BenefitHub Privacy Policy

Last Updated on May 16, 2025

BenefitHub, Inc., including our affiliates, which include Abenity, LLC, BenefitHub, Ltd., BenefitHub Technology Canada Ltd., Motivano, Inc. and Insurean, Inc. (collectively “BenefitHub”), wants you to understand how we handle your personal information. We also want you to know your rights and choices.  BenefitHub is referred to in this policy (“Privacy Policy” or “Policy”) as “we”, “our” or “us.”  In this Privacy Policy, the terms “include”, “includes” or “including” or “such as” mean “including but not limited to”.

This Policy describes how we handle your personal information when you access or use the following BenefitHub services (“Services”):

• our websites, such as benefithub.com, abenity.com, and their respective subdomains as well as vanity domains and websites which offer the Services, including your organization’s BenefitHub website located often at “organization’s name.benefithub.com” ;
• our applications, which include our web based BenefitHub and Abenity  application, our mobile apps for both iOS and Android, any white labeled apps developed for specific clients, our back-office systems that include email processing, data analytics, customer support, finance or customer management systems;  

• third-party merchant offers;
• our get an insurance quote feature;  and
• anywhere that we gather information from or about you and refer you to this Privacy Policy.

How we handle information about you depends on which Services you use and how you use them. For example, we use different information about website visitors than users of our get an insurance quote feature.

Also be aware that certain aspects of the Services are provided by third parties and may work different from how we operate.  For example, offers from third-party merchants marketing and selling their products and services through our Services contain links to their websites, which have additional terms that supplement this Policy.  We do not own, operate or control those third-party websites and we advise you to review their individual privacy policies in order to understand the privacy practices of those merchants.  Also with regard to such third-party merchants, we may be required to share the information that you provide to us with such merchants.  For more information about such third parties, please see below, including “For Transactions” under “Information Collected Through the Services” below, as well as “What about Third-party Products and Services, “ “Merchants, Advertisers and Other Third-Party Partners” and “Third-Party Partner Site Data Sharing” below.

If you have any questions, please do not hesitate to contact us at DPO@benefithub.com.  For more information about how to contact us, please see Section 12 below.

1. What Information Do We Gather About You?

The information that we gather about you depends on the context. Generally, the information gathered about you can be used to personally identify you either on its own or when combined with other information.

Below is a description of the information that we collect and how we obtain it.

1(A) Information Collected through the Services.

• For Registration:

When you sign up for the Services, we collect personal identifiers such as your contact information, including your name and email address, and other account credentials such as postal code and country of residence.  We may also ask you to create an account name. Once you’re registered, we assign you a unique ID number. The ID number helps us with recognizing you when you are signed in.  When you create an account or at any time thereafter, you also have the opportunity to provide us with information to further complete your profile, including information regarding what you are interested in, who comprises your family and how much you might spend in certain instances.  All of the information that you provide to us for your profile enables us to provide a more personalized experience for you as you use our Services.   

Over the course of your use of the Services, we may request additional information about you, in order to provide you with an even more personalized experience.  For example, and as described in the section on “During Contact with Our Call Centers (Internal and Offshore)” below, if you contact Customer Care, you may be asked to provide information such as your telephone number and payment information.  As another example and as described in the section on “For Offers and Sweepstakes;  Notice of Financial Incentives” below, when you sign-up to receive special offers or enter a sweepstakes, you may also be asked to provide information including your name, email address and other personal information.  As an additional example of when we may request more information about you, if you contact one of our insurance agents or use our get an insurance quote feature, you may be asked to provide information such as your name, address, telephone number, email address and other relevant information.  The foregoing is not a complete recitation of all of the instances where we may request additional information about you over the course of your use of the Services;  nor is the foregoing a complete recitation of the all of additional information that we may request about you during the course of your use of the Services.

• For Transactions:

To process any transactions that we may handle, such as payments or completing a purchase, including obtaining an insurance quote or binding an insurance policy, we would collect and use your personal information. The foregoing may include your name, address, telephone number, email address, credit card number and banking information, and any other relevant information.  Such information may need to be shared with our business partners where appropriate, including for the process of obtaining an insurance quote or binding an insurance policy.

• For Offers and Sweepstakes;  Notice of Financial Incentives:

Our Services provide you with access to offers, including promotions and giveaways, from third parties, such as and again merchants. Your accessing such offers involves the collection of personal information. We use this information for the purposes described in this Privacy Policy, including for targeted advertising. We may share your personal information with third parties as described in this Privacy Policy, including merchants, authentication service providers, data analytics providers, advertising technology vendors and social media platforms. 

From time to time, we may also offer certain opportunities through sweepstakes. When you sign up for same, you may provide us with information including your name, email address and any other required information.  Note, that sweepstakes and giveaways are not available to users outside the United States (“US”), including in the United Kingdom (“UK”), unless explicitly stated in the applicable posted rules for such sweepstakes and giveaways.

Note too, that you may have opportunities, such as through such offers or sweepstakes, to earn “rewards” (“Incentive Program(s)”). We will provide you with a full description of the Incentive Program, including the benefits offered and related legal terms. Since such Incentive Programs involve the collection of personal information, they may be interpreted as “financial incentive” programs under California law (or other similar concept under another law). We use such information for the purposes described in this Privacy Policy, including for any targeted advertising as described below in this Privacy Policy. We may share your personal information with third parties as described in this Privacy Policy, including data analytics providers, advertising technology vendors and social media platforms.  The value of any financial incentive that we offer is reasonably related to the value of any personal information you provide to us. We estimate the value of your personal information by considering, without limitation, the expenses that we incur from collecting your personal information and/or providing the financial incentive to you, the revenue generated by your use of the financial incentive and any improvements that we can make to our Services based on information obtained through the financial incentive program.  Please note that we may provide additional terms that apply to a particular financial incentive. If applicable, those terms will be presented to you at sign up for same. You may cancel your participation in any such Incentive Programs at any time by contacting DPO@benefithub.com. 

Furthermore, your personal information may need to be shared with third parties who are involved in administering Incentive Programs, such as payments in connection with such programs.  Details regarding the foregoing would be available in the terms of the particular Incentive Program.  Additional information about the foregoing can be found in Section 3(A) of this Privacy Policy.  

• For Research:

We may gather personal information through questionnaires, surveys and feedback programs.  In such cases, we will request your consent to provide on a purely voluntary basis information regarding your interests in various topics, including travel, entertainment and health and wellness, as well as demographic information, some of which may be considered sensitive under applicable laws such as your age, ethnicity, race, gender, family characteristics and income. We may use service providers to support any such questionnaires, surveys and feedback and personal information is shared with or collected by them as described below in Section 3(B) with respect to service providers in general.  Such questionnaires, surveys and feedback may be used for a variety of purposes described throughout this Privacy Policy, including research for marketing of the Services, as well as research for third-party advertisers that are interested in targeting ads to particular groups of users of the Services. Please see Section 2 below for the definition of service provider.  

