CA PRIVACY NOTICE

Last Updated: 7/1/2023

Core V Solutions, Inc. dba Careington Benefit Solutions and its subsidiaries and affiliates (collectively "Careington," "we," "us," "our") work hard to build and maintain a relationship of trust with you. This California Privacy Notice (the "Privacy Notice") describes our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s), microsite(s), mobile website(s), and mobile applications (collectively, "Sites"), and information we collect from you or third parties through any other means to provide our services or perform other business activities (collectively, "Services"). This Privacy Notice only applies to residents of the State of California.

This Privacy Notice does not apply to information we collect from employees, job applicants, independent contractors, or their respective beneficiaries, dependents, or emergency contacts in our capacity as an employer or purchaser of independent contractor services. This Privacy Notice is subject to change. We encourage you to review this Privacy Notice frequently for any revisions or amendments. Unless otherwise stated, changes will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Sites or Services.

This Privacy Notice is a supplement to our Privacy Policy and you should review our Privacy Policy in its entirety.

INFORMATION WE COLLECT

Personal Information

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you ("Personal Information"), including:

  • Identifiers such as name, social security number, driver's license number, mailing address, service address, email addresses, phone numbers, fax numbers, account password, signatures, IP address;
  • Characteristics of protected classification under California or federal law such as gender, age, ethnicity, country of origin, religion, marital status;
  • Commercial information such as your account information and status, member benefits, purchase history, health insurance information, credit/debit card numbers and expiration date, checking account and routing numbers, check or credit/debit card images, and various demographic information such as the number and ages of children in your household, what language(s) you speak, membership in union;
  • Internet or other electronic network information such as browsing/search history, data collected by cookies and similar technologies;
  • Geolocation data such as approximate geographic location indicators from websites or mobile devices;
  • Audio, electronic, visual, thermal, olfactory, or similar information such as call recordings, chat transcripts;
  • Professional or employment-related information such as employer, job title;
  • Health information such as diagnoses and treatments;
  • Inferences drawn from other Personal Information or data that relate to your preferences, interests, characteristics, etc.; and
  • Categories of personal information described in Cal. Civ. Code § 1798.80 to the extent collected under another category of Personal Information or Sensitive Personal Information.

The types of Personal Information we collect about you may vary based on how you use our Sites and/or Services, and your relationship with us.

Some of the Personal Information we collect may be considered "Sensitive Personal Information" under applicable law. We collect the following types of Sensitive Personal Information:

  • Social Security Number
  • Account log-in information
  • Racial or ethnic origin
  • Religious or philosophical beliefs
  • Union membership
  • Personal Information collected and analyzed concerning your health

Business Information

We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, "Business Information"). This information is generally not considered Personal Information because it relates to a business.

Usage Data and Sites Activity

We automatically collect information in connection with the actions you take on our Sites or when using our Services ("Usage Data"). For example, each time you use our Sites, we automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within our Sites, and the duration of your visits to our Sites. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information under the category Internet or other electronic network information. If this information is not capable of being individually associated with you, we treat it as anonymous Usage Data. We may collect, use, and disclose Usage Data for any purpose without restriction.

Communication Recordings

We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

Deidentified Information

We may anonymize or aggregate Personal Information so that it is no longer capable of being associated with you in which case it will be considered "Deidentified Information". We will not attempt to reidentify you or any other person from Deidentified Information. We may use and disclose Deidentified Information for any purpose without restriction.

HOW WE USE AND DISCLOSE INFORMATION

Generally

We may use Personal Information for the following business purposes:

