Premier Secure Insurance Solutions LLC
Privacy policy.
Last Modified: October of 2024
en español
This Privacy Policy (the “Policy”) is issued by Premier Secure Insurance Solutions LLC (collectively “we”, “us”, “our” or “PSIS”) in furtherance of our commitment to respecting data privacy rights. For purposes of this Policy, “you” or “your” means any visitor to our website, or any natural person or household whose "Personal Information" is collected by us in any way. This Policy describes how we collect, use, analyze and share Personal Information and how we ensure that your privacy rights always are honored. By using our website or Services (as defined herein), you consent to the privacy practices described in this Policy.
I. CATEGORIES OF PERSONAL INFORMATION WE COLLECT
We are dedicated to respecting and protecting your privacy rights. Within this Policy, "Personal Information" means any information that identifies, relates to, describes, is capable of being associated with, or reasonably could be linked, directly or indirectly, to a particular individual or household. Such can include, but is not limited to, real name, postal address, Internet Protocol (commonly know as “IP”) address, email address, account names, or other similar identifiers, or information generated from electronic network activity, including browsing history, search history and any information concerning an individual’s interaction with an internet website or use of products or Services. “Sensitive Personal Information”, as a subset of Personal Information, can include government identification numbers, financial account numbers, geolocation data, genetic, medical information or other similar identifiers. “Protected Health Information”, as a subset of Personal Information, is information that relates to an individual’s past, present, or future physical or mental health or condition, the provision of health care to an individual, or past, present, or future payment for the provision of health care to an individual. Personal Information does not include certain forms of publicly available information, deidentified information, or aggregated information that is not capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual or household.
In providing services to our health insurance carrier business clients (“Carriers”), we may collect the following categories of Personal Information:
i. Transactional Data and Information. This includes Personal Information generated when you apply for and enroll in health insurance coverage offered by Carriers or renew the same through our Services, which may encompass first and last name, address, contact information (such as phone number, mailing address, and email address), details of a particular Qualified Health Plan (“QHP”) transaction including, without limitation, Carrier, QHP information (including policy number), social security number, driver’s license, date of birth, citizenship status and number or eligible immigration status, sex, permanent move, divorce, marriage, birth of a child, adoption, tax filings, premium tax credit reconciliation, employer and income details, spouse and dependents (and their Personal Information necessary for inclusion of such individuals on your QHP), medical information (such as health history, prescriptions, and provider lists), power of attorney documentation, payment card data and other transactional information, and the nature of the transaction, as well as information generated from your engagement with any of our business partners, third party service providers, and Carriers.
ii. Compliance and Operational Information. This includes Personal Information related to our subcontractors (and their employees, commonly known as “Agents”), which can encompass information such as first and last name, product and compliance training data generated from those individuals, information in what is commonly known as a "background check", as provided by a consumer reporting agency and as authorized pursuant to applicable law, and government-issued identification.
iii. Information Generated from Our Website. This includes “Cookies”, web beacons, and other tracking technologies. “Cookies” are text files that websites store on a visitor’s device to identify the visitor’s browser or to store information or settings in the browser to track activity and patterns. Web beacons, pixel tags or clear GIVs are typically one-pixel, transparent images located on a webpage or in an email or other message that demonstrate a user has accessed or opened certain content or that the content was viewed or clicked. These, or similar technologies may be used on our sites and in some of our digital communications (such as email or other marketing messages). They may also be used when you are served advertisements or you otherwise interact with advertisements outside of our online services. We only track cookies that are from Google Analytics and Google Tag Manager.
a. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete cookies, please visit: www.allaboutcookies.org. Some browsers may be configured to send “do not track” signals to the online services that you visit. To find out more about “do not track” please visit: www.allaboutdnt.com.
b. You can learn more about Google Analytics cookies at: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage, and how Google uses data at https://policies.google.com/technologies/partner-sites. You can prevent the use of Google Analytics relating to your use of our webpage by downloading and installing a browser plugin available at: https://tools.google.com/dlpage/gaoptout?hl=en.
ii. Information You Provided to Us. This includes Personal Information you submit to us, such as information submitted to us in any request or provided to us when you communicate with us or use our website.
II. HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION
Personal Information is collected by us in a variety of ways and used to support our business operations. We will not retain or use any Personal Information for any purpose other than: (i) fulfilling the purposes for which you provided the data or that were described when it was collected; (ii) assisting with your eligibility, enrollment, and automatic direct enrollment for health insurance coverage through the Federally Funded Marketplace (“Marketplace”), including, without limitation, assisting with completion of Marketplace applications, transmitting information about your decisions regarding QHP enrollment and/or other related information to the Marketplace, and correcting errors in applications for QHP enrollment; (iii) providing ongoing account maintenance and enrollment assistance, including, without limitation, assisting your ability to report changes in eligibility status to the Marketplace throughout the coverage year, including changes that may impact eligibility (e.g., adding a dependent); (iv) notifying you about changes to our sites, applications, or services; (v) facilitating services and operations performance, security, and integrity, including internally verifying transactions secured by our subcontractors, maintaining the quality of and improving our services; (vi) complying with our legal obligations and risk management, recordkeeping, audit, investigation and reporting, fraud prevention, and other legal and compliance obligations; (vii) providing information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a Carrier; (viii) facilitating and targeting sales and marketing activities; (ix) managing verifications and information requested by you, our Carriers, and the Marketplace; and (x) other functions substantially similar to those enumerated above and such other functions that may be approved by the Centers for Medicare and Medicaid Services (“CMS”) in writing from time to time (collectively, “Services”).
i. Transactional Data and Information.
a. This data is generated by your transactions or activity through us, which is delivered to us through our third party service provider, Salesforce, Inc., and is necessary for your Services. This data can also be provided to us (i) by you in filling in forms in the health insurance coverage applications submitted to us as part of our Services, (ii) by our Carriers, business partners and third party service providers, including, without limitation, enrollment processors and consumer reporting agencies, through reoccurring reporting and is delivered electronically or accessed through secure portals, and (iii) by inbound and outbound telephonic communications between our enrollment processors and you. We may be required to collect specific Personal Information about you as required by insurance carriers and applicable law. If you choose not to provide us with the Personal Information requested, or not to respond to specific questions, your enrollment or automatic direct enrollment may be denied or delayed, and we will inform you of such consequences.
b. Certain categories of de-identified transactional data are shared with our subcontractors or other third party service providers to validate the Services performed and otherwise oversee performance. We may use this data to validate sales, process payments to our subcontractors and otherwise ensure we are performing in accordance with our Carriers’ expectations
ii. Compliance and Operational Information. This Personal Information is collected from our subcontractors and is provided to ensure subcontractors and their employees are eligible to perform Services. Sensitive Personal Information may be delivered to us in a consumer report (also known as a "background check") through a consumer reporting agency at the direction of a subcontractor. We access this information through a portal that is used to transmit the Personal Information in a secure and protected environment.
iii. Information Generated from Our Website. Cookies, web beacons, and tracking technologies may be used for various Services, such as fraud prevention, monitoring our websites, and assessing our marketing performance. This information is gathered by and through a visitor to our website and interactions generated from that visit. Some of these tracking tools may detect characteristics or settings of the specific device you use to access our online services.
iv. Other Information Provided to Us. This Personal Information is provided to us by you and is used to (i) provide you with information, products, or Services, (ii) verify, process or respond to any request you submit to us, and (iii) otherwise communicate with you for any other purpose.
v. Aggregate Analytical Data. We may also use data that we collect on an aggregate and anonymous basis (such that it does not identify any individual customer, directly or indirectly) for various Services, where permissible under applicable laws and regulations. This data may be used by us to (i) provide, support, improve, maintain, and otherwise operate our Services; (ii) develop new features and Services; (iii) compile statistical reports and record insights into usage patterns; and (iv) otherwise further our business objectives.
III. SHARING OF PERSONAL INFORMATION
We never sell your Personal Information. We share information provided to us with various trusted business partners, third party service providers, and Carriers for the purpose of our performing our Services and otherwise facilitating our business objectives.
i. Our Subcontractors. We share Personal Information with our subcontractors to process payments and otherwise oversee campaign operations. This data often is de-identified and does not contain information that would be capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual or household. We also may share information in lead lists for the purpose of targeting sales and marketing efforts.
ii. Our Business Partners And Carriers. We share Personal Information with our business partners for the purpose of facilitating our Services and submitting your application(s) to Carriers, as well as to improve the quality and integrity of Services delivered and to otherwise ensure we perform effectively.
iii. Third Party Service Providers. We share Personal Information with third party service providers that provide essential services on our behalf or on behalf of our Carriers to operate and support our business objectives. These third parties may use your Personal Information only to help us operate and deliver Services as part of our business, as authorized in our contracts with our business partners. These may include third parties providing transactional support; software to transmit, process or verify transactions; third party verification services; call center transaction processing; software development; and other forms of support services necessary to operate our business.
iv. Affiliates and Related Companies. We also may disclose Personal Information to our subsidiaries, affiliates, and other third parties we use (i) to support our business; (ii) to fulfill the purpose for which you provide it; (iii) to comply with any court order, law, regulation, or legal process, including responding to any government or regulatory request; (iv) to carry out our obligations and enforce our rights arising from any contracts entered into between you and Carriers as a result of our Services; (v) if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us, our Carriers, business partners or others; or (vi) to any other party with your consent.