As described in more detail below, we may combine information from the activities above, as well as from or regarding your use of the Services in general, with information collected automatically from the Services; and, we may also apply internal or third-party machine learning or artificial intelligence large language models or applications to this information, alone or in combination with other personal information that we collect about you.  For more information about other information that may be collected about you, please see the “Information Collected from Other Sources” section below.  The above described combining of data may be done for amongst other purposes of improving the Services,  marketing research, to personalize marketing of the Services to you and/or to create audiences for third-party advertisers.

• During Contact with Our Call Centers (Internal and Offshore):

We collect information from you when you contact Customer Care through one of our telephone numbers, whether for customer service or general inquiries about the Services.  Such information can include your name, contact information, information about your account and any other information you choose to provide.  Note, that our insurance-related services are generally provided from a location within the US and that we do have a Call Center in India.

• During Contact with Our Live Chat or Chabot Features:

We collect information from you when you interact with the live chat or chatbot features on our websites.  The features enable you to ask a question and supply whatever information you deem relevant.  Such live chat and chatbot features are provided by third-party service providers.  Please see Section 2 below for the definition of service provider.

• When Requesting a Demo of our Services:

When you request a demo of our Services, we also request and collect information about you, including your name, email address and telephone number and the name of your employer or the organization that you are affiliated with.  The foregoing information is stored by the service provider that we use for sales process-related services.  For more information on the topic of service providers, please see Section 2 below.

• When Interacting with Us at Events:

When attending events, including industry or networking events and the like, where a BenefitHub representative is present, you may provide them with personal information, including  your name, email address, phone number, company affiliation and job title.  We typically use such data for follow-up communications, lead generation, market research and networking purposes and we may share that information with our service providers for such purposes, including storage of the information.  Again, for more information about service providers, please see Section 2 below.

• When Interacting with Us in Other Ways:

When you send us an email, we collect information too, such as your name and email address, as well as your telephone number and the name of your employer or the organization that you are affiliated with if requested and provided.  In addition, when you complete a form that is available on our websites, such as to sign up for our blog or one of our webinars, to request customer assistance or to learn more information about becoming a broker, client, merchant or advertiser,  we collect the information that you provide to us in connection with completing such form.  Such information would similarly include your name and email address, your employer or the organization that you are affiliated with and all other information that you provide to us in connection with completing the form.  The foregoing information is similarly stored by the service providers that we use for sales process-related services and other services.  Further note, that the foregoing is not a complete recitation of all of the other instances under which we may collect information about you.   Also and again, see Section 2 below for more information on the topic of service providers.

We generally do not want to receive sensitive personal information about you.  However, it may be necessary for you to share such information in connection with your use of the Services, including when you obtain insurance quotes, when purchasing items directly from us via our storefront, for more personalization of your experience with the Services and, as indicated directly above, when you interact with Customer Care. Such information includes the following:

• government-issued IDs (such as your driver’s license or passport or social security number);
• your racial or ethnic origin;
• your health;
• your precise geolocation;  and 
• account access information, such as a username and password (- note, that we collect the foregoing information only for the account that you create with us and not for any other account that you may have with any third-party).

In addition, and as explained in the section on “Research” above, there are situations when we may request certain sensitive personal information, such as a user survey that may ask about your political leanings or ethnicity. You will always have the option to decline to participate in any such surveys or other feedback programs. Outside of any of the situations described above, we would prefer that you never provide any sensitive personal information to us.

When you use the Services, we do collect some information automatically too. The technologies that we use to assist with such data collection include cookies, web beacons, tags, scripts and software development kits (or SDKs). We may also use newer technologies, such as clean rooms and matching services, as described below, as many browsers begin to deprecate third-party cookies. We use such technologies on our digital properties, including our websites and apps, as well as in our email communications. In addition, we use push technologies and in-app location technologies, as well as browser extensions and search and saved search functionalities.  In order to obtain more information about how to manage tracking methods on the Services, please read our Cookie Policy,  refer to your browser’s “help” section, see www.allaboutcookies.org or see the section on “What Are Your Rights and Choices?” below.

The categories of personal information that we collect automatically include those that follow below.

• Identifiers and Device Information:

When you access our Services digitally, including our websites, apps and email communications, our servers use a variety of technologies in order to automatically  receive, record and/or log information about the device that you are using, including unique identifiers. If your browser does not accept our cookies or similar technologies, you may not be able to access certain parts of our websites or apps (e.g., your account on our website or app). The items that may be collected include the following:

• your IP address;
• cookie identifiers;
• your operating system and browser (e.g., type, version and configuration);
• your browser language;
• device identifiers (such as MAC address);
• advertising identifiers;  and
• the unique ID that we assign to you when you register, as described above.

We combine the data above with other information that we collect about you.  The technologies that we use, as further described above, are provided by service providers, who also collect information for us and who store information for us.  Please see Section 2 below for more information about service providers.  

We similarly collect information regarding you if you just visit our websites and are not signed up for the Services – i.e., you are not a registered user.  For example, we collect and aggregate information about you, including which pages you visited, the order in which they were visited and which links were "clicked."  Collecting the foregoing information involves the logging of information, including your IP address, operating system and browser software, such as browser extensions and similar technologies.  Browser extensions can extend the functionality of web browsers, allowing users to customize their browsing experience and access specific features;  and, similar technologies include web apps and plugins, each offering unique capabilities for customizing a user’s browsing experience. 

Based on your device type, operating system, app usage and other user-defined segments, you receive “push” notifications.  Those are small, broader messages that pop up on your device, even when you are not actively using our apps or websites.  They can be informative or promotional and are a way for us to send timely information directly to a user's device without the need for the user to actively check the website or app.

In addition, when you request a demo or otherwise contact us about business opportunities, such as for information regarding the merchants who offer products and services on our websites and apps, information about you may be collected automatically too.  For example, you may be able to fill out a form on our website that provides you with the ability to furnish information about you, such as your name, email address and telephone number and the name of your employer or the organization that you are affiliated with.  For more information about the foregoing, please see the “When Requesting a Demo of our Services” section above.

• Geolocation Information:

Where applicable, we may use location information, such as your city, state and zip code, to personalize content provided to you. For example, we may use location information, such as zip code, to provide you with merchant offers in your area.  For additional information on the foregoing, please see the discussion about personalization in Section 2(B) below.  We may also, as discussed above in Section 1(A)(i), provide you with the opportunity to share more of your location information in your account profile in order to have an even more personalized experience when using the Services.

