Last Updated: May 22, 2020
II. Information Collected.
We may collect Information about you in the following ways:
A. Information You and Others Provide to Us.
We may collect Information about you which you provide to us (directly or through one or more Third-Party Sources) including when you purchase or renew an insurance policy or annuity, when you make a premium payment or deposit on your insurance policy or annuity, when you fill out one or more of our applications or forms (through one of our websites or otherwise), when you call us (either directly or through a Third-Party Source), when you correspond with us by letter, fax, email or text message (either directly or through a Third-Party Source), when you call us (either directly or through a Third-Party Source), when you communicate with us via third-party social media sites (such as Facebook, Instagram, Twitter or LinkedIn), when you visit or use our websites, when you use any of the Haven Services, or when you otherwise interact with us.
The types of Information we may obtain directly from you and/or obtain or monitor from one or more Third-Party Sources include without limitation your name, gender, pictures, date of birth, age, place of birth, social security number, driver’s license number, passport number, other government identification numbers, current and former residential addresses, current and former postal addresses, landline and cellular telephone numbers, current and former employment details (including without limitation your employers’ names, addresses, telephone numbers and emails, your job titles, your supervisors’ names), your income, your assets and liabilities, and your credit worthiness and credit history. We may also collect from you and/or obtain or monitor from one or more Third-Party Sources your online presence, including without limitation your email addresses and third-party social media profiles (such as Facebook, Instagram, Twitter or LinkedIn). We may also collect directly from you and/or obtain and monitor from one or more Third-Party Sources transactional information (including without limitation policy coverages, premiums, account balances, payment history, claims history, service request history, Haven Services you have purchased or subscribed to, and billing addresses) as well as any contact or other information. Please be aware that the Information you choose to provide to us may reveal or identify information that is not expressly stated (for example, if you choose to provide your picture, your picture may reveal your gender). We may also collect any and all of the above Information with respect to any beneficiaries or contingent beneficiaries you may designate as part of any insurance policy or annuity you have purchased from us.
In addition, we may collect sensitive healthcare information known as PHI under HIPAA from you, healthcare providers working for you or us, other insurance companies and/or government sources.
C. Information We Collect Automatically When You Use the Haven Services.
When you visit or access the Haven Services, we may automatically collect Information about you, including without limitation:
- Usage Information: We may monitor user activity in connection with the Haven Services and may collect Information about the applications and features you use.
- Log Information: We may log information about you when you visit or use the Haven Services including your Internet Protocol ("IP") address, access dates and times, browser type and language, mouse clicks, mouse movements, scrolling activity, Internet Service Provider ("ISP"), and the URL of the web page you visited before navigating to the Haven Services.
- Device Information: If you visit or use the Haven Services from a mobile device, we may collect information about the device, including the hardware model, operating system and version, unique device identifiers, mobile network information (as allowed by the mobile network) or platform information (as allowed by the specific platform type). We may ask for or obtain your location based on information from your mobile device with your consent through our mobile apps.
- Information Collected by Cookies and Other Tracking Technologies: We may use various technologies to collect Information, which may include saving cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory (on a computer or mobile device) that help us to improve the Haven Services and your experience and to count visits. We may also collect Information using web beacons (also known as "tracking pixels"). Web beacons are electronic images (also called "gifs") that may be used in the Haven Services or in emails that help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. For more information about cookies and how to disable them, please see "Your Choices" below.
- Third Party Clear Gifs: Third-party service providers may employ clear gifs (also known as web beacons or web bugs), images, and scripts that help them better manage content on our websites. We do not tie the information gathered to your personal Information.
- Local Shared Objects: We may use Local Shared Objects (“LSOs”) such as HTML 5 to collect and store information in order to provide certain features on our websites. Third parties with whom we partner may also use LSOs in order to provide certain features on our websites or to display advertising based upon your Web browsing activity. Various browsers may offer their own management tools for removing HTML5 LSOs.
- Google AdSense: We may use Google AdSense to publish ads on our websites. When you view or click on an ad a cookie may be set to help better provide advertisements that may be of interest to you on our own or other websites. You may opt-out of the use of these cookies by visiting Google’s Advertising and Privacy page: http://www.google.com/privacy_ads.html.
