This Policy will inform you as to how we look after your personal information, your privacy rights, how the law protects you, and our practices for collecting, using, maintaining, protecting and disclosing your personal information when you visit our website(s), www.aims4claims.com and/or www.alliedmanagedcare.com (our “Website”), or transact with us (collectively, the Website and our services are referred to as the “Services”)
Please read this Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services because we will not be able to perform the Services.
- IMPORTANT INFORMATION
- Directly from you when you visit our Website or communicate with us or our representatives (whether electronically, by telephone or paper forms);
- From our clients who contract with us to provide claims administrator services; and
- From our Services, including claim handling, loss adjustment, or similar processes such as claim forms, telephone calls, e-mails and other communication with us, as well as from third parties such as claim investigators, medical professionals, witnesses or other third parties involved in our business dealings with you.
- THE PERSONAL INFORMATION WE COLLECT
We collect types of information which identify, relate to or is reasonably capable of being associated with a particular individual (“Personal Information”) such as:
General Identification and Contact Information
- Your name, e-mail address, telephone numbers, gender, marital status, family status, date of birth, place of birth, educational background, physical attributes, activity records, driving records, photos and video images, employment history, skills and experience, professional licenses affiliations, relationship to policyholder, insured or claimant, date and cause of death, injury, or disability.
- Identification numbers issued by government bodies or agencies such as Social Security Number, passport number, tax identification number, military identification number, or drivers licenses or other license numbers.
- Bank account numbers and account details, credit history and or credit score
- In certain cases, we may receive information about your current or former physical or mental or medical condition, health status, injury or disability information, medical procedures performed, personal habits (for example, smoking or consumption of alcohol), prescription information and medical history.
- Recordings of telephone calls to our staff
- Information to investigate crime, including fraud and money laundering: For example, insurers commonly share information about their previous dealings with policyholders and claimants for this purpose.
- In certain cases, we may receive sensitive information about your trade union membership, religious beliefs, political opinions, family medical history or genetic information (for example, if you apply for insurance through a third-party marketing partner that is a trade, religious or political organization). In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud
- Location and identification of property insured (for example, property address, vehicle license plate or identification number);
- Travel arrangements including reservation numbers, destination and hotel details
- Policy details and claim numbers, details of policy coverage and cause of loss; and
- Prior accident or loss history, your status as director or partner or other ownership or management interest in an organization and other insurance policies you hold
- HOW PERSONAL INFORMATION IS COLLECTED
We use different methods to collect this information from you and about you including:
- Direct interactions. You may give us your Personal Information by filling in forms or by corresponding with us by mail, phone, e-mail or otherwise. This includes Personal Information you provide when you:
- Use our Services
- Request marketing be sent to you;
- Fill out a form or contact our representatives; or
- Give us some feedback or report a problem with our Services.
- Third parties or publicly available sources. We may receive Personal Information about you from various third parties and public sources as set out below:
- From our clients and business partners, such as through our Services, including claim handling, loss adjustment, or similar processes such as claim forms, telephone calls, e-mails and other communication with us, as well as from third parties such as claim investigators, medical professionals, witnesses or other third parties involved in our business dealings with you (the “Services”).
- Web analytics providers.
- Advertising networks.
- Search information providers.
- HOW WE USE PERSONAL INFORMATION
The Company will not sell or otherwise transfer or disclose Personal Information to third parties not affiliated with the Company or providing Services to you without your prior consent, except as may be required by law, such as a court-ordered subpoena, search warrant, or other court order; or required by exigent circumstances. That means that the Company will never disclose your name, e-mail address, street address or phone number to third parties not affiliated with the Company or providing Services to you without your consent.
We may use information that we collect about you or that you provide to us, including your Personal Information for the following purposes:
- To fulfill or meet the reason you or your employer provided the information.
- Communicate with you and other interested parties to manage your claim.
- 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.
- Send you important information regarding your claim and other administrative information.
- Make decisions about claim assessment, processing and settlement.
- Manage claim disputes, where applicable.
- To provide you with updates and marketing communications about products, services and offers that may be relevant to you.
- Manage our business operations to comply with internal policies and procedures, including those relating to auditing finance, accounting and billing, IT systems, data and website hosting, business continuity, document and print management. 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 process your requests, purchases, transactions, and payments and prevent transactional fraud.
- Prevent, detect and investigate crime, including fraud and money laundering, and analyze and manage other commercial risks.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- Conduct satisfaction surveys.
- Resolve complaints, and handle requests for data access or correction.
- Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and comply with legal process and respond to requests from public and government authorities (including those outside your country of residence).