Our native and web apps, as well as websites, may provide content based on your GPS location if that feature is available and you enable it. Your GPS location is your precise geolocation, which (as noted above) is considered a type of sensitive personal information. You choose whether to enable GPS features when you first install our apps.  Browser geolocation is a technology supported by web browsers too.  You can edit the foregoing settings on your devices at any time.

If you enable said features, your GPS location can be found by satellite, cell phone tower or Wi-Fi and used by our apps and websites.  You can, in turn, receive alerts or messages based on your current location as determined by GPS, including from our service provider, allowing for targeted, time-sensitive notifications based on where you are in real-time. 

You may also receive push notifications based location data that we may collect.  For more information about push notifications, please see the “Identifiers and Device Information” above."  These messages can be informative or promotional and are a way for us to send timely information directly to a user's device without the need for the user to actively check the website or app. 

With regard to in-app location technology, or location-based services, such technology utilizes real-time data from your device, as determined by GPS, Wi-Fi or cellular network, to ascertain your location.  With such data, we are in turn able to deliver contextually relevant information based on your location.   

If you save a location-based search in your history, that data moves to our service providers’ servers too.  Again, please see Section 2 below for the definition of service provider.

If you do not enable GPS location-based services, or if a specific app or website does not have location-based features, we would not collect your precise GPS location. We do, however, collect your IP address, which can establish your approximate location. Ads on our sites and apps may be targeted based on this approximate location.  We use service providers to serve ads;  and, again, please see Section 2 regarding the definition of service providers. 

• Other Usage Data:

We collect information about certain internet and network activity on the Services, including  your interactions with our websites and apps, such as your search history and saved searches, your “likes” of products or services offered by the merchants on our sites or apps, the URLs of any pages that you visit on our sites and apps, the URL of the website from which you came to our sites, how long you spent on a page, access times, search queries and other details about your use of and actions in connection with our Services. The foregoing also includes your interactions with marketing and advertisements on the Services.  Our service providers do assist us with such data collection, as well as store such data for us.  Once again, more information about service providers may be found in Section 2 of this Privacy Policy.  In addition, more information about the collection of usage data can be found at “Information Collected Automatically” and in the “Identifiers and Device Information” section above. 

As described elsewhere in this Policy, we may use such usage data to personalize or customize content for you that we believe might be of interest to you based on your usage patterns or for other similar purposes. We may also use such data to improve the Services.  For example, such data can tell us how often users use a particular feature of the Services, and we can, in turn, use that knowledge to make the Services interesting to as many users as possible. We also use such information for surveys or questionnaires based on your usage patterns. We combine the foregoing data with other information that we, or our service providers and other third parties, such as the organization to which you belong and merchants who offer products and services on our websites and apps (as further described in the “For Offers and Sweepstakes;  Notice of Financial Incentives” and “Identifiers and Device Information” sections above and in  Section 1(C) below) may collect about you.  The foregoing may include adding such information to your user profile. Not only do we use the data that we, our service providers and other third parties collect to create a picture of a given user, but we and our service providers use such data to create a real-time view of a user.  The foregoing enables us, our service providers and our third-party advertisers to, amongst other things, create personalized advertising campaigns and improve the effectiveness of marketing and advertising on or through the Services.  More information about service providers can, again, be found in Section 2 below.

1(B) Inferences; Information We Create or Generate.

We and our service providers may infer new information from other data that we collect, including using automated means such as machine learning, which may include third-party machine learning services or large language models. Such inferences would include information about your likely preferences or other characteristics (e.g., products or markets of interest to you). As described below, we use such inferences for purposes of personalization, in order to improve our Services, market the Services to you and create audiences for third-party advertisers and marketing on our apps and websites and/or other sites and services and for other purposes.  Again, please see Section 2 below, regarding the definition of service providers. 

1(C) Information Gathered from Other Sources.

Marketing, data analytic and social media-owned databases give us access to a range of information, such as public data, survey data and more.  Such data may sometimes include your mailing address, your gender, your age, your household income and other demographic data. As described elsewhere in this Policy, including in Section 2 below, we receive information about you from some of our service providers, as defined in such section.

Social media platforms include Instagram, Facebook and LinkedIn. Third-party services include services such as Google.  You may be able to link your social media or other third-party account to the Services.  By linking that account, you authorize us to collect, store and use any information that the social media platform or third-party service may provide to give us, including your name and email address.  You should be able to disconnect such link at any time.  Note, that such disconnection does not also include deletion of data that has been collected.  For more information on the foregoing, please see the paragraphs that follows, as well as Sections 2(G) and 4(A) below.

We also receive information from you when you interact with our pages, groups, accounts or posts on social media platforms. The foregoing includes aggregate data on our followers, such as age, gender and location, engagement data, such as “likes,” comments, shares, reposts and clicks, awareness data, such as number of impressions and reach, and individual users’ public profiles.  You should familiarize yourself with the privacy practices of such social media platforms and third-party services.

When your employer or the organization to which you belong obtains a company- or organization-wide subscription to the Services, they may provide us with your name and company or organization or personal email address in order for you to be granted access as a user of the Services.  We may also be provided with your name and contact information in connection with alumni programs offered to your former employer or to an organization that you belonged to or were affiliated with previously.

iv. Friends and Family:

Your name and email address may also be provided to us through our friends and family program.  If one of your friends or family members is a registered user of the Services, we may provide them with the ability to refer a friend or family member to us in order to enable them to access the Services too.    

Third parties, such as merchants, whose offers are provided through the Services, may also provide us with information regarding you.  Note, that merchants may be engaged directly by the employer or organization to which you belong.  For more information about such third parties, see the “For Transactions” and “For Offers and Sweepstakes;  Notice of Financial Incentives” sections above, the “Third-Party Partner Site Data Sharing” section below, as well as Section 2(F) below.

Our websites and apps may also contain third party advertising.  Your interactions with such advertising will therefore be subject to additional terms and conditions on the use and disclose your personal information.  You should familiarize yourself with and understand those additional terms and conditions, as third parties are involved.

There are times when we must share information you have provided to us via our web site as part of third-party site links or API calls, with third-party partner sites to derive and present to you results that you have requested.  This information shared is limited to information you have shared with us as part of the registration, authentication and navigation processes on our site.

2. What Do We Do with the Information that We Gather about You?

We use each of the categories of personal information described above to operate, improve, understand and personalize our Services, and for the business and commercial purposes described below. The activities below may involve outside companies, agents or contractors (“service providers”) who may collect and to whom we disclose your personal information for these purposes.  For example, such service providers include third parties who assist us with marketing or promotional services related to how you interact with the Services and advertisements and communications on or through the Services, as well as assist us with administering the Services, including business development activities, account creation and Incentive Programs.  For more information on who we share your personal information with, please see Sections 2(C), 2(F) and 3 below.

2(A) We Provide the Services.

