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Privacy Notice

Healthy Paws Pet Insurance, LLC As of January 1, 2020


Healthy Paws Pet Insurance is the managing general underwriter for the Healthy Paws Pet Insurance program. Healthy Paws is committed to protecting your privacy. This commitment reflects the value we place on earning and keeping the trust of our customers, business partners, and others who share their personal information with us.


PURPOSE OF THIS NOTICE

Title V of the Gramm-Leach-Bliley Act (GLBA) and applicable state laws generally prohibit any financial institution, directly or through its affiliates, from sharing non-public personal information about you with a non-affiliated third party unless the institution provides you with a notice of its privacy policies and practices, including the type of information that it collects about you and the categories of persons or entities to whom it may be disclosed. In compliance with GLBA and state privacy laws, we are providing you with this notice, which informs you of the privacy policies and practices of Healthy Paws Pet Insurance, LLC.

GLBA further requires that we inform you of your right to restrict sharing of your non-public personal information with a non-affiliated third party for any purpose that is not specifically authorized by law. Your right to restrict sharing of non-public personal information with a non-affiliated third party for a purpose that is not specifically authorized by law is called your right to "opt-out" of such information sharing.

What does this Privacy Notice do?

This Privacy Notice ("Notice") explains Healthy Paws Pet Insurance's information processing practices. It applies to any personal information you provide to us and any personal information wecollect from other sources. This Notice is a statement of our practices and of your rights regarding your personal information. This is not a contractual document, and it does not create any rights or obligations on either party, beyond those which already exist under data protection laws.

This Notice does not apply to your use of a third-party site linked to this website.

If you have a disability and require an alternative format to this privacy notice, please email us corporate.compliance@healthypawspetinsurance.com so that we may provide you with a more suitable format.


Who is responsible for your information?

Throughout this Notice, "Healthy Paws" refers to Healthy Paws Pet Insurance LLC, including its affiliated companies and subsidiaries (also referred to as "we", "us", or "our"). Healthy Paws is responsible for your personal information (and the controller for the purposes of data protection laws) that we collect from or about you.

When and how do we collect your information?

We collect personal information in the following ways:

Category Description
From Our Partners When we perform services for our partners
Customer Service Requests When you request service from us
Quotes and Enrollment When you register with or use any of our websites or applications
Contact Us If you contact us with a complaint or query
Social Media When you engage with us over social media
Claims Services To process your claim submissions

For specific information on the source for each category of personal information collected, please see the section titled "Categories of personal information we may collected, disclose, and "sell" (as defined under applicable law below).


What information do we collect?


In general, we collect personal information about you that you provide to us, that we receive from third parties or that we indirectly collect or infer about your activities or usage of our websites, apps or services. The actual personal information we collect about you varies depending upon the nature of the services and our interactions for you.

Information you provide to us

When you request services, we ask that you provide accurate and necessary information that enables us to respond to your request. When you provide personal information to us, we use it for the purposes for which it was provided to us as stated at the point of collection or as obvious from the context of collection, for example providing an insurance quote, applying for a position with us or creating a profile on our website or application.

More information about the categories of personal information collected for each of our services, together with the purpose and legal basis for collecting the information is provided below.

We will not knowingly collect any sensitive personal information unless this is required. Sensitive personal information includes a number of types of data relating to: race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life.

If you provide us with sensitive personal information, you understand and give your explicit consent that we may collect, use and disclose this information to appropriate third parties for the purposes described in this Notice. If you provide personal information about other individuals such as employees or dependents, you must obtain their consent prior to your disclosure to us.

Information we collect over Healthy Paws websites, mobile applications and social media. We may ask you for personal information, such as name and contact information, when you register for events, request services, manage accounts, access various content and features or directly visit our websites. (For purposes of this Notice, "website" includes our mobile applications.)

In some instances, we automatically collect certain types of information when you visit our websites and through e-mails that we may exchange. Automated technologies may include the use of web server logs to collect IP addresses, "cookies" and web beacons. Further information about our use of cookies can be found in our Cookie Notice.

Social media. You can engage with us through social media websites or through features such as plug-ins or applications on our websites that integrate with social media sites. You may also choose to link your account with us to third party social media sites. When you link your account or engage with us on or through third party social media sites, plug-ins, or applications, you may allow us to have ongoing access to certain information from your social media account (e.g., name, e-mail address, photo, gender, birthday, the posts or the 'likes' you make).

Content you post. If you post information when you interact with our websites through social media sites, plug-ins or other applications, depending on your privacy settings, this information may become public on the Internet. You can control what information you share through privacy settings available on some social media sites. For more information about how you can customize your privacy settings and how third party social media sites handle your personal information, please refer to their privacy help guides, privacy notices and terms of use.

Mobile devices. If you access our websites on your mobile telephone or mobile device, we may also collect your unique device identifier and mobile device IP address, as well as information about your device's operating system, mobile carrier and your location information. We