Safeguards Maintained by NCD to Protect Your Personally Identifiable and Protected Health Information
We make every effort to protect your Personally Identifiable Information and Protected Health Information. NCD protects your Personally Identifiable Information and your Protected Health Information by maintaining physical, electronic, and procedural safeguards that protect such information, including data encryption, usernames and passwords, and other security tools.
Disclosure and Use of Your Protected Health Information and, Personally Identifiable Information
Protected Health Information. Because we are a business associate of certain health insurers and group health plans, we are subject to many of the privacy and security requirements of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). NCD protects your Protected Health Information as required by HIPAA and NCD will not disclose Protected Health Information that you provide via the Website (e.g. information provided on an application or in connection with a policy or a claim) unless one or more of the following conditions
• We receive your prior written authorization. Answers to questions about your medical history and physical condition are required by our insurance carrier partners and will be released to the insurer so that they may underwrite your insurance application. NCD will not give or sell such information about you to any other company, individual, or group without your prior authorization.
• We verify that the prospective recipient is you or your authorized representative.
• We are required by law to disclose the information.
• The disclosure is permitted under HIPAA.
Information and Personally Identifiable Information. NCD only uses Information, including Personally Identifiable Information, as allowed by law and as described herein. NCD protects your Personally Identifiable Information by, for example:
• Not disclosing Personally Identifiable Information about you to anyone, except as permitted by law.
• Restricting access to your Personally Identifiable Information to authorized individuals who need to know this information
in order to provide services and/or products to you.
• Not allowing employees to share your Personally Identifiable Information outside NCD except as authorized by you or for a
specific business purpose.
The law permits us to share certain Information with (i) our affiliates, (ii) non-affiliate insurance companies, group health
plans and insurance service providers, and (iii) companies that perform marketing services for us (including, without limitation,
licensed insurance agents and/or brokers). We will share such Information only as permitted by law, and this Information may or
may not include Personally Identifiable Information and/or Protected Health Information and may or may not be directly related to
our transaction with you.
NCD will use Information about you to help us better serve your insurance needs or to suggest NCD services or insurance materials that may be of interest to you.
We may share your Information, which may or may not include Protected Health Information, as permitted by law, among insurance companies, including for routine business administration. As permitted by law, we may share Information, which may or may not include Protected Health Information, with non-affiliated companies such as firms that perform services on our behalf, including the administration and marketing of our products. We require these companies to meet strict privacy standards.
We may enter into alliances, partnerships or other business arrangements with third parties who may be given access to Personally Identifiable Information including your name, address, telephone number and e-mail for the purpose of providing you information regarding products and services that we think will be of interest to you.
In connection with alliances, partnerships or arrangements, we may also provide certain information to third parties if we have determined that the information will be used in a responsible manner by a responsible third party. We also use third parties to facilitate our business, including, but not limited to, sending e-mail and processing credit card payments. In connection with these offerings and business operations, our partners and other third parties may have access to your Personally Identifiable Information for use in connection with such business activities.
If you choose to send us an e-mail, we will do our best to respond to your request in a timely manner. We may use return e-mail addresses you provide to send e-mails and to answer the e-mail we receive. We may forward your request on to third parties in situations where we cannot answer your question and may also respond to your e-mail with offers or correspondence which we believe may be relevant to you. If you choose to give us Personally Identifiable Information such as your zip code, e-mail, contact information, etc., we may share this information with third parties to help answer your questions or fulfill your request. We reserve the right to use such data provided to us for any legally permissible purpose. We may use our e-mail lists for sending newsletters and other NCD outbound communications, such as product information.
Our management team uses non-personally identifiable information to improve the user experience for all Website visitors. We may analyze site usage statistics to do things such as update our content, alter our navigation, or otherwise customize our site to better serve our visitors.
Though we will make every effort to preserve user privacy, we may need to disclose Personally Identifiable Information when required by law, or if we have a good-faith belief that the action is necessary to comply with a pending judicial proceeding, a court order or legal process served on NCD or to protect our rights or the rights of others, to fight fraud, identity theft, to ensure the integrity and operation of our organization and systems, or to protect the rights, property or safety of NCD, its employees, members or others.
including your Personally Identifiable Information and your Protected Health Information.
The Personally Identifiable Information and Protected Health Information you submit to us through the Website may be processed by us in the country where it was collected as well as other countries (including the United States) where laws regarding the processing of such information may be less stringent than the laws in your country.
Categories of Information That We Collect
Certain materials and information provided by NCD on the Website is available without NCD collecting any Personally Identifiable Information from you. However, NCD does collect Personally Identifiable Information and/or Protected Health Information that you provide voluntarily during the course of using the Website.
In the normal course of business, we may collect the following types of information:
• Information you provide on applications and other forms (including your name and address), which may include Personally Identifiable Information and/or Protected Health Information, including Information you might provide in connection with your enrollment
• Data about your transactions with us (such as types of products you have purchased and your account status).
• Information gathered on our Website through online forms, site visit data and online information-collecting devices such as “cookies” and as further described herein.