We use your information in order to assist you with using the Services, such as:

• making the Services available to you or otherwise meeting or fulfilling the purposes for which you provided the information to us;
• arranging access to your account;
• providing customer service;
• responding to your inquiries, requests, suggestions or complaints;
• completing your transactions;
• sending Services-related transactional messages (e.g., a change in our Terms of Service or other terms and conditions) and otherwise communicating with you about the Services;
• saving your search queries, in order to build “best of lists” and further personalize your experience, as further discussed in Section 2(B) below;
• letting you take part in promotions and research;  and
• creating and managing user profiles and content.

2(B) We Personalize Your Experience.

We may track your interests and habits while using the Services, such as the marketplace or categories that you look at or search for, in order to personalize and calibrate your experience using technology like algorithmic recommendations and machine learning, which may include third-party machine learning services or large language models.  The foregoing is how we highlight things that might be of interest to you, both directly to you and to third parties, such as advertisers and advertising agencies, as further described below and in Section 2(F). We may recommend offers for products or services that we believe might be of interest to you, based on demographic and usage data, including location data such as IP address and zip code, as well as utilize that data to formulate recommendations to other parties, again including third party advertisers or their agencies.

We collect your past search queries and browsing history in order to create a personalized picture of your interests.  Doing so enables us to tailor the results that you see based on your likely preferences and past behavior.  By collecting and analyzing your searches and browser history, we are better able to understand what you are looking for and in turn provide you with more relevant suggestions.  In addition, we are able to improve our websites and apps, namely by having the ability to better understand what we need to add in order to make our websites and apps more useful and relevant. 

We combine the data described above in this paragraph with other information that we, our service providers and other third parties collect about you.  More information regarding how we combine data can be found in the paragraph above the “During Contact with Our Call Centers (Internal and Offshore) section, in the “Identifiers and Device Information” and “Other Usage Data” sections above, at the end of Section 1(A) above, and in Section 2(F) below.

We also share the information described above with our service providers, who store the information for us.  More information about service providers can be found in Sections 2(F)-(G) below.

2(C) We Develop and Improve Our Products and Services, and Perform Analyses.

We analyze usage data, such as data regarding our users’ offer selections, account activity and other behaviors, when the Services are used. Such data enables us to make business and marketing decisions. Such data enables us to understand how users interact with the Services and to improve and develop the Services, including test new features, conduct research and analyses, add new content and product development.  For example, our analyses, which may include the use of technology such as machine learning and large language models, would enable us to predict preferences for our products and services.  The foregoing helps us determine whether our marketing is successful and shows us characteristics about our users, which we sometimes share in the aggregate with advertisers or advertising agencies. We may use our own analytics technologies, but we also utilize third-party data visualization products and analytics providers. Such products and providers enable us to find patterns in data, which enable us to deliver more compelling Services and further personalize your experience. Google Analytics is an example of a third-party analytics providers. You can find out how Google Analytics uses data at https://policies.google.com/technologies/partner-sites and how to opt out of Google Analytics at https://tools.google.com/dlpage/gaoptout.

2(D) We Carry Out Administrative or Legal Tasks.

We verify that our internal processes work as intended and comply with applicable legal and contractual requirements. We process the information that we collect in order to comply with legal, regulatory and contractual obligations and to respond to law enforcement requests.  More information regarding who we share information with can be found in Section 3 below.

We strive to detect and prevent cyberattacks or unauthorized robot activities, protect against or deter fraudulent, illegal or harmful actions, and maintain the safety, security and integrity of the Services.  We process information in connection with the foregoing.

2(E) We Provide Access to Offers.

As discussed above, you will have access to third-party offers.  More specifically, our websites and apps provide access to products and services offered on sites that are owned or operated by other parties. We provide such access through the use of hyperlinks provided by such third parties that, when clicked on, move you from our websites or apps to the applicable third-parties’ sites. Those offers will therefore be subject to additional terms and conditions on the use and disclose your personal information.  You should therefore also familiarize yourself with and understand those third-party terms and conditions.

2(F) We Provide Personalized Advertising on the Services and Develop Audiences for Advertisers. 

We collect data and work with service providers and third parties, including advertising agencies, in order to present you with and measure the performance of personalized advertisements on behalf of third-party advertisers. Such data comes from ad tracking technologies set by us or the applicable third-party (e.g., cookies), the information that you provide (e.g., your email address), your use of the Services (e.g., your browsing and account activity), information from third-party advertisers or advertising vendors (e.g., demographic data) and anything that can be inferred from any of the foregoing.  Note, that the consideration for our advertising-related fees is solely the reservation of advertising placements on, or in connection with, our Services.  

We use a third party to serve advertisements on our websites and apps. Said service provider uses information that we supply to them, cookies or unique device identifiers, in combination with their own data, to deliver ads based on information about you, such as your visit to our websites or apps.

Other service providers that we work with deliver emails and email newsletters to you, as well as push notifications.  You can modify your e-mail subscription preferences in the “Email” section of “Your Account”.  Please note that, due to email production schedules, you may however receive any emails that were already in production prior to any modification to your email subscription preferences, as well as important non-marketing notices.  For more information about the foregoing, please see Section 4(A)(i) of this Privacy Policy below. 

We also identify groups of users to whom to serve personalized ads on behalf of our advertisers. To do this, we combine the information that we collect through registration and other ways, namely through the use of services from an additional service provider, with the information that we collect automatically through the use of tracking technologies while you browse our websites and apps.  Said service provider serves as our customer data platform and combines unique tracked behavioral insights, machine learning and real-time campaign orchestration.  Such combined information may, in turn, be used to create models, which would then be used to measure users’ attributes, such as their demographic information or their interests. We would use such measurements to group users by common attributes as we work with service providers. Each group would be associated with a random ID, which would then be passed to our third party service providers described above for use in targeted advertising campaigns on our websites and apps.   Such combined information may also be passed along to said service providers to create unique one-to-one marketing campaigns and engagements based on each user’s interests and journey.

We may target third-party advertising to users through matching, as well.  In such situations, we would use information that directly identifies you, including your name, email address or phone number, in order to engage in targeted advertising, including by converting email addresses and phone numbers into identifiers that could be used for advertising purposes, namely serving or displaying ads or distributing emails. We may therefore share information that we collect from or about you, such as your email, IP address or information about your browser or operating system, with third parties that we may work with regarding the foregoing, such as our third-party advertisers and service providers.

In addition, we may collect information, such as your name, email address, IP address, phone number and/or browser or operating system information, from third parties in order to engage in personalized marketing towards you on the Services and/or to create audiences for third-party advertisers.  Such third parties may include merchants who offer their products or services on our websites and apps and even the organization that you are affiliated with.

For more information about your choices with respect to the processing described above, please see the “What Are Your Right and Choices?” section below.  As you will see, there are a variety of ways for you to control the personal information that we hold regarding you.  One such way has already been discussed above in this section, where we discuss how you can modify your e-mail subscription preferences in the “Email” section of “Your Account”. 

