- The information we collect about you
- How we use the information we collect
- With whom we share your information
- How you can access your information
- Your choices about collection and use of your information
How we protect your personal information
THE INFORMATION WE COLLECT ABOUT YOU
In General. We may collect personal information that can identify you such as your name and e-mail address, as well as other information that does not identify you such as your zip code. When you provide personal information through our website, the information may be sent to CMSlinc.com servers located in the United States and other countries around the world.
Information You Provide. As mentioned above, we may collect information you submit on our website, such as your name, e-mail address and zip code. We may also track your interaction with email advertisements sent to you by CMSlinc.com or our e-mail service providers on our behalf (for example, when you register, purchase, or browse in response to such emails).
List Information from Vendors. We may obtain information about you after you provide information to a third party and you permit that party (the “Seller”) to share the information, which CMSlinc.com subsequently purchases, licenses or otherwise lawfully acquires. Such information may include, but is not limited to, your name, street address, zip code, telephone numbers, birth date, gender, salary range, education, marital status, occupation, industry of employment, personal and/or online interests, and/or other information which you provided to the Seller (together, “Vendor List Information”). When acquiring Vendor List Information, CMSlinc.com requires assurances from the Seller that the Seller has a right to transfer the Vendor List Information to CMSlinc.com and that CMSlinc.com may lawfully use the Vendor List Information to transmit offers to you. You may opt out of receiving these offers by using one of the methods specified in the section below entitled “Your Choices About Collection and Use of Your Information”.
Information from Other Sources. We may also periodically obtain both personal and non-personal information about you from business partners, contractors and other third parties, as well as information from public databases. Examples of information that we may receive include information about your home and additional demographic information.
Other Technologies. We may use other standard Internet activity tracking technologies, such as web beacons and similar technologies, to track your use on our website or your interaction with our advertisements. A web beacon is a programming code used to display an image on a web page and can also transfer an individual’s user identification to a database and associate the individual with previously acquired information about the individual. Such information may be used in targeted or behavioral advertising, as well as for the other uses described in this paragraph. We may include web beacons in promotional e-mail messages or newsletters or online advertisements to determine whether messages have been opened or acted upon. We may use the information we obtain in this manner to customize the services and offers we provide our website’s visitors, to deliver targeted advertisements, and to measure the overall effectiveness of our online advertising, content, programming or other activities. We do not tie web beacons to any personal information you submit while on our website.
Purchasing an Insurance Policy and/or Applying for Insurance Coverage Through CMSlinc.com
If you submit an application for an insurance product offered by us, then we will disclose your personal information to your chosen insurance company to process your application. If you submit a request for information or an application for an insurance product offered through an insurance agent, agency or other business partner with whom we associate or contract, then we may disclose your personal information to that agent, agency or business partner to process your request for information or application or to otherwise provide you with information about insurance products (including contacting you by telephone, email, or otherwise to discuss insurance products in which you may be interested). If you complete an enrollment form for a health savings account (“HSA”) offered through an authorized HSA trustee or administrator with whom we have associated, then we may disclose your personal information to that trustee or administrator to enroll you in an HSA. If you complete an application with us that is processed through a government-run exchange or other government-run entity, we will disclose your personal information to that government-run exchange or entity. Please be assured that these partners are only allowed to use your personal information to process your requested quote, application or enrollment form and are legally obligated to maintain strict confidentiality.
We may disclose your personal information to other companies that help us to process or service any application you begin, process or submit through us or to correspond with you. For example, we may provide your personal information to a service provider to verify the validity or credit limit of your credit card. Please be assured that the companies we hire to process or service your insurance application or correspond with you are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality.
Employers, Affinity Groups, and Benefits Administrators or Consultants.
If you were referred to us by, or use our website or call center in connection with, a current or former employer, affinity group, or other organization with which you may be affiliated (or a benefits administrator or consultant associated with such employer, group or organization), we may disclose your personal information to such employer, group, organization, administrator and/or consultant. For example, we may inform such employer, group, organization, administrator and/or consultant whether or not you have enrolled in a plan. Please be assured that these parties are only allowed to use your personal information as permitted by applicable law.
We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process. We may disclose or report your personal information when we believe, in good faith, that the disclosure is required or permitted under law, for example, to cooperate with regulators or law enforcement authorities, to resolve consumer disputes, to protect our rights, to protect your safety or the safety of others, to investigate fraud, or to otherwise respond to a government request.