When you request more information about, health insurance or ancillary products, you may provide Information about yourself, including your name, address, age, birthdate, gender, amount of coverage requested, phone number, e-mail address, and other items. This Information is shared with relevant third-parties necessary to fulfill your request. We may share this Information with insurance agencies, insurance brokers, and insurance companies. We do not share this Information with outside parties except to the extent necessary to complete your request such as submitting your application to insurer(s). To the extent that Protected Health Information is provided, such information will be used only as permitted by HIPAA.
Insurance institutions and other service providers subscribe to our system and compete for the opportunity to provide insurance products and services that match your inquiry. When you make an inquiry about an insurance product or enroll in an insurance product and enter your personal information and click the “Submit” button, you are authorizing the sharing of your inquiry and your Personally Identifiable Information entered with other businesses who provide insurance products or services that match your inquiry. By submitting your Personally Identifiable Information to us, you are also authorizing these businesses to contact you directly by e-mail and telephone with information about insurance products or services they offer that match your inquiry. You expressly consent to receive phone calls whether or not you are on the Do Not Call list (federal or state).
However, you should be aware that we have no control over how other businesses with whom we share your Personally Identifiable Information may use such Information or whether they will sell or share your Information with third parties.
Occasionally, NCD may conduct marketing surveys or research to help us evaluate products, services, and the changing needs of our customers. NCD will only provide such third parties with non-personally identifiable information in connection with such marketing surveys or marketing research.
Third-party Access and Use
Occasionally, we hire third-party service providers to help provide or improve the services we offer you. Sometimes it is necessary for these providers to have access to the Personally Identifiable Information and/or Personal Health Information we collect about you. In those cases, we take reasonable steps to ensure that these providers do not use or otherwise disclose any Personally Identifiable Information we collect about you except for the purpose of fulfilling their service obligations to us.
We may share aggregate information about Website users with certain third parties. This information shows user activity as a whole rather than on an individual basis; such aggregate information cannot be used to individually identify you. We may use such aggregated information we collect about Website users to continue to improve our service for you.
Accuracy of Your Information
We strive to maintain the accuracy of Information, including Personal Health Information and Protected Health Information, that is in our possession about you. In order to help us maintain accuracy, you have the right to reasonably access your Information, including Protected Health Information. If you believe any Information in our possession, including any Protected Health Information, is inaccurate, a request can be made to amend or delete such information that you believe to be erroneous. If we concur with the request, we will amend or delete the information in question.
Certain users of the Website may review and make changes to some of the Personally Identifiable Information that we collect and maintain online by simply logging in to the Website by inputting their username and password where indicated and following the instructions provided.
You can also correct factual errors in your Personally Identifiable Information by sending us a request that clearly shows the error that is to be corrected. Please contact us with such requests at: 1-800-979-8266 or email@example.com. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections. In addition, you may be prompted at certain times on the Website to update and correct your Personally Identifiable Information with us. It is your responsibility to keep the information that you provide to us current and accurate.
Our Commitment To Data Security
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of Personally Identifiable Information and Protected Health Information, we have put in place reasonable physical, electronic, and managerial procedures to safeguard and secure the Personally Identifiable Information we collect online and we make good faith efforts to store your Personally Identifiable Information in a secure operating environment. We comply with HIPAA security requirements with respect to safeguarding and securing your Protected Health Information. Unfortunately, no data transmission over the Internet can be guaranteed to be absolutely secure. As a result, while we strive to protect your Personally Identifiable Information and Protected Health Information, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. If NCD provides you with a username and password to access portions of the Website, NCD disclaims any responsibility for a breach of privacy as a result of your willingly or inadvertently disclosing your username and password to others. NCD further disclaims any responsibility for a breach of privacy as a result of your willingly or inadvertently disclosing your policy number(s) and social security number, which may in some instances be used to access Personally Identifiable Information or Protected Health Information on the Website. If someone calls you, explains the call is on behalf of NCD and asks for your policy number or social security number, you should beware.
Other Websites and Links
The Website contains links to other websites that are not operated by NCD. Please note that when you click on a link to one of these sites, you are exiting the Website to go to another site. NCD is not responsible for the content or privacy practices of these websites. We suggest that you read the privacy policies of these sites, as their practices and policies may differ from ours.
The Website is not intended to be used by children and is not directed toward children under the age of 18. NCD does not use the Website to knowingly solicit data from or market to children under the age of 18. The Website does not sell products for purchase by children. No person under 18 years of age should disclose information on the Website. If you are under 18, you may use the Website only with the involvement of a parent or guardian.
Please visit www.consumer.ftc.gov/topics/kids-online-safety to learn more about protecting children privacy.
How to Contact Us
California Residents Privacy Rights
Companies that collect Personally Identifiable Information from California residents and disclose such information to third parties (including affiliated entities) for marketing purposes must, in response to a request by a consumer, either (1) provide a list detailing the categories of information shared and the entities to which such information was provided, or (2) provide a mechanism by which a consumer may opt-out of having their information shared with Third Parties. We have elected the second option and you may request that your Personally Identifiable Information not be shared with third parties by sending your request, including your full name, e-mail address and postal address to: firstname.lastname@example.org. In accordance with California Civil Code Sec. 1798.83, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, Suite 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by e-mail to email@example.com.