For more information regarding targeted advertising, and how to opt out with your specific browser and device, please go to the DAA Webchoices Browser Check and NAI Opt Out of Interest-Based Advertising. You can download the AppChoices app to opt out in mobile apps. You can follow the instructions in the “What Are Your Rights and Choices?“ section below too.

We do attempt to limit how any third-party advertising technology vendors that we do business with, such as those described above, use the information that they gather from or receive about you.  We enter into contracts with such providers, note which allow them to optimize their own services and products. These providers may combine any information that they gather about you through the Services with information that they may receive from their other clients. The foregoing would enable them to target ads to you on behalf of their other clients, as well.    

For further information on tracking technologies and your rights and choices regarding them, please see our Cookie Policy. As described in further detail below, California residents have the right to instruct us not to “sell” or “share” their personal information, as such terms are defined under applicable California law.  In addition, residents of other states, such as Colorado, Connecticut, Oregon, Texas, Utah and Virginia, have the right to opt out of “targeted advertising” and "sales" as defined under applicable law too. For more information concerning the above, please see the “What Are Your Rights and Choices?” section below, as well as Sections 4(A)(v) and 4(B) below.

2(G) We Market or Advertise the Services to You.

We market the Services to you. We may serve advertisements through sites, locations, platforms and services, as discussed above, that are owned and operated by third parties. Such advertisements may be targeted at individuals who are registered users of the Services, but who have not purchased anything through the Services. Such advertisements may also be targeted at people with similar traits or behaviors to our users. We use the information described in Section 1 above, including inferences, to build audiences that may be used for purposes of these marketing initiatives. We may also make predictions using machine learning, as described above, based on a combination of different types of information to support such initiatives.

We may target our advertising of the Services to users via the use of social media, creating content and using message matching, as well.  Such targeting or retargeting may include providing user information, such as email addresses, to a third-party, or the incorporation of tracking technology from a third-party into our Services. The third-party would, in turn, be able to match the individuals who appear in both our data and their data.  Our goal with respect to the foregoing is to engage with users and build relationships, to ensure that the benefits that are available through the Services do not pass such users by.  We will take steps designed to opt you out of such matched ads if you are a resident of certain states where you have the right to opt out of such processing, as discussed in further detail below. In order to opt out of receiving these matched ads, you should also, however, contact the applicable third-party.  Such third parties may include Facebook, Instagram or LinkedIn.  Note, that we are not responsible for any third-party’s failure to comply with opt-out requests. 

We will also of course send you targeted email newsletters and promotional emails, as well as  text messages and mail pieces, to ensure that opportunities available through the Services continue or are not missed. For information on opting out of these emails, text messages and mail pieces, please see the “What Are Your Rights and Choices?“ section below too.

2(H) We Aggregate or De-identify Personal Information into Findings.

We may sometimes aggregate or de-identify information such that same can no longer identify you, subject to applicable law. Said practice enables us to better understand and represent our users, such as when we measure advertising campaign performance or curate audiences for advertising or marketing. We may use and disclose aggregated or de-identified information for any purpose, including the generation of reporting, except if an applicable law provides otherwise.  More information about the foregoing can be found in Sections 3(A), 4(A)(vi) and 5 below.

3. To Whom Do We Disclose or Share the Information that We Gather for Business Purposes?

3(A) With Service Providers:

We engage various service providers, as described above and below, to support our business operations.  The foregoing includes tasks relating to the following business purposes:

• account creation;
• processing transactions;

• serving and targeting advertisements and measuring the performance thereof;
• distributing emails, mail pieces and other content;
• maintaining technology; and
• attempting to detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity.

When performing the foregoing tasks, our service providers have access to your personal information.  Our service providers have access to your personal information to perform other tasks related to our business operations, as well, including those described below and elsewhere in this Policy. 

We may also allow our service providers to use aggregated or de-identified information for other purposes, subject to applicable law. Information about service providers can, again, be found in Section 2 above.  In addition, more information about the foregoing may be found in Section 2(H) above and in Sections 4(A)(vi) and 5 below. 

As noted earlier in this Policy, we use additional service providers for a variety of tasks relating to our business operations, such as customer relationship management, including account registration, customer service and sales.  In connection therewith, we may share a variety of the information that we collect both on- and off-line, such as contact information, including names, email addresses and business affiliations, with said service providers, who store such information.  For example, if you request a demo, your name and contact information is collected via one of those service providers.  We, in turn, use that service provider for purposes of sales engagement and customer relationship management and even for administrative tasks such as generating links that are sent through email to complete passwordless authentication.  We use said service provider’s live chat feature too.  In connection therewith, you may, as further discussed above in the “During Contact with Our Live Chat or Chabot Features” section, be prompted to share information, which information would be stored by said service provider and in turn provided to us for further action, such as responding to a question about us or the Services. 

We similarly use a third-party live chat service for customer service-related purposes, during which  you may, again as previously discussed in the “During Contact with Our Live Chat or Chabot Features” section above, be prompted to share information.  Such information would similarly be stored by that service provider and, then, provided to us for further action, such as answering a question about us or the Services.

We use third-party service providers to process purchases of goods and services using the Site too, as also noted above in this Policy.  Said third-party service providers collect and store personal information, such as your name, email, phone number, address information, billing information and payment method details, and other data that may be relevant to your transaction.  Accordingly, you should familiarize yourself with and understand the terms and conditions applicable to said service providers.  Transaction processing in connection with the Site is discussed in further detail above, in the fourth full paragraph of this Policy and in the “For Transactions” section and Section 1(C)(v) of this Policy.  Transaction processing is also further discussed below, including at Sections 3(B) and 10 of this Policy.

It should be noted, as well, that the use of a third-party payment services provider is an option available with one of our Incentive Programs, as further described in the terms thereof.  In connection therewith, you may link your account with such payment services provider for purposes of payouts as an option to receiving a physical check.  Said service provider collects and stores personal information, such as your name, email, phone number, address information, billing information and payment method details, and other data that may be relevant or that you may provide them.  You should therefore familiarize yourself with and understand the terms and conditions applicable to the use thereof.  All of the foregoing is discussed in greater detail above, in the fourth full paragraph of this Policy, the “For Transactions” section, the last paragraph of the “For Offers and Sweepstakes;  Notice of Financial Incentives” section and Section 1(C)(v).

Furthermore, we do utilize other service providers, to manage and analyze our information database.  The foregoing assists us with operating, improving, understanding and personalizing our Services, and is for the business and commercial purposes described above in Section 2 of this Privacy Policy.