If CMSlinc is involved in a merger, acquisition, or sale of all or a portion of it’s assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
If you provide us an indication of your consent to disclose, share or use your personal information in connection with a third party, we may disclose, share or use your personal information in that manner. For example, if you opt in to our social media mailing lists and promotional updates, then we may disclose your relevant personal information to social media platforms where CMSlinc has a corporate account for the purpose of adding you to CMSlinc’s social media mailing and promotional update lists. Generally in such a situation, the social media platforms are not allowed to use your personal information for their own purposes unless you have a direct account on such social media platforms, in which case your personal information would be handled by the social media platforms in accordance with the social media platforms’ privacy policies.
Your Requests for Products.
Applying for Health Insurance and Other Products.
If you apply for a health insurance or other product through our website, we may ask you to provide us with personal information and/or health information relating to you and any family member who will be included on your application. This information will be used by your chosen insurance company, agent, HSA trustee or administrator, or government-run exchange or entity to process your application. Additionally, we may ask you to provide us with your credit card, bank information and social security number, which will be used by your chosen insurance company or HSA Trustee or Administrator to process your application or collect any fees associated with your application or insurance premiums upon approval of your application. If you apply through us for government health insurance subsidies or for health insurance sold through a government-run exchange, we will ask you for personal information, including financial, tax filing and household information, that we will pass on to government-run sites and entities responsible for processing such subsidies and applications.
Providing you with a quote or processing your application.
We may use your personal information to get in touch with you when necessary to process your application or to provide you with a quote. For example, emails will be sent to you throughout the application process to inform you of the status of your application and to seek additional information that is requested as part of the application. We may also use phone numbers you provide to send you telephone or text messages about your application or account, and such messages may be automatically sent with an autodialer, an artificial or prerecorded voice, or other automation technology.
Customer satisfaction, referrals and other products.
We or our wholly-owned subsidiaries may contact you to survey your satisfaction of our service, refer our products and services to other people, and/or to inform you of additional products and services. You may opt out of receiving these additional communications from us by following the opt-out procedures below.
Information Collected by Third Parties.
Targeted or Behavioral Advertising
Targeted advertising (also known as behavioral advertising) uses information collected on an individual’s web browsing behavior such as the pages they have visited or the searches they have made. This information is then used to select which CMSlinc Corporation advertisement should be displayed to a particular individual on websites other than an CMSlinc Corporation site. For example, if you have shown a preference for Medicare supplemental insurance while visiting an CMSlinc Corporation, site, you may be served an advertisement from or about the CMSlinc Corporation site for Medicare supplemental insurance when you visit a site other than the CMSlinc Corporation site. The information collected is only linked to an anonymous cookie ID (alphanumeric number); it does not include any information that could be linked back to a particular person, such as their name, address or credit card number. The information used for targeted advertising either comes from the CMSlinc Corporation site you are visiting or through third party website publishers.
In addition, we may place (or allow third parties to place) cookies and pixels on our website which enable our authorized service providers, advertising companies and advertising networks to collect information about our users who view or interact with their or our advertisements on our website or complete certain actions on our site, such as submitting a form. However, we do not tie these cookies and pixels to personal information that you submit on our website. The information collected by the cookies and pixels allows us and our partner companies to deliver, and gauge the effectiveness of, targeted advertisements, both on our website and when you are browsing other websites. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative (www.networkadvertising.org), which offers a single location to opt out of ad targeting from member companies.
Storage of Information We Collect
We may store the personal information described above as necessary to accomplish the business purposes for which it was collected, as well as to comply with our legal and audit obligations, resolve reported and potential disputes, and enforce our agreements. We also maintain an information security program that limits storage of personal information to what is needed to fulfill our reasonable business, legal and audit requirements.
HOW WE USE THE INFORMATION WE COLLECT
In general. We may use information that we collect about you to:
- deliver the products and services that you have requested (for example, to provide you with Medicare supplemental insurance quotes and/or match you with insurance companies);
- send you offers that you have opted in to receive;
- manage your relationship with us and provide you with customer support;
- perform research and analysis about your use of, or interest in, our products, services or content, or products, services or content offered by others;
- communicate with you by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us or third parties;
- develop and display content and advertising (such as targeted ads) tailored to your interests on our websites and other websites;
- enforce our terms and conditions;
- protect CMSlinc.com, our websites, our customers and/or our other users from fraud, hacking or other harm;
- cooperate with legal, criminal or regulatory investigations or proceedings;
- manage our business; and
- perform functions as otherwise described to you at the time of information collection.
WITH WHOM WE SHARE YOUR INFORMATION
We want you to understand when and with whom we may share personal or other information we have collected about you or your activities on our website, while using our services or in your other interactions (such as responding to e-mails) with us.
We may share your personal information with the following third parties:
Authorized Service Providers. We may share your personal information with our authorized service providers that perform certain services on our behalf. For example, we may engage other companies to provide data storage, to assist in marketing CMSlinc.com products or services, to conduct audits, to provide web analytics, and to provide hosting, design, development and other operations which make our website work. Other third-party service providers may help us communicate with you through e-mail. Our policy is to permit these third-party service providers to obtain only the personal information they need to provide the services, and to require them to protect personal information to the same extent as CMSlinc.com, including not using it for any improper purpose.