- To provide, support, personalize, improve and develop our Website, Services, and products.
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets and business.
- Tailor your experience at our Webite, and to compile and display content and information that we think you might be interested in and to display content according to such preferences, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
- To enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Website users is among the assets transferred.
- As described to you when collecting your Personal Information.
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 YOUR PERSONAL INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose your Personal Information to affiliated companies and external parties for business purposes, and when we do so, the parties are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. We may make Personal Information available to the following external parties for the purposes of claim assessment and processing or as required by law:
Other Insurance Parties
- In the course of processing claims, we may make Personal Information available to third parties such as reinsurance brokers, appointed representatives, distributors, financial institutions, securities firms and other business partners.
- External third-party service providers, such as medical professionals, accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; travel and medical assistance providers.
- IT systems, support and hosting service providers, document and records management providers and outsourced service providers that assist us in carrying out business activities.
- Banks and financial institutions that service our accounts, third-party claim administrators, claim investigators, construction consultants, engineers, examiners, jury consultants, translators and similar third-party vendors.
Authorities and Third Parties Involved in Legal Action
- We may share Personal Information with government or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate:
- to comply with applicable law and regulations, including those outside your country of residence;
- to comply with legal process;
- to respond to requests from public and government authorities including public and government authorities outside your country of residence;
- to protect our operations or those of any of our group companies;
- to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and
- to allow us to pursue available remedies or limit our damages.
Other Third Parties
- We may share Personal Information with emergency providers (fire, police and medical emergency services); retailers; medical organizations and providers; travel carriers; credit bureaus; credit reporting agencies; and other people involved in an incident that is the subject of a claim; as well as purchasers and prospective purchasers or other parties in any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business. To check information provided, and to detect and prevent fraudulent claims, Personal Information (including details of injuries) may be put on registers of claims and shared with other insurers. We may search these registers when dealing with claims to detect, prevent and investigate fraud.
- CHILDREN AND PRIVACY
Our Website and Services are not intended for children under the age of 16 and we do not knowingly collect, use, disclose or sell Personal Information from children under age 16. If you know or suspect that your child has submitted Personal Information to us and you would like to request that such information be removed, you may do so by contacting us at the address listed below in the Contact Information section.
- INTERNATIONAL TRANSFER
If you are located in a province, country, or other government jurisdiction outside of the United States, and if you choose to provide your Personal Information to the Company through our Services, please be aware that your personal information will be transferred to and maintained on computers located in the United States and the applicable US privacy laws may not be as protective as those in your jurisdiction.
- DATA SECURITY
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. We also limit access to Personal Information to those employees, agents, contractors, and other third parties who have a business need to know. These individuals will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.
We will take all appropriate reasonable technical, legal and organizational measures, which are consistent with applicable privacy and data security laws to safeguard your Personal Information. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of the data transmitted to or through our Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any personal data you might have with us has been compromised), please immediately notify us.
Where we provide Personal Information to an external party, the party will be selected carefully and required to use appropriate measures to protect the confidentiality and security of your Personal Information.
- DATA RETENTION
- CALIFORNIA PRIVACY RIGHTS (effective January 1, 2020)
THE PERSONAL INFORMATION WE COLLECT
In the last twelve (12) months, the Company has collected the following categories of Personal Information:
Examples of Information Under This Category
(*Not all of this information is collected by the Company)
|Whether this Information is Collected|
|A. Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, government issued identification number, or other similar identifiers.||We may collect Personal Information within this category.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code section 1798.80(e))||A name, signature, Social Security number, physical characteristics or description, address ,telephone number, government issued identification number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number or any other financial information, medical information or health insurance information.||We may collect Personal Information within this category.|
|C. Protected classification characteristics under California or federal law||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||We may collect Personal Information within this category.|
|D. Commercial information||Records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.||We do not collect any Personal Information within this category.|
|E. Biometric information||Genetic, physiological, behavioral, and biological characteristics, fingerprints, faceprints and voiceprints,.||We do not collect any Personal Information within this category.|
|F. Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application or advertisement.||We may collect Personal Information within this category.|
|G. Geolocation data||Physical location.||We may collect Personal Information within this category.|
|H. Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.||We may collect Personal Information within this category.|
|I. Professional or employment-related information||Current or past job history.||We may collect Personal Information within this category.|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.W. 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.||We do not collect any Personal Information within this category.|
|K. Inferences drawn from other personal information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||We do not collect any Personal Information within this category.|
Personal Information does not include publicly available information from government records, de-identified or aggregated consumer information, or other information specifically exempted by statute (such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and other sector-specific privacy laws (including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994).