3(B) With Other Third Parties:

There are scenarios in which we may need to disclose your information to third parties besides our service providers. For example, and as discussed in Sections 2(F) and 2(G) above, we may share your email address and other personal information with third parties for purposes of marketing the Services across third-party sites and services and supporting matching for third-party advertising on the Services.  Such email addresses may or may not be hashed when they are shared with such third parties. To the extent that regulators take the position that the disclosure of information for matched advertisements is a “sale” under applicable law, we will take steps that are designed to opt you out of such matched advertisements if you are a resident of an applicable jurisdiction and you exercise your right not to have your personal information “sold” as defined under applicable law.  As noted in Section 2(G) above, you may also have to contact certain third parties, such as Facebook, Instagram or LinkedIn, to opt out of such matched advertisements.  Furthermore, while we do attempt to control the behavior of those of our business partners that we believe are service providers, some of those partners may engage in activities that are beyond our control and which may be deemed by regulators to be activities of “third parties,” rather than service providers.

The following are circumstances where we may be disclosing personal information to third parties that might not be service providers:

• we provide information to websites, platforms and services owned and operated by third parties in connection with marketing, as described in Section 1(C)(iv) below and Section 2(G) above;
• we may provide information about the users of offers to the applicable merchants, such as in connection with the interactions of such users with Customer Care;
• we may assist with processing transactions that you make through the Services with external services by collecting your information and providing it to the applicable business partners whose products or services are being purchased or to our third-party service providers for processing or the business partners or third-party service providers may collect your information for such processing, as further discussed in the fourth full paragraph of this Policy, the “For Transactions” section, the last paragraph of the “For Offers and Sweepstakes; Notice of Financial Incentives” section and Section 1(C)(v) of this Policy;
• in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or equity, including in connection with any bankruptcy or similar proceedings, we would have a legitimate interest in disclosing or transferring your information to a third-party, such as an acquiring entity and its advisers;
• we can preserve or disclose personal information to the extent that applicable law requires us to do so;
• we can preserve or disclose personal information if we believe that doing so would be necessary for any of the following: complying with the law or with legal process, protecting and defending our rights and property, protecting against any misuse or unauthorized use of the Services, protecting the safety or property of our personnel, users or the general public (for example, if you provide false information or attempt to pose as someone else, we may share your information in order to assist with investigations into your actions), or cooperating with government authorities, which may be outside of the jurisdiction where you reside;

• if, as discussed above in Section 1(C)(iii), your employer or the organization to which you belong has obtained a company- or organization-wide subscription to the Services and you have not registered to use the Services, we may share the fact that you have not yet registered with that third-party employer or organization;  and

• as described above in Section 2(H), we may disclose aggregated or de-identified information for any purpose, unless doing so is prohibited by applicable law.

We provide a variety of ways for you to control the personal information that we hold regarding you, including choices about how we use that information. In some jurisdictions, such controls and choices are enforceable as rights under the applicable law there. The choices described below are limited to the specific email address, mailing address, phone or device used and will not affect different email addresses, mailing addresses, phones or devices used, or subsequent registrations or information sharing.

4(A) In General:

• Email:  We offer a variety of emails and email newsletters. You can unsubscribe from such emails and email newsletters at any time by following the instructions near the bottom of the email or emailing us at DPO@benefithub.com.  In addition, and as discussed above in the third paragraph of Section 2(F), you can manage your preferences in the “Email” section of “Your Account”.

• Mail or Telephone Promotions:  You can ask us to unsubscribe from our mail or telephone solicitations, such as regarding the renewal of an insurance policy. In some jurisdictions, as discussed elsewhere in this Policy, you can also ask us to not share your information with third parties for marketing purposes. To do so, please call our Customer Care Team at 813-675-2210 or, with respect to insurance, please call us at 813-675-2220. You may also email us at any time at DPO@benefithub.com with “Opt Out” in the subject line, and “remove me from mailing list” or “do not call” and your mailing address or your phone number, as applicable, in the body of the email.

• Push Notifications:  You can opt out of push notifications at any time by adjusting your device settings, adjusting settings within or uninstalling our app, or blocking (removing) our web browser extension.
• Text Messages:  You can opt out of text alerts at any time by replying “STOP” or any alternative keyword that we’ve shared with you.  You may also email us at any time at DPO@benefithub.com with “Opt Out” in the subject line and your mobile phone number in the body of the email.  You can also opt-out of receiving such text messages by calling our Customer Care Team at 813-675-2210 or, with respect to insurance, please call us at 813-675-2220.
• Browser Extensions:  To remove browser extensions, you would generally need to open your browser's settings, navigate to the extensions section and, then, select the extension that you want to remove and click "Remove" or "Uninstall".  Each browser has its own specific instructions on how to remove browser extensions, which you would need to adhere to.

Please note that we complete any opt-out request as quickly as we can. Such opt-out request will not, however, prohibit us from sending you important non-marketing notices.  For additional information about the foregoing, please also see the third paragraph of Section 2(F) of this Policy above.

In some jurisdictions, namely those identified below, you may exercise the following choices:

• access, modify or delete the personal information that we have about you;
• be informed of, or receive an electronic copy of, the personal information that we have about you, for data portability;  and
• restrict, or object to, how we process personal information about you.

In the European Union (“EU”) and UK, for example, you have the right to object to, or obtain a restriction of, the processing of your personal information under certain circumstances; and, where the processing is based on your consent, you have a right to withdraw that consent at any time for future processing.  You have similar rights in Canada.

Note, that the foregoing information is not intended to be a complete or exact recitation of applicable law in the jurisdictions above;  nor is the foregoing intended to be a complete recitation of all jurisdictions where you may in fact have the choices or rights described above.  For some additional relevant information, please refer to the websites listed in second paragraph of the “Other Rights and Choices” section below.  

If you wish to exercise any of the above choices, please contact us at DPO@benefithub.com. In your request, please be as specific as possible.  Please state the information that you want changed, whether you want your information suppressed from our database or whether there are limitations that want us to put on how we use your personal information.  Please use the email address linked to the subject personal information, as we only complete requests on the information linked to your email address.  In order to verify your identity, we will email the email address that you provide us and wait for your response and, in some instances, we may also ask for additional information. The foregoing is how we verify your identity before complying. Note, that if you use the Services without creating an account or signing in, there may be no reasonable means by which we can verify your identity or the personal information related to you.

In some jurisdictions, you may designate an authorized agent to make a request on your behalf. In order to do so, please provide the agent with written permission, signed by you, authorizing the agent to submit the request on your behalf. The agent must submit that written permission along with the request. We may contact you to verify your identity and the authorized agent’s permission before a response to the request is sent.

We will respond to your request, or the request of your authorized agent, in a manner that is consistent with applicable law, including any exceptions that may result in a request being denied in whole or in part.  We may need to retain certain information for recordkeeping purposes, or to complete a transaction that you may have commenced prior to your or your agent’s request for a change or deletion.  For example, in the event of a transaction or other action that you may have requested, you might not be able to change or delete the personal information provided until after the completion thereof.  In some cases, your request may not ensure the complete removal of the subject information.  For additional information about the foregoing, please see Sections 4(A)(vi) and 5 of this Policy below.