Business Partners. When you express interest in products, services or promotions offered through our website or our services, we may share your expression of interest with the businesses with which we partner to offer you those products, services and promotions, and, as applicable, their affiliates and third-party finder or marketing companies. When you elect to engage in a particular offer or program, you authorize us to provide your e-mail address, phone number, and other information to those businesses.
Marketers. From time to time, where permitted by applicable law, we may share your personal information and automatically collected or aggregated information about you with reputable direct marketers so that they may offer products and services, which we hope, will be of interest to you. Please see the section below entitled “Your Choices About Collection and Use of Your Information” for detailed information on your choices regarding your personal information.
Insurance Companies. If you provide your zip code, we will find insurance companies in your area whom we think may be of interest to you. Once you submit your zip code and select the company you wish to obtain a quote from, you will then be redirected to that third party site and provide information to them directly. Because the insurance companies and other partners on the CMSlinc.com network with whom you are matched may retain or use your personal information whether or not you qualify for, or obtain, Medicare supplemental insurance or another product from them, you should contact these persons directly concerning their privacy and information sharing practices.
Special Notice to Vermont Residents. CMSlinc.com will not share any personal information about you with other affiliated companies to the extent prohibited by applicable Vermont law or to the extent your prior consent to share is required by applicable Vermont law.
Other Situations. We also may disclose your information:
(1) In response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law.
(2) When we believe disclosure is appropriate in connection with efforts to investigate, or to prevent or take other action regarding, illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees or others; or to enforce our website’s terms and conditions or other agreements or policies.
(3) In the event CMSlinc.com goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, or in the unlikely event of a bankruptcy, your personally identifiable information will likely be among the assets transferred. You will be notified via email or prominent notice on our website for 30 days of any such change in ownership or control of your personal information.
Please note that information may also be collected by third parties such as advertising companies and advertising networks via third-party cookies and pixels on our site (please see the subsection above entitled “Targeted or Behavioral Advertising” for details).
Aggregated and Non-Personal Information. We may share aggregated information (i.e., information about you and other customers collectively, but not specifically identifiable to you) and other non-personal information we collect under any of the above circumstances. We may also share it with third parties and affiliated companies to develop and deliver targeted advertising on our websites and on websites of third parties. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our website and the most popular features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.
HOW YOU CAN ACCESS YOUR INFORMATION
If your personal information changes, or if you would no longer like us to contact you, you may correct, update, or request deletion by emailing us at info@CMSlinc.com.
We will retain your information for as long as needed to provide you services. We may also retain and use your information as necessary to comply with our legal and audit obligations, resolve reported and potential disputes, and enforce our agreements. If you wish to request that we no longer use your information to provide you services, please contact us at info@CMSlinc.com. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing all such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required. All requests are also subject to the next section below (“Your Choices About Collection and Use of Your Information”).
We also maintain an information security program that limits storage of personal information to what is needed to fulfill our reasonable business, legal and audit requirements.
YOUR CHOICES ABOUT COLLECTION AND USE OF YOUR INFORMATION
You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our website because such information may be required in order for you to apply for or obtain products or services.
If you receive e-mail messages or newsletters from us, you will be given the opportunity, in any commercial e-mail that we send to you, to opt out of receiving such messages in the future. It may take up to 10 business days for us to fully process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as requests for additional information, confirmations, service updates or announcements, administrative notices and surveys, without offering you the opportunity to opt out of receiving them. Please note that opting out of receipt of commercial e-mail communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We take appropriate security measures (including physical, electronic, and procedural measures) to help safeguard your personal information from unauthorized access and disclosure. For example, with regard to CMSlinc.com’s internal operations, only authorized employees and authorized third party service providers are permitted to access personal information, and they may do so only for permitted business functions. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
YOUR CALIFORNIA PRIVACY RIGHTS
the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
the names and addresses of the third parties that received that information; and
if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.
We may provide this information in a standardized format that is not specific to you. The designated e-mail address for these requests is info@CMSlinc.com. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address or mailing address. Please also be aware that not all information sharing is covered by the California requirements and only information on covered sharing will be included in our response.
Our website is for adults, and we do not knowingly collect personal information from children under the age of 18.
VISITING OUR WEBSITES FROM OUTSIDE THE UNITED STATES
NO RIGHTS OF THIRD PARTIES
HOW TO CONTACT US
You may also contact us at:
5 PHEASANT DRIVE
MOUNT LAUREL, NEW JERSEY 08054