IV. DATA RESIDENCY AND RETENTION
Because we are based in the United States and our Services are only intended for residents of the United States, any data we collect will reside within the United States.
Transactional Data containing Personal Information will be retained for the duration of your use of our Services and for ten (10) years following either your de-enrollment date (i.e., the date you no are no longer enrolled in a QHP offered through our Carriers) or, if you submitted an application for a QHP offered through our Carriers but did not enroll in such QHP, your application submission date (i.e., date your application was submitted to the Marketplace). We will, or ensure our subcontractors or third party service providers (as applicable) will, obtain (i) Marketplace consumer consents to receive assistance with application for or enrollment in a QHP, prior to receiving such assistance, and (ii) Marketplace consumer eligibility application attestations, prior to submission of applications to the Marketplace. Documentation and/or recordings of consumer consents and eligibility application attestations shall be retained for at least ten (10) years from the date of creation. We may retain other de-identified information for ten (10) years, however this information will not be information that is capable of being associated with, or reasonably could be linked, directly or indirectly, to a particular individual or household.
Compliance and Operational Data will be retained for as long as a subcontractor and its respective employees work on our campaigns, and three (3) years thereafter. In the event we receive Sensitive Personal Information pertaining to an employee of one of our subcontractors, such as information contained in a background check or government-issued identification, that information is retained for fourteen (14) days.
Information generated from the use of our website is retained for no longer than thirteen (13) months.
V. YOUR DATA RIGHTS
This portion of our Policy details your rights and how we strive to respect the data privacy rights that may apply in our business. Within this Policy, we also provide you information on how you may exercise these rights. Assuming we are able to verify your identity and the request you submit to us, you have the following rights:
i. Right to Know. You have a right to know what Personal Information we may have collected and retained pertaining to you in the twelve (12) months prior to the date of your requests. If requested and if verified (as discussed below), we will provide you the categories, specific pieces and sources of your Personal Information we have collected, the business purpose for which we gathered the information, and the categories of any third parties with whom we have shared the Personal Information.
ii. Access and Correction. You can request a copy of the categories and specific pieces of Your Personal Information collected by us in the twelve (12) months prior to the date of your requests, and to correct inaccuracies therein, if any.
iii. Deletion. You can request that we delete your Personal Information, provided that no exemption to the deletion exists (discussed below). For clarity, we will retain Transactional Data for ten (10) years from the applicable triggering events, as detailed in Section IV of this Policy, notwithstanding our receipt of a verifiable data deletion request, in order to comply with retention obligations set forth by applicable law.
iv. Opt-Out of the Selling or Sharing. You can request to opt out of our ability to sell or share your Personal Information.
v. Non-Discrimination. You are entitled to exercise the rights in this Policy free from discrimination as prohibited under applicable privacy laws.
VI. EXERCISING YOUR DATA RIGHTS
If you have a question as to how you can exercise your data rights under this policy, please contact us through our website, by calling our toll free number at 1-(888)-995-0265, or by emailing us at privacy@premiersecureinsurance.com. The requests herein are subject to certain exemptions and limitations that may limit our ability to process or grant the request. For example, we reserve the right to deny a request if the information is necessary to comply with a legal requirement or to provide you Services, of if we have a legal obligation that requires us to maintain the requested information.
i. Submitting a Data Request to Us. You may submit a request to us to identify the categories and specific pieces of your Personal Information we have gathered in the twelve (12) months prior to your request. You may submit a data request to us by contacting our Data Manager, through any of the following methods:
Phone (toll free): 1 (888) 995-0265
Email: privacy@premiersecureinsurance.com
Request Form: REQUEST PERSONAL INFORMATION
ii. DO NOT SELL OR SHARE MY PERSONAL INFORMATION. While it is not our practice to sell any Personal Information, you may request that we not sell or share your Personal Information by contacting our Data Manager, through any of the following methods:
Phone (toll free): 1 (888) 995-0265
Email: privacy@premiersecureinsurance.com
Request Form: DO NOT SELL OR SHARE MY PERSONAL INFORMATION
iii. LIMIT THE USE OF MY SENSITIVE PERSONAL INFORMATION. Certain data privacy laws provide you the right to request that we limit the use of any of your Sensitive Personal Information we may hold (if any). You may request that we limit the use of your Sensitive Personal Information by contacting our Data Manager through any of the following methods:
Phone (toll free): 1 (888) 995-0265
Email: privacy@premiersecureinsurance.com
Request Form: LIMIT THE USE OF MY SENSITIVE PERSONAL INFORMATION
iv. Processing Requests.