In addition, where your employer or the organization to which you belong has a company- or organization-wide subscription to the Services, you may contact your employer or such organization for assistance with accessing, modifying or deleting the personal information that we have about you.  The same goes for any alumni program offered to your former employer or an organization that you were previously affiliated with, that you may belong to.  For more information about the foregoing, please see Section 1(C)(iii) above.  Note, that BenefitHub is not responsible for the failure of your employer, organization or alumni group to comply with said requests.

You can update your account information.  If you need assistance with updating your account information, please call our Customer Care Team at 813-675-2210, or with respect to insurance, please call us at 813-675-2220.  Note, that managing your account information may work differently if you are using our apps.

• Cookie Controls:  Most web browsers are set to accept cookies by default. You can, if you prefer, go to your browser settings in order to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain aspects or features of our websites. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated. For more information, please refer to our Cookie Policy. 

• Do Not Track:  Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the websites that you visit indicating that you do not wish to be tracked. There is not a common understanding of how to interpret the DNT signal; therefore, our websites do not respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described above in this Policy.

• Mobile Advertising ID Controls:  Apple’s iOS and Google’s Android operating systems do provide options to limit tracking and/or reset the advertising IDs.
• Email Web Beacons:  Most email clients have settings which allow you to prevent the automatic downloading of images, including web beacons, which prevents the automatic connection to the web servers that host those images.

Residents of certain jurisdictions, including Colorado, Connecticut, Oregon, Texas, Utah and Virginia, have the right to opt out of targeted advertising and "sales or sharing," as defined under applicable law, of their personal information. If you are in one of said jurisdictions, in order to exercise your right to opt out of targeted advertising or "sales or sharing" of your personal information, please  submit a request to opt-out by emailing us at DPO@benefithub.com with the subject line “[Your State] Resident - Do Not Sell or Share.”  California residents can review relevant information relating to California privacy laws in Section 4(B) below. 

If you want to delete your user account or the information that we have about you, you can always do so by sending an email to us at DPO@benefithub.com. We will delete your user account, including any personal information that we have with respect to same, or your personal information, as applicable;  however, we may retain some data if we are legally required to do so or in an anonymized and aggregated format that does not personally identify you and cannot be connected to you.  In addition, we may retain some data in a redacted manner that removes personal information .  Also bear in mind that we may need to retain certain information about you for purposes of completing a transaction that you may have commenced prior to your request for deletion or to have an order history for you.  For further information on the foregoing, please see the “Access, Correct, Change/Update, Delete or Restrict Processing of Your Personal Information” section of this Policy above and Section 5 of this Policy below.

You will not receive discriminatory treatment by us for the exercise of your privacy rights.

If you experience difficulties accessing this Policy, please do not hesitate to contact us at DPO@benefithub.com.

You may also lodge a complaint about us with a data protection authority, such as if you reside in the or EU or Economic Area (“EEA”).  A list of EU data protection authorities is available at https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080, but we encourage you to contact us first with any questions or concerns that you may have if you reside in the EU or EEA.  Similarly, in the UK, you may choose to file a complaint with the Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/.  Furthermore, in Canada, you can choose to file a complaint with the Office of the Privacy Commissioner of Canada / Commissariat à la protection de la vie privée du Canada at https://www.priv.gc.ca/en/report-a-concern/.  We do, however, similarly encourage you to contact us first with any questions or concerns that you may have about us if you reside in the UK or Canada.  Information on how to contact us can be found both above and below, including at Section 12 of this Privacy Policy.   

In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain of the choices described above. In order to appeal such a refusal, please contact us at DPO@benefithub.com using the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide us with all relevant information in the email.

4(B) California Privacy Notices and Rights

If you are a California resident, you have certain rights with respect to your personal information. 

At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected – see Section 1 above, the purposes for which such information is collected or used – see Section 2 above, whether such information is "sold or shared" – see Sections 3(A)-(B)  above and “iii” below - as defined under California law, and how long such information is retained – see Section 5 below.  For the Notice of Financial Incentives, please see Section 1(A)(i) above.

You have a right to request that we disclose to you the personal information that we have collected about you. You also have a right to request additional information about our collection, use, disclosure or sale of such personal information. Note, that we have provided much of said information in this Privacy Policy. You also have rights to request that we correct inaccurate personal information and that we delete personal information under certain circumstances, subject to a number of exceptions. Under the CCPA (defined below), the foregoing rights are subject to certain exceptions.  For example, we may need to retain your personal information to provide you with the Services or to complete a transaction or other action that you have requested. If your request is subject to one of these exceptions, we may deny your request.  Please see the “Access, Correct, Change/Update, Delete, or Restrict Processing of Your Personal Information “ section above for additional details, including about how to exercise these rights and how we verify your identity.  In addition, please see Section 4(A)(vi) above and Section 5 above.

To the extent that BenefitHub “sells” your personal information, as the term “sell” is defined under the CCPA (defined below), you have the right to opt-out of that “sale” on a going-forward basis at any time.  Please see the information that follows below on how to do so. 

If you are a California resident, you have a right to opt-out from the “sale” or “sharing” of your personal information with third parties who are not our service providers, as defined under the California Consumer Privacy Act and the California Privacy Rights Act (collectively referred to in this Policy as  “CCPA”). To exercise the foregoing right, you may submit a request to opt-out by emailing us at DPO@benefithub.com with the subject line “California Resident - Do Not Sell or Share.” Also, you may need to clear your cookies, or local storage in apps, on your browser or device.

We do not knowingly “sell” or “share”, as those terms are defined by the CCPA, the personal information of “children”. 

Furthermore, and notwithstanding anything to the contrary that may be set forth in the first sentence of this Section 4(B)(iii), we do not “sell” personal information, as the term “sell” is defined under the CCPA.   

If you are a California resident, you have a right to limit our use of sensitive personal information for any purposes other than to provide the Services or any goods that you request or as otherwise permitted by applicable law. To opt-out from such additional purposes, please contact us by emailing us at DPO@benefithub.com, calling our Customer Care Team at 813-675-2210 or with respect to insurance, calling us at 813-675-2220.

You can designate an authorized agent to make a request to exercise your rights under the CCPA on your behalf. In order to do so, please provide the agent with written permission, signed by you, authorizing the agent to submit the request on your behalf. The agent must submit that written permission to us as aforesaid, along with the request. We may contact you to verify your identity, as well as the authorized agent’s permission, before a response to the request may be sent.

You may exercise any of your rights listed in this section without fear of unlawful discrimination.