- Advertising Cookies: We may partner with third parties to manage our advertising on our own or other websites. These third parties may use tracking technologies such as cookies to gather information about your activities on our own or other websites in order to provide you advertising based upon your browsing activities and interests. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website https://www.networkadvertising.org and from members of the Digital Advertising Alliance on its website http://www.aboutads.info. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website and from other advertisers at https://preferences-mgr.truste.com. Please note that opting-out will only prevent targeted ads so you may continue to see generic (non-targeted ads) after you opt-out.
- Do Not Track: Some browsers offer a “do not track” (“DNT”) option. Because no common industry or legal standard for DNT has been adopted by industry groups, technology companies or regulators, we may not respond to DNT signals. We may make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
C. Information We Collect from Other Sources.
III. Use of Information.
We may use any and all of the Information collected about you for the limited purposes of servicing your insurance policy or annuity with us, underwriting or offering you a new or amended insurance policy or annuity, underwriting or offering to repurchase your insurance policy or annuity, as well as providing the Haven Services and related functionality and services. This Information may be used to perform a variety of purposes including without limitation to:
- Pay, deny, adjust or modify claims and/or money due to you and/or any beneficiary or contingent beneficiary, on any insurance policy or annuity;
- Permit healthcare providers to verify coverage or authorize treatment;
- Investigate, detect and prevent false insurance claims, fraudulent transactions, unauthorized access to the Haven Services, and other illegal and/or fraudulent activities;
- Provide, operate, maintain and improve the Haven Services;
- Authenticate you as a user and/or to enable you to visit and use the Haven Services;
- Send you technical notices, updates, security alerts and support and administrative messages;
- Provide and deliver the services and features you request, process and complete transactions, and send you related information, including purchase confirmations, invoices and receipts;
- Respond to your comments, questions and technical and other requests and provide and improve customer service and support;
- Communicate with you about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about us and our select partners;
- Monitor and analyze trends, usage, and activities in connection with the Haven Services and for our marketing or advertising purposes;
- Personalize and improve the Haven Services, and provide content, features and/or advertisements that match your interests and preferences or otherwise customize your experience on the Haven Services;
- Link or combine with other Information we receive from Third-Party Sources to help understand your needs and provide you with better service;
- To assist you for any other lawful purpose, so long as you have presented us with a valid authorization form in writing permitting us to do so; and/or
- Assist us with other purposes about which we will notify you in writing.
IV. Sharing and Disclosure of Information.
A. Vendors, Consultants and Other Service Providers.
We may share Information about you with third-party vendors (such as third-party administrators), consultants, other service providers and/or other partners who are working on our behalf and require access to Information about you to carry out that work. These third parties are authorized to use your Information only as necessary to provide services to us and/or our affiliates.
B. Compliance with Laws.
We may disclose Information about you to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable laws, regulations, legal process, subpoenas, law enforcement demand or request or other governmental demand or request, (b) to enforce our agreements, policies and terms of service, (c) to protect the security or integrity of the Haven Services, (d) to protect (i) any insured, owner, beneficiary or contingent beneficiary of an insurance policy or annuity, (ii) us and/or any of our affiliates, and/or (iii) the public, from harm or illegal or fraudulent activities, (e) to respond to an emergency which we believe in the good faith requires us to disclose Information to assist in preventing the death or serious bodily injury of any person, (f) with respect to your medical information, to health care providers or other insurance companies in compliance with HIPAA and any other similar applicable state law, or (f) with your prior consent to any other third party.
C. Business Transfers.
We may share or transfer Information about you in connection with, or during negotiations of, any merger, acquisition, sale or financing of all or any portion of our business or its assets to another company.
D. Aggregated or Anonymized Data.
We may share aggregated or anonymized Information with third parties that does not directly identify you, for any purpose described in this section and for testing and research purposes.
While no service is completely secure, we will endeavor to take reasonable measures to help protect Information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. For example, sensitive information such as credit card numbers that we may request from you will be protected with encryption, such as Secured Socket Layer (SSL) protocol, during transmission over the Internet. The servers on which personal Information is stored are kept in a controlled environment with limited access. While we will endeavor to take reasonable efforts to guard personal Information we knowingly collect directly from you, no security system is impenetrable. If we choose to make certain of your account information available online, you may access that account information and the Haven Services only through the use of an individual user identification and password. To protect the confidentiality of personal Information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. Always logout and close your browser when you finish your session. Please note that we will never ask you to disclose your password in an unsolicited phone call or email. If you wish to communicate Information to us which you consider confidential or highly sensitive, please consider not using email. Email is typically not encrypted and therefore not secure. An email message can potentially by viewed by others without your knowledge or consent while in transit to us or after you have sent it. If you have any questions about the security of your personal Information, you may contact us at contact at firstname.lastname@example.org.
