Navia Benefit Solutions, Inc. Privacy Policy & Notice

Links

Our Sites may link or contain links to other third-party sites (“Third-Party Sites”) that are not owned or controlled by Navia. Navia may also provide links to Third-Party Sites managed by our vendors. Such Third-Party Sites are provided as a service to you. These Third-Party Sites may have similar appearance to the Sites but they are not owned or controlled by Navia. Please keep in mind that this policy only applies to Navia’s Sites.

Information We Collect

As used in this Privacy Notice, personal information means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information subject to laws such as HIPAA, CMIA, the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.Other information excluded as personal information by applicable privacy laws.

We have collected the following categories of personal information within the last twelve (12) months as indicated below:

Category	Examples	Collected
A. Identifiers.	A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, address, telephone number, bank account number, other financial information, medical information, or health insurance information.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions).	YES
D. Commercial information.	Products or services purchased, obtained, or considered, or other purchasing or consuming histories.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Information on a consumer’s interaction with a website, application, or advertisement, including the type of computer, smart phone, or operating system used to interact with our Sites and internet provider.	YES
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records, for purposes of benefit administration	YES
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO
L.  Sensitive personal information.	Social Security number, state identification card, medical and health information, sexual orientation or identification, account log-in, financial information, union membership (for non-discrimination testing when applicable), email, text, or other message contents when provided to substantiate a benefit claim, personal information of children (when provided to substantiate a benefit claim).	YES

 

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you, your spouse, your dependents, your employer or other service providers contracted with or used by your employer (carriers, data transmission providers, etc.). For example, we may obtain information from enrollment forms, claims you submit, or services you use or enroll in. Note that some information may be incidentally share with Navia in enrolment forms, claims, or other similar methods and medium but such information may not be required to be shared. For example, under section C. above we do not directly request information regarding childbirth, but you may include such information in a benefit claim and thus we incidentally receive such information.
• Indirectly from you. For example, from observing your actions on our Sites.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to submit a claim or ask a question about our services, we will use that personal information to respond accordingly. If you provide your personal information for benefit purposes, we will use that information to process your request.
• To provide, support, personalize, and develop our Sites, products, and services
• To create, maintain, customize, and secure your account with us.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Site experience and to deliver content and service offerings relevant to your interests, with your consent, where required by law.

• Internal operations such as enhancing our services, and the quality or safety of the services or devices which we may own, control or provide.
• To help maintain the safety, security, and integrity of our Sites, products and services, databases and other technology assets, and business while using personal information as may be reasonably necessary and proportionate for these purposes;
• For testing, research, analysis, and product development, including to develop and improve our Sites, products, and services, including to develop and demonstrate technology.
• For short term, transient use including non-personalized advertising shown as part of a consumer’s current interaction with us.
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with state privacy laws and other standards; and
• Debugging to identify and repair errors in our systems.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

As described to you when we collect your personal information.  Navia does not use or disclose sensitive personal information for purposes that, under applicable law, require us to offer consumers a “Right to Limit” the use or disclosure of sensitive personal information.

Retention of Personal Information

We retain personal information for the length of time needed to carry out the purposes outlined in this Privacy Notice and to adhere to our policies on keeping records (unless a longer period is needed by law). Our records policies reflect applicable laws. We retain personal information to the extent necessary to provide individuals with our services, to manage accounts, communicate with you, personalize and improve your experience on our Site  and comply with our legal obligations and as otherwise described in this Privacy Notice.

Sharing Personal Information

We have disclosed personal information in all or substantially all of the categories identified in the Information We Collect section of this Privacy Notice for the business purposes described in the Use of Personal Information section above.

We share your personal information with the following categories of third parties:

• Print and email fulfillment
• Benefit debit card management
• Site analytics
• Other third parties as required to administer the benefits offered and support our business operations.

We may disclose your personal information to comply with applicable law, fulfill our contractual obligations, to enforce our legal rights or obligations, and as may be necessary to protect the rights and interests of Navia and its affiliates, employees, customers, or any other person or entity. We may transfer or disclose your personal information in connection with, or during negotiations concerning, any merger, sale of our assets, financing or acquisition of all or a portion of our business by another company or other business transaction. We also may share your personal information with your direction or consent, or after providing appropriate notice to you.

We have not sold or shared personal information for monetary or other valuable consideration in the past 12 months.

We do not disclose personal information of individuals we know to be under the age of 16 to other businesses or third parties for consideration (unless necessary for benefits administration i.e. dependent care FSA, health care FSA, or health reimbursement arrangements).

Google Analytics website disclosure:

We may use a variety of third-party services to help provide our website and services, such as developing and hosting our website and to help us understand the use of our website, such as Google Analytics, to provide information to us regarding our website, products and services. We may also collect or otherwise gather information related to you from these third-party service providers. These third-party service providers may collect, store, and share information as further dictated by the privacy policies of those third parties

You can prevent the collection of the data generated by Google Analytics in relation to your use of our website and the processing of this data by downloading and installing the browser plug-in, with more information regarding how you can opt out of Google Analytics data collection as instructed here: https://tools.google.com/dlpage/gaoptout.This link provides instructions for installing an opt-out cookie on your device. As a result, the collection of data by Google Analytics is prevented in future for the Site and for this browser as long as the opt-out cookie remains installed in your browser.