We keep a record of requests that we receive from California residents.  For data deletion and data access requests, you may submit such requests by emailing us at DPO@benefithub.com and indicating that you reside in California. We will begin to fulfill your request within forty-five (45) days thereof.  If we require more time, we will inform you of the reason and the extension period in writing.

Under the California “Shine the Light” law, California residents can opt out of our sharing of their information to third parties, and sometimes affiliates, for their direct marketing purposes. We do not generally disclose your personal information as defined in the Shine the Light law. To the extent that we share your email address with a third-party in connection with online marketing in a way that might be covered by the Shine the Light law, you may opt out of such sharing by submitting a written request to us at DPO@benefithub.com.

5. How Long Do We Retain Data?

We store your personal information for as long as needed, or permitted, based on the reason that we obtained it, consistent with applicable law. The foregoing means that we may retain your personal information even after you close your account with us or after you have requested the deletion of your personal information.

When deciding on how long to retain your information, we may consider the following:

• how long we have had a relationship with you or provided the Services to you;
• whether we are subject to any legal obligations, such as  any contracts or laws that require us to keep transaction records for a certain period of time before we can delete them;  and
• whether we have taken or may need to take any legal positions, such as in connection with any statute of limitations.

Rather than delete your data, we might de-identify it by removing identifying details.  For additional information about data deletion, please see Sections 4(A)(ii) and 4(A)(vi) above.  Please also see the third to last and fourth to last bullet points of the last paragraph of Section 3(B), where we discuss situations in which we may be required by law to preserve personal information.

6. How Do You Protect My Information?

We protect your personal information with appropriate organizational, technological and physical safeguards.  However, we cannot guarantee the absolute security of your personal information. We therefore recommend that you:

• use complex and unique passwords for your account and for any third-party account that may be linked to it;
• do not share your password with anyone;
• be mindful of the information that you share both on- and off-line;
• stay vigilant against attempts intended to trick you into revealing sensitive information such as your account password or credit card details, or installing malware on your devices; and
• regularly update your devices and software.

If you have reason to believe your interaction with us is no longer secure, please notify us immediately at DPO@benefithub.com.

7. Are There Guidelines for Children?

The Services are unavailable to individuals who are under the age of eighteen (18) or not of the majority age in the jurisdiction where they reside.  We therefore neither gather personal information as defined by the U.S. Children’s Privacy Protection Act (COPPA), nor in a manner not permitted by COPPA.

Please contact us at DPO@benefithub.com if you have any questions about the foregoing. We collect data as permitted by applicable laws.  In addition, we remove data to the extent required by applicable laws or when requested to do so under Section 4 above, and subject to the provisions of Section 5 above.

8. Is Information Transferred Internationally?

BenefitHub is headquartered in the United States. If you are located in Europe, information that we collect directly from you, as well as information that is provided to us from other sources, such as your employer or the organization to which you belong or one of our merchants of service providers, is housed in a datacenter located in the UK that is operated by one of our third party service providers.  Such information that is provided to us may, in turn, be accessed and utilized via third-party service providers, such as those described above in Sections 2(F) and 3(A) of this Policy.  Your information is not, however, transferred by BenefitHub outside of such jurisdiction.  For more information about information collected from other sources, please see Section 1(C) above.  In addition, for more information about service providers, please see Sections 2 and 3(A) above.

9. What Is Our Legal Basis?

In some jurisdictions, namely the EU or EEA, the UK and Canada, information about you would only be collected, used or shared when there is a valid reason for doing so. The foregoing is called a “lawful basis” or “legal basis.”  Specifically, that is one of the following:

• the consent that you provide at the point of collection of your information;
• the performance of any contract with you;
• the compliance with an applicable legal obligation; or
• legitimate interests.

Note, that “Legitimate interest” is a technical term under international law, including the EU General Data Protection Regulation and the UK General Data Protection Regulation. The term means that there are good reasons for the processing of your personal information and that measures are taken to minimize the impact thereof on your privacy rights and interests.  Also, “Legitimate interest” refers to use of your data in ways that you would reasonably expect and that have a minimal privacy impact.

We have a legitimate interest in gathering and processing personal information, for example:

• to ensure that our networks and information are secure;
• to administer, and generally conduct business within, our Services;
• to prevent fraud; and
• to conduct our advertising and marketing activities.

Note too, that the information set forth in this section is not intended to be a complete or exact recitation of the applicable law in any of the jurisdictions above.  For some further information about the foregoing, kindly refer to the websites listed in second paragraph of the “Other Rights and Choices” section above.  

10. What about Third-Party Products and Services?

The Services, again, contain links to third-party websites, apps, resources, merchants and advertisers, as well as provide access to such third-party resources and merchants. Again, such third parties are not BenefitHub;  and, we do not control and are not responsible for any third-party content, products or services, or privacy practices. Such third parties may independently collect and solicit information from and about you and affect your data preferences when you access the Services. Any personal information that you provide to such third parties is not covered by this Privacy Policy. Such third parties have their own policies and practices about data, which may include what information they share with us, your rights and choices on their websites and with respect to their services, and whether they store information in the US or elsewhere. We encourage you to familiarize yourself with the privacy policies and terms of use of such third parties.  All of the foregoing is discussed in further detail above in the fourth full paragraph of this Policy, the “For Transactions” section, the last paragraph of the “For Offers and Sweepstakes;  Notice of Financial Incentives” section, Section 1(C)(v), the third to last and second to last paragraphs of Section 3(A), and Section 3(B) of this Policy.

11. How Are Changes to this Privacy Policy Communicated?

We are always striving to improve the Services, and we create new features on a regular basis. Such updates may require us to collect new information or to use information that we have already collected in a different manner. Furthermore, the laws concerning personal information and privacy often change. Accordingly, we may periodically revise this Privacy Policy.

We will post any changes on this page by updating this Policy.  You will be notified of such changes via our revising the date set on this Privacy Policy set forth above.  After we post any changes on this page, your continued use of the Services is subject to the updated Privacy Policy.  Your continued use of the Services also constitutes your agreement to be bound by any modified version of this Privacy Policy.  If you do not agree to be bound by a modified version of this Privacy Policy, your only remedy is to terminate you use of the Services.  Simply put, if you object to any changes to this Privacy Policy, you can stop using the Services.

12. How Can You Contact Us?

If you have any questions about this Privacy Policy, you can email us at DPO@benefithub.com or you can write to us at the addresses below.

169 Madison Ave, Suite 11773

New York, NY 10016

U.S.A.

Attn: Data Protection Officer

If you are outside the US or Canada, the address below applies.

2nd Floor Regis House

45 King William Street

London, EC4R 9AN

United Kingdom

Attn: Data Protection Officer

You can also reach us by phone at 813-675-2210 or, with respect to insurance, at 813-675-2200, if you have any questions.