V. Your Choices and Rights.
A. Account Information.
You may access, update, or correct Information about you at any time by corresponding with us (either directly or through one of our Third-Party Sources) by letter or fax, by calling us (either directly or through one of our Third-Party Sources), or by emailing us at email@example.com. Upon your written request, we will provide you with data about whether we hold, or process on behalf of a third party, any of your personal Information (including without limitation medical information) that we are aware of. If we agree with your update or correction request, we will make the changes; if we disagree with your request, we may provide you with a short statement of the reasons for the disagreement. To request this data, email us at firstname.lastname@example.org.
B. Deletion of Account Information.
You can request that we delete all of your Information. However, we cannot delete your Information except if we also terminate your insurance policy or annuity (see below under Account Termination). In that case, we will only delete your Information after the retention periods set forth below under Account Retention. We may not accommodate a request to delete Information if we believe the deletion would violate any applicable law, regulation or legal requirement or cause other data we process to be incorrect or incomplete. In addition, we cannot completely delete your Information as some data may rest in previous backups. These backups will be retained for the periods set forth in our disaster recovery policies.
C. Account Termination.
To inform us of your interest in terminating your insurance policy or annuity with us, please email us at email@example.com so that we can make the necessary arrangements.
D. Account Retention.
E. Promotional and Newsletter Communications.
You may opt out of receiving promotional and newsletter emails from us by following the opt-out instructions provided in those emails or by emailing us at firstname.lastname@example.org. If you opt out, we may still send you non-promotional communications, such as security alerts and notices related to your access to or use of the Haven Services or our ongoing business relationship.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies or to prompt you before accepting such a cookie. Please note that, if you choose to remove or reject browser cookies, this could affect the availability or functionality of some or all of the Haven Services.
G. Social Media Features and Widgets.
H. Community Forums and Blogs.
We may display personal testimonials of satisfied policy and annuity holders on our websites in addition to other endorsements. With your consent we may post your testimonial along with your name or partial name.
J. Links to Third Party Websites.
VI. HIPAA and State Law.
A. Compliance with HIPAA and State Law.
B. Permitted Sharing Under HIPAA and State Law.
- Servicing your insurance policy or annuity with us, including without limitation (a) paying, denying, adjusting or modifying any claims and/or money due to you and/or any beneficiary or contingent beneficiary, on any insurance policy or annuity, (b) underwriting or offering you a new or amended insurance policy or annuity, and/or (c) underwriting or offering to repurchase your insurance policy or annuity; and/or
- Investigating, detecting and/or preventing false insurance claims, fraudulent transactions, unauthorized access to the Haven Services, and other illegal and/or fraudulent activities.
VII. Other Provisions.
A. Fair Credit Reporting Act.
We will not share Information subject to the Fair Credit Reporting Act with our affiliates or any other person or entity, except in compliance with applicable laws and regulations.
B. California Residents.
Under California law, California residents who have an established business relationship with us may choose to opt out of our disclosure of personal Information about them to third parties for direct marketing purposes. If you choose to opt-out at any time after granting approval email us at email@example.com.
California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of the Haven Services that are California residents and who provide Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Information and the names and addresses of those businesses with which we shared your Information with for the immediately prior calendar year (e.g. requests made in 2019 will receive information regarding such activities in 2018). You may request this information once per calendar year. To make such a request, please send an email to firstname.lastname@example.org.
C. Our Policy Toward Children.
The Haven Services are not directed to individuals under the age of 18. Except as required by applicable law or with respect to beneficiaries of our insurance policies or annuities, we do not knowingly collect personal Information from individuals under the age of 18. If you become aware that an individual under the age of 18 has provided us with personal information, email us immediately at email@example.com. If we become aware that an individual under the age of 18 has provided us with personal Information (other than with regard to the noted exceptions), we will take steps to delete such Information.