DISCLOSURE OF YOUR PERSONAL INFORMATION
- Disclosures of Personal Information for a Business Purpose. In the preceding twelve (12) month period, we may have disclosed information within the following categories of Personal Information for a business purpose: (A) Identifiers, (B) Personal information categories listed in the California Customer Records statute, (C) Protected classification characteristics under California or federal law, (F) Internet or other similar network activity, (G) Geolocation data, (H) Sensory data, (I) Professional or employment-related information.
In the preceding twelve (12) month period, we may have disclosed Personal Information for a business purpose to the following categories of third parties:
- Clients who contract with us to provide claim administrator services
- Service providers
- Affiliated companies
- Sales of Personal Information. We do not, and do not intend to, sell your Personal Information. The Company does not sell any categories of Personal Information to any external parties that are considered to be a “third party” as such term is defined under California Civil Code section 1798.140, and the Company has not sold any Personal Information in the preceding twelve (12) months.
YOUR CONSUMER RIGHTS UNDER CALIFORNIA LAW
Consumer Requests: Your Rights and Choices About Personal Information Under California Law
This section describes your CCPA rights and how to exercise those rights by submitting a consumer request (“Consumer Request”). In some instances, where we are acting as a “service provider,” we may direct consumer requests to the business who holds your Personal Information.
- Access to Specific Information and Data Portability Rights
You have the right to request that the Company disclose certain or all of the following information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive a verifiable Consumer Request, we will be able to disclose to you any of the following information if we have it:
- 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 purposes for collecting or selling that Personal Information.
- The categories of third parties to whom we disclosed that Personal Information.
- The specific pieces of Personal Information we collected about you (also may be called a data portability request).
- If we sold or disclosed your Personal Information for a business purposes, we will provide you with two lists disclosing (if applicable):
- Sales, identifying the Personal Information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
- Deletion Request Rights
You have the right to request that we delete any or all of your Personal Information that we collected from and about you, subject to certain statutory exceptions. Once we receive a verifiable Consumer Request, we will identify the Personal Information, confirm that you want that Personal Information deleted, and then delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may be unable to comply, or may deny, your deletion request if retaining the Personal Information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract(s) with you.
- 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 section 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.
- 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 will not discriminate against you for exercising any of your legal rights regarding your Personal Information, unless permitted by law. We will not take any of the following actions solely because you chose to exercise any of your legal rights regarding your Personal Information:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.
- Provide you a different level or qualify of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- Disclosures for Direct Marketing
California Civil Code Section § 1798.83 permits users of our Services 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 e-mail us at the address listed in the Contact Information section below.
How to Submit a Consumer Request
To exercise your access, data portability, and deletion rights, please submit a Consumer Request to the contact information below. The Consumer Request must describe the request with sufficient detail that allows us to properly understand, evaluate and respond to it. Please specify if your Consumer Request pertains to all specific pieces of your Personal Information, or only with respect to the categories of Personal Information. You may only make a Consumer Request for access or data portability twice within a twelve (12) month period.
How We Will Verify Consumer Requests
Only you, or a person or entity that you authorize to act on your behalf, may make a Consumer Request related to your Personal Information. To designate an authorized agent, we will ask you provide us with legal documentation (such as power of attorney documentation) or written permission and the agent will need to verify their own identity with us.
We reserve the right to require you to provide additional information to enable us to reasonably verify that you are the person about whom the Personal Information pertains in order to release the requested information to you (or your authorized representative). If you have an account with us, you will be asked to use the standard authentication procedures to access your account. If you do not have an account with us, you will be asked to verify certain pieces of your Personal Information. If we are unable to verify your identity, we may be unable to provide you with information responsive to the request.
How We Will Respond to Consumer Requests
We endeavor to respond to verifiable Consumer Requests within forty-five (45) days after receipt. If we require more time (up to 45 days) we will inform you of the reason and extension in writing. If you have an account with us, we will deliver our written response(s) to that account. If you do not have an account with us, we will deliver our written response(s) by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the Consumer Request. If we deny (or cannot comply with) the Consumer Request, we will explain why. 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. We do not charge a fee to process or respond to your Consumer Request unless such request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why and provide you with a cost estimate before completing your request.
- Contact for General Inquiries, Consumer Requests, and Requests to Change Information
If you provided us with Personal Information and would like to exercise your access, data portability, deletion or other disclosure rights, or request changes to your information, please contact us in one of the following methods.
Telephone: (800) 444-6157
Mail: P.O. Box 269120
Sacramento, CA 95826
Attn: Larry Hunt, Senior Vice President Corporate Affairs