a. Agents. To protect your privacy and security, we may take reasonable steps to verify your identity before granting any request relating to your data. Only you, or, may submit a request related to your Personal Information. To be actionable and verified, a request must (i) provide sufficient information that allows us to reasonably verify you are the person who is the subject of the data request, or a person that you authorize to act on your behalf, and (ii) describe the request with sufficient detail that allows us to properly understand and respond. If an agent submits a request on your behalf, we will require that you: (i) provide the authorized agent written permission to do so; and (ii) verify your own identity directly with us. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf. If the agent demonstrates authorization through power of attorney, we will not require written permission to make a request on your behalf. We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
b. Timing and Process: We will acknowledge receipt of your request within ten (10) days of its receipt. We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable Consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
c. Cost. We do not charge a fee to process or respond to your verifiable Consumer 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.
d. Exemptions. We may not process a request if a legal exemption applies or if we have a legal reason to not process the request. We specifically reserve the right to not process a request if: your Personal Information is necessary to exercise or defend any actual or potential legal claims; your Personal Information is necessary to comply with any court order, law, or legal process, including responding to any government or regulatory request; your Personal Information is necessary to complete the transaction for which the Personal Information was collected; you previously made two (2) requests within a twelve (12) month time period; as well as any other reason allowed under applicable laws.
e. Verification. We can only process those requests that have sufficient information for us to verify the identity of the person submitting the request in relation to the information that we possess. A requestor’s failure to provide us complete or accurate information may prevent or delay our ability to verify a request. To verify a request, we reserve the right to request government identification, personal identifiers that allow us to match information and a declaration from the requestor under penalty of perjury. To properly verify a request, we must be provided sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
VII. SECURITY
The security of your information is our highest priority. We are required by law to maintain the privacy and security of your Personal Information, including your Protected Health Information. We use technical, physical, and organizational security measures designed to protect your Personal Information from accidental loss and from unauthorized access and disclosure, in compliance with federal, state, and international standards. We maintain physical, electronic and procedural safeguards to limit access to your Personal Information. We also actively monitor our systems for suspicious or fraudulent activity. The use of, and access to, your Personal Information by us is restricted to employees, subcontractors, business partners, and authorized third party service providers, who need to know that information to enable us to provide our Services. Notwithstanding, security risk is inherent in all internet and information technology platforms and no part of this Policy should be interpreted as a guarantee or other legal obligation in relation to preventing all threats to networks, systems or other repositories of information.
VIII. CHILDREN
In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we will not knowingly collect or accept Personal Information from a child under the age of thirteen (13) without a parent’s or guardian’s prior consent. We will allow the parent or guardian of a minor under the age of thirteen (13) to review, update, change, delete, or refuse to permit further collection of any and all information collected as part of your use of our Services and your inclusion of such minor on your QHP. A child’s Personal Information will be treated with the same care and respect as an adult’s information. In the event we learn that we inadvertently collect any Personal Information of a minor, without the required consent by law, we will delete said information immediately. If you believe that we have collected information of a minor, please contact our Data Manager through any of the following methods:
Phone (toll free): 1 (888) 995-0265
Email: privacy@premiersecureinsurance.com
Our website: https://premiersecureinsurance.com/
IX. CONTACTING YOU ABOUT THE SERVICES OR OTHER MARKETING OFFERS
i. Your Authorization for Us to Contact You. You understand and agree that we have the right to contact you about your Services and any other marketing offers that we may offer. By accepting this Policy, you consent to being called, emailed, or receiving SMS texts from us about any marketing offers we may offer you at any point during our use of our Services and for thirty (30) days thereafter. This may include automated dialers, prerecorded messages, artificial voice or automatic texting systems. This consent is not required to complete any purchase. Message and data rates may apply to any communication. This authorization will apply notwithstanding any prior placement on a do-no-call registry.
ii. RIGHT TO OPT-OUT OF MARKETING COMMUNICATIONS. You may opt out of receiving any marketing communications from us. This will not include opting out of non-marketing communications related to your Services so long as you are still enrolled in an insurance plan with a Carrier obtained through our Services. You may request that we stop sending you marketing communications by contacting our Data Manager through any of the following methods:
Phone (toll free): 1 (888) 995-0265
Email: privacy@premiersecureinsurance.com
Request Form: DO NOT SEND ME MARKETING COMMUNICATIONS
X. CHANGES TO OUR PRIVACY POLICY
We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated notice on the Website and update the effective date. Your use of our Website or our Services following the posting of changes constitutes your acceptance of such changes.
XI. CARRIERS
Please note that the Carriers that issue your policies may have Personal Information about you. Our Policy does not govern their use of Personal Information about you. You should review the privacy notices of your Carrier(s) to understand how they collect, use, and disclose your Personal Information.
XII. CONTACT US
If you have any questions or comments about this notice, the ways in which PSIS collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights, or if you have an applicable disability and want to request access to this Policy in an alternative format, please do not hesitate to contact us at:
Phone: 1 (888) 995-0265