Processing Purpose Personal Information That May Be Used
Account creation, fulfillment, servicing and customer support: for example, to process applications, create customer accounts, allow customers to create online accounts and profiles, provide goods or services, keep customers informed about the status of their goods or services, respond to questions and address customers concerns, deliver updates, upgrades and product improvement information
  • Identifiers
  • Characteristics of protected classification under California or federal law
  • Commercial information
  • Internet or other electronic network information
  • Geolocation data (approximate)
  • Audio, electronic, visual, thermal, olfactory, or similar information
  • Professional or employment-related information
  • Health information
  • Inferences drawn from other Personal Information or data
  • Sensitive Personal Information (see below for details)
  • Categories of personal information described in Cal. Civ. Code § 1798.80 to the extent collected under another category of Personal Information or Sensitive Personal Information.
Marketing and market research: for example, to send communications and offers for our or third parties' products and services, including offers based on consumers' interests, personal and business characteristics and location; perform analytics for market and consumer research, trend analysis, financial analysis, and anonymization of personal information
  • Identifiers
  • Characteristics of protected classification under California or federal law
  • Commercial information
  • Internet or other electronic network information
  • Geolocation data (approximate)
  • Audio, electronic, visual, thermal, olfactory, or similar information
  • Professional or employment-related information
  • Inferences drawn from other Personal Information or data
  • Sensitive Personal Information (see below for details)
  • Categories of personal information described in Cal. Civ. Code § 1798.80 to the extent collected under another category of Personal Information or Sensitive Personal Information.
Surveys, promotional events, contests: for example, to administer surveys, polls, sweepstakes, contests, loyalty programs and other promotional events and contests
  • Identifiers
  • Characteristics of protected classification under California or federal law
  • Commercial information
  • Internet or other electronic network information
  • Geolocation data (approximate)
  • Professional or employment-related information
  • Inferences drawn from other Personal Information or data
  • Sensitive Personal Information (see below for details)
  • Categories of personal information described in Cal. Civ. Code § 1798.80 to the extent collected under another category of Personal Information or Sensitive Personal Information.
Other company communications: for example, to provide consumers with information that may be of interest such as company newsletters, announcements, reminders and technical service bulletins
  • Identifiers
  • Commercial information
  • Internet or other electronic network information
  • Geolocation data (approximate)
  • Professional or employment-related information
  • Health information
  • Inferences drawn from other Personal Information or data
Website use and analytics: for example, to provide you with access to and use of our Sites and Services; analyze consumers' use of our websites, including the use of third-party web analytics services, which may utilize automated technologies to collect data (such as email and IP addresses)
  • Identifiers
  • Characteristics of protected classification under California or federal law
  • Commercial information
  • Internet or other electronic network information
  • Geolocation data (approximate)
  • Audio, electronic, visual, thermal, olfactory, or similar information
  • Professional or employment-related information
  • Health information
  • Inferences drawn from other Personal Information or data
Eligibility and pricing: for example, to determine if consumers are eligible for certain products, services or offers and the pricing related to such offers
  • Identifiers
  • Professional or employment-related information
  • Health information
  • Inferences drawn from other Personal Information or data
  • Sensitive Personal Information (see below for details)
  • Categories of personal information described in Cal. Civ. Code § 1798.80 to the extent collected under another category of Personal Information or Sensitive Personal Information.
Product research: for example, to conduct research and analysis for maintaining, protecting, and developing services, increase and maintain the safety of our products and services
  • Identifiers
  • Characteristics of protected classification under California or federal law
  • Commercial information
  • Internet or other electronic network information
  • Geolocation data (approximate)
  • Audio, electronic, visual, thermal, olfactory, or similar information
  • Professional or employment-related information
  • Health information
  • Inferences drawn from other Personal Information or data
  • Sensitive Personal Information (see below for details)
  • Categories of personal information described in Cal. Civ. Code § 1798.80 to the extent collected under another category of Personal Information or Sensitive Personal Information.
Business operations: for example, to evaluate, develop, and improve business operations, products and services offered; business administration and other normal business activities
  • Identifiers
  • Characteristics of protected classification under California or federal law
  • Commercial information
  • Internet or other electronic network information
  • Geolocation data (approximate)
  • Audio, electronic, visual, thermal, olfactory, or similar information
  • Professional or employment-related information
  • Health information
  • Inferences drawn from other Personal Information or data
  • Sensitive Personal Information (see below for details)
  • Categories of personal information described in Cal. Civ. Code § 1798.80 to the extent collected under another category of Personal Information or Sensitive Personal Information.
Compliance: for example, to comply with applicable legal requirements, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others, prevent misuse
  • Identifiers
  • Characteristics of protected classification under California or federal law
  • Commercial information
  • Internet or other electronic network information
  • Geolocation data (approximate)
  • Audio, electronic, visual, thermal, olfactory, or similar information
  • Professional or employment-related information
  • Health information
  • Inferences drawn from other Personal Information or data
  • Sensitive Personal Information (see below for details)
  • Categories of personal information described in Cal. Civ. Code § 1798.80 to the extent collected under another category of Personal Information or Sensitive Personal Information.
Information security and fraud prevention: for example, to operate information security and anti-fraud programs
  • Identifiers
  • Characteristics of protected classification under California or federal law
  • Commercial information
  • Internet or other electronic network information
  • Geolocation data (approximate)
  • Audio, electronic, visual, thermal, olfactory, or similar information
  • Professional or employment-related information
  • Health information
  • Inferences drawn from other Personal Information or data
  • Sensitive Personal Information (see below for details)
  • Categories of personal information described in Cal. Civ. Code § 1798.80 to the extent collected under another category of Personal Information or Sensitive Personal Information.

We do not use Personal Information to engage in profiling with legal or similarly significant effects.

