [ or [OTHER PERSONAL INFORMATION CATEGORY COLLECTED]/any other identifier by which you may be contacted online or offline] (“personal information“)
• That is about you but individually does not identify you, such as [INFORMATION EXAMPLES]; and/or
• About your internet connection, the equipment you use to access our Website, and usage details. We collect this information:
• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies [web beacons,] [and other tracking technologies].
• [From third parties, for example, our business partners.]

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our website, [subscribing to our service,] [posting material,] [or requesting further services]. We may also ask you for information [when you enter a contest or promotion sponsored by us, and] when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• [Your responses to surveys that we might ask you to complete for research purposes.]
• [Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.]
• [Your search queries on the Website.]
• [ANY OTHER TYPES OF INFORMATION THE USER PROVIDES.]

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although [we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile], please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including [traffic data,] [location data,] [logs,] and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

[We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Click here [URL LINK TO DO NOT TRACK DISCLOSURES] for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.]

The information we collect automatically [does/may/is only statistical data and does not] include personal information [, [but/or] we may maintain it or associate it with personal information we collect in other ways or receive from third parties]. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

We may use personal information for a number of purposes such as:

• To respond to an email or request from you.
• To personalize the website for you.
• To process an application as requested by you.
• To administer surveys and promotions.
• To provide you with information that we believe may be useful to you, such as information about health products or services provided by us or other businesses.
• To perform analytics and to improve our products, websites, and advertising.
• To comply with applicable laws, regulations, and legal process.
• To protect someone’s health, safety, or welfare.
• To protect our rights, the rights of affiliates or related third parties, or take appropriate legal action, such as to enforce our Terms of Use.
• To keep a record of our transactions and communications.
• As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law.
• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may use personal information to contact you through any contact information you provide through this website, including any email address, telephone number, cell phone number, text message number, or fax number.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request. We may share personal information in response to a court order, subpoena, search warrant, law or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting activities that are illegal, violate our rules, or may be harmful to other visitors.

• To enforce or apply our Terms of Use [INSERT AS LINK TO WEBSITE’S TERMS OF USE] and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of eBenefits Network, LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We may also share personal information within the Company, and we may combine personal information that you provide us through this website with other information we have received from you, whether online or offline, or from other sources such as from our vendors. For example, if you have purchased a product or service from us, we may combine personal information you provide through this website with information regarding your receipt of the product or service.

Sharing personal information

We will only share your personal information with third parties as outlined in this policy and as otherwise permitted by law.

We may share personal information if all or part of the Company is sold, merged, dissolved, acquired, or in a similar transaction.

If you submit information or a posting to a chat room, bulletin board, or similar “chat” related portion of this website, the information you submit along with your screen name will be visible to all visitors, and such visitors may share with others. Therefore, please be thoughtful in what you write and understand that this information may become public.

We may also share personal information with other third-party companies that we collaborate with or hire to perform services on our behalf. For example, we may hire a company to help us send and manage email, and we might provide the company with your email address and certain other information in order for them to send you an email message on our behalf. Similarly, we may hire companies to host or operate some of our websites and related computers and software applications.

This website may permit you to view your visitor profile and related personal information and to request changes to such information. If this function is available, we will include a link on this website with a heading such as “My Profile” or similar words. Clicking on the link will take you to a page through which you may review your visitor profile and related personal information.

Our online communication practices.

We may send electronic newsletters, notification of account status, and other communications, such as marketing communications, on a periodic basis to various individuals and organizations. We may also send email communications regarding topics such as general health benefits, website updates, health conditions, and general health topics. We offer you appropriate consent mechanisms, such as opt-out, for marketing and certain other communications. As examples, you may opt-out as provided for in a specific email communication or contact us as described below in the section “Contact Us.” Please be aware that opt-outs may not apply to certain types of communications, such as account status, website updates, or other communications.

Information for children under 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at 703-970-9200..

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights for more information.

Contact us.

To contact us regarding this policy and our related privacy practices, please contact us at:

eBenefits Network, LLC Customer Service

9108 Church Street, STE 292

Manassas, VA 20108

If you believe we or any company associated with us has misused any of your information, please contact us immediately and report such misuse by calling Member Services at 800-788-5187 Ext 2 Effective date

The Effective Date of this Privacy Policy is January 01,2023

Changes to this Website Privacy Policy

We may change this policy. If we do so, such change will appear on this page of our website. We will also provide appropriate notice and choices to you, on this website and in other appropriate locations, based on the scope and extent of changes. You may always visit this policy to learn of any updates.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal      information.     To learn more about California residents’ privacy rights, visit https://oag.ca.gov/privacy/ccpa.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All data provided is encrypted at rest and in transit.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

 Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website, and we are not liable for the illegal acts of third parties such as criminal hackers.

 Social Security Number Protection Policy

Protecting personal information is important to eBenefits. It is our policy to protect the confidentiality of Social Security numbers (“SSNs”) that we receive or collect in the course of business. We secure the confidentiality of SSNs through various means, including physical, technical, and administrative safeguards that are designed to protect against unauthorized access. It is our policy to limit access to SSNs to that which is lawful, and to prohibit unlawful disclosure of SSNs.

Social Media Disclaimer

Are you using social media? So are we! We encourage you to read, share, follow us and provide commentary on Facebook®, and other social media sites. Before you post, please make sure you read our social media disclaimer:

We are under no obligation to screen or monitor your posts or any other User Content, however, we do make a reasonable effort to monitor participation to ensure that you stay on topic, are courteous and avoid making offensive comments. Your posts and User Content must adhere to the following requirements and cannot:

• Contain any third-party material including logos, drawings, tattoos, photographs, pictures, sculptures, paintings and other images or works of art, phrases, trademarks, trade secrets or other items without explicit prior written permission to use such materials.
• Contain sexually explicit, graphic, gratuitous or unnecessarily violent content or defamatory or derogatory content against any ethnic, racial, gender, religious, sexual orientation, professional or age group or contain any pornographic or nude material.
• Contain any private information about yourself or any other individual, including without limitation, information related to the health of the individual, financial information about the individual or any identification or account numbers related to the individual, with or without their permission or consent.
• Contain any software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software, hardware or telecommunications equipment.
• Contain any advertising, promotional materials, “junk mail”, “spam”, “chain letters”, “pyramid schemes”, or promote illegal activity and/or illegal contests, sweepstakes, gambling, including any online casino, sports books, bingo, poker or any other form of solicitation.

We reserve the right to edit comments for content, remove off-topic contributions, delete offensive comments or remarks, block offensive contributors and delete actual or suspected spam content from any Social Media site. Please be aware that once you post something online, there is the potential for numerous individuals to read your words, even years from now. Therefore, we suggest that you exercise caution when posting on any social media sites and that you not disclose personally identifiable information like your location, medical record number, personal medical information, financial information, etc. We are not responsible for the content of any comments or responses posted by others to any website or social media site managed or monitored by eBenefits. We do not control the placement of any marketing or advertising displayed on our pages by social media or third-party organizations.

We reserve the right to respond to any post or User Content and may occasionally privately request your contact information to assist offline with your consent by routing the matter to the appropriate persons or department for further handling. Any further questions about your account, claims or benefits or request for additional information can be addressed by visiting your member website or calling the toll-free member phone number on the back of your health plan ID card.

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