How You Can Access or Change Your Information

If your personal information changes you may log onto the Sites to update that information. Keep in mind, some personal information is routinely transmitted to Navia by your employer. If your employer’s information is outdated, that outdated information may eventually override any changes you may make using the Sites. Be sure you also make those updates with your employer. You may also call or email us by going to the “Contact Us” page at www.naviabenefits.com and we will assist you with making any necessary changes.

Email and Other Alerts

From time to time you may receive benefit plan communications through electronic mail or a phone alert. Alerts are provided within our applications and you will not receive “Push Notices”. You may opt out of certain electronic communications by logging onto your participant account online. There you may configure the communications you would like to receive.

Your State-Specific Privacy Rights

If you are a resident of California,  Colorado, Connecticut, Utah or Virginia you may have one or more of the rights described below.  We will honor requests received to the extent required by applicable law and within the time provided by law.

Right to Access Personal Information

• You have the right to request that we disclose the following information to you about our collection and use of your personal information in the 12 months preceding your request.

• whether we are processing personal information about you;

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting, sharing or selling that personal information.
• The categories of third parties with whom we disclose that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• the categories of personal information about you, if any, that we have sold or shared and the categories of third parties to whom we have sold or shared the information, by category or categories of Personal Information for each category of third party to whom we sold or shared the Personal Information; and
• the categories of personal information about you that we disclosed for a business purpose and the categories of persons to whom we disclosed the information for a business purpose

Deletion Request Rights

You may have the right to request that we delete personal information that we have collected from or about you.

Right to Correct

You have the right to request that we correct inaccurate Personal Information that we have collected about you.

Right to Limit the Use of Sensitive Personal Information.

You have the right to limit the use or disclosure of your sensitive Personal Information. To exercise this right, you may submit a request to us by emailing compliance@naviabenefits.com

Right to Appeal.

If we decline to take action on a request that you make in accordance with the foregoing to exercise the foregoing privacy rights, then you may appeal our decision by emailing compliance@naviabenefits.com

Requests to Exercise Your Rights

To exercise the rights described above, please submit a written request to us by either:

• Calling us at 425-452-3500 or toll free at 1-800-669-3539
• Emailing us at compliance@naviabenefits.com
• Visiting www.naviabenefits.com

Only you, or someone legally authorized to act on your behalf, may make a written request related to your personal information. You may also make a request on behalf of your minor child.

You may only make a written request for access or data portability twice within a 12-month period.

Verification

We may require you to provide certain information that allows us to verify that you are the person about whom we collected personal information or an authorized representative, which may include:

• • Name
  • Physical Address
  • Email
  • Social Security Number
  • Date of birth
  • Or other information as necessary

We may also ask that you describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.  We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a written request does not require you to create an account with us.  We will only use personal information provided in a written request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

As required by law, we endeavor to respond to your request within forty-five (45) days of its receipt (or the applicable statutory timeframe). If we require more time, we will inform you and will respond within such additional period of time required by law. If necessary, we may redirect you to your employer.

If your request involves us providing personal information to you, we will deliver our written response by mail or electronically, at your option or through your account if you have an account with Navia. If electronically, then we will deliver the information to you or, if you so request and by permitted by law, to another entity,  in a portable and, to the extent technically feasible, in a structured, commonly used, machine-readable format that allows you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of the rights described above, including by:

• Denying you services.
• Charging you different prices for services, including through granting discounts or other benefits, or imposing penalties.
• Providing you a different level of services.
• Suggesting that you or your employer may receive a different price for services or a different level or quality for services.

Do Not Track

Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “do not track” signals.

Accessibility

If you use assistive technology and the format of this Privacy Notice interferes with your ability to access information, please contact us at compliance@naviabenefits.com.

Other California Privacy Rights

As applicable, California’s “Shine the Light” law (Civil Code Section § 1798.83) may permit users of our Sites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to compliance@naviabenefits.com.

Children’s Privacy

Our Online Services are not intended for use by children under 13. We do not knowingly collect personal information from children under the age of 13 without parental or guardian consent. Please notify us as provided below in the Contact Information section if you believe we may have collected such information without parental or guardian consent or other than in a manner authorized by law, and we will work to delete it.

Security

You must take steps to ensure the privacy and security of your information. You must always log out of your online account when using public computers. Never share your username and password with anyone or otherwise permit them to impersonate you online. Finally, if you log onto your account while at work or use your work email address, we cannot control the monitoring used by your employer. It is important to note that email is not a secure means of communicating. If you feel your information may have been or will be compromised change your password immediately at www.naviabenefits.com or call our Customer Service department to have your password reset.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our Sites and update the notice’s effective date. Your continued use of our Sites following the posting of changes constitutes your acceptance of such changes. Your use of our Sites and our benefits also constitutes explicit consent to use your information as necessary to provide services, retain such information as required by law and our contract with your employer, and destroy or dispose of your information consistent with applicable laws, our contracts, and our internal policies.

For a list of subcontractors and vendors that may have access to your information please click here.

Contact Information

If you need to notify Navia Benefits of operational failures, incidents, problems, or complaints please contact compliance@naviabenefits.com.

Phone: 1-800-669-3539
Website: www.naviabenefits.com
Email: compliance@naviabenefits.com

Postal Address:
600 Naches Ave SW
Renton WA, 98057