We also use Sensitive Personal Information specifically for the following purposes:

Sensitive Personal Information Type Purpose(s) of Processing
Social Security Number Confirm your identity
Verify eligibility for services
Prevent and investigate fraud
Account log-in information Provide access to our services to you through our online systems
Racial or ethnic origin Received and used in connection with providing our health-related services to you
Religious or philosophical beliefs Received and used in connection with providing our health-related services to you
Union membership Membership in a union could be inferred if you receive our services via union; however, we do not use the fact that person is a union member for any purpose other than to indicate the affiliation with the service provided via a union.
Personal Information collected and analyzed concerning your health Necessary to provide our health-related services to you
Prevent and investigate fraud

If you are a California resident, we do not use your Sensitive Personal Information for any purpose beyond those permitted by 11 Cal. Code of Regs. § 7027(m).

Reviews and Testimonials

If you provide a review or testimonial, we may post it publicly on our Sites or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.

Service Providers

We may provide your Personal Information to other businesses ("Service Providers") to provide services to us or on our behalf. Categories of service providers we use include:

  • Fulfillment and account servicing vendors, which help us provide products, services and information to you and service your account or benefits;
  • Payment processors, which help us to accept and process the payments for our products/services to you;
  • Marketing and communications vendors, which help us market and communicate about our products/services to/with you, and conduct promotions, surveys and other outreach campaigns;
  • Research and development vendors, which help us develop and improve our products and services;
  • Data and business analytics vendors, which help us collect, analyze and improve the accuracy of our data, and analyze and improve our Sites and Services such as by the recording and analysis of user behavior;
  • IT and network administration vendors, which provide services such as data storage and management, website hosting, and data and network security;
  • Professional service firms, which provide accounting, legal, design, and other professional services; and
  • General service providers, which help us with day-to-day business operations such as office support services, general business software application providers, print and mail services, staff augmentation services, courier services, facilities management, and document destruction.

Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information that we provide to them other than as specified by us. In the past twelve months we have disclosed each category of Personal Information to one or more Service Providers and have disclosed the following categories of Sensitive Personal Information to Service Providers for the purposes stated above: Social Security, driver's license, state identification card, or passport numbers; account log-in information; racial or ethnic origin; union membership; Personal Information collected and analyzed concerning your health.

Third-Party Selling and Sharing

We may share or sell your Personal Information, which may include Sensitive Personal Information, with other companies who do not provide services to us ("Third Parties") as explained below. For purposes of this Privacy Policy, when we use the words "share" or "sharing, we mean sharing for cross-context behavioral or targeted advertising.

Third Party Type(s) Sell or Share Categories of Personal Information Disclosed in Last 12 Months Purpose of Disclosure
Ad networks and social media companies Share
  • Identifiers
  • Internet or other electronic network information
  • Geolocation data (approximate)
  • Categories of personal information described in Cal. Civ. Code § 1798.80 to the extent collected under another category of Personal Information
 To market and advertise our goods and services.

Other Third-Party Disclosures

In the past twelve months, we have disclosed Personal Information to Third Parties for a business purpose that is not a sale or sharing (for cross-context behavioral or targeted advertising purposes) in the following scenarios:

Type of Third Party Personal Information Disclosed
Courts and governmental agencies
  • Identifiers
  • Commercial information
  • Health information
  • Sensitive Personal Information
  • Categories of personal information described in Cal. Civ. Code § 1798.80 to the extent collected under another category of Personal Information or Sensitive Personal Information.
Parties in litigation None
Purchasers or potential purchasers of our business assets None
Parties or potential parties to a merger or other business combination with us None

DATA RETENTION

We retain your Personal Information in accordance with our record retention policies which are informed by our legal, regulatory, tax, and/or accounting obligations as well as business needs. The term for which we retain each element of your Personal Information may be longer or shorter than the term we retain other elements, and the term for which we retain your Personal Information may differ from the term for which we retain other people's Personal Information depending on your relationship with us.

ADDITIONAL CONSUMER PRIVACY RIGHTS

As a resident of California you may have additional rights to access and control your Personal Information under your state's laws and our Privacy Policy including the right to request to opt out of the sale or sharing (for cross-context behavioral advertising purposes) of your Personal Information or to limit the use of your Sensitive Personal Information by using our webform. Exemptions may apply. Please see our Privacy Policy for more details.

CONTACT US

If you have any questions about our Sites, Services, or this Privacy Notice, please email us at [email protected], call us at (888) 585-8979, or send us a letter to the following address:

Careington Benefit Solutions
www.careington.com
7400 Gaylord Parkway
Frisco, TX 75034
(888) 585-8079
[email protected]