Navia Benefit Solutions, Inc. Privacy Notice
Effective Date: June 17, 2020
Last Reviewed on: June 17, 2020
This Privacy Notice supplements any information provided by your Employer with respect to the benefits provided to you by Navia Benefit Solutions, Inc. (“Navia) and applies to all visitors, users, and participants (“consumers” or “you”). We adopt this notice to comply with applicable law, including but not limited to the California Consumer Privacy Act of 2018 (“CCPA”) and any terms used in this Notice have the same meaning as the term defined by the CCPA.
Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information“) from some of its requirements.
Information We Collect
We collect 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“). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including 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.
We collect the following categories of personal information within the last twelve (12) months:
|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.
Some personal information included in this category may overlap with other categories.”
|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.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|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.||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.||NO|
|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.||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|
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 Website.
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 Website, 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 Website experience and to deliver content and service offerings relevant to your interests, with your consent, where required by law.
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose, to comply with applicable law or to fulfill our contractual obligations. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
- Print and email fulfillment
- Benefit debit card management
- Website analytics
- Other third parties as required to administer the benefits offered
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company disclosed the following categories (as outlined above) of personal information for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category C: Protected classification characteristics under California or federal law.
- Category D: Commercial information.
- Category E: Internet or other similar network activity.
- Category F: Sensory data.
- Category G: Non-public education information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Print and email fulfillment
- Benefit Debit card management
- Website analytics
- Other third parties in order to administer the benefits offered
Sales of Personal Information
In the preceding twelve (12) months, Company has not sold your personal information.
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.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
- You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive your written request and confirm your identity (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you, as required by law, the following:
- 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 or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- We do not sell personal information.
We do not provide these access and data portability rights for B2B personal information.
Deletion Request Rights
You may have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your identity (see Exercising Access, Data Portability, and Deletion Rights), we may delete your personal information from our records, unless an exception applies.
Keep in mind, since Navia is a service provider contracted by your Employer, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide the services requested, take actions reasonably anticipated within the context of our ongoing business relationship with you and your Employer, fulfill or otherwise perform our contract with you or your employer.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and our relationship with your Employer.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We do not provide these deletion rights for B2B personal information.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion 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 email@example.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. The request must:
- Provide sufficient information that allows us to identify you are the person about whom we collected personal information or an authorized representative, which may include:
- Physical Address
- Social Security Number
- Date of birth
- Or other information as necessary
- 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 a written request within forty-five (45) days of its receipt. If we require more time (up to 45/90 days), we will inform you of the reason and extension period in writing. If necessary, we may redirect you to your Employer.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the receipt of the written request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow 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 written 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.
Personal Information Sales Opt-Out and Opt-In Rights
We do not sell personal information. Consequently opt-out is not necessary.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you services.
- Charge you different prices for services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level of services.
- Suggest that you or your Employer may receive a different price for services or a different level or quality for services.
Other California Privacy Rights
As applicable, California’s “Shine the Light” law (Civil Code Section § 1798.83) may permit users of our Website 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 firstname.lastname@example.org. Note that we administer health and employee tax benefits and marketing is highly restricted.
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 the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes. Your use of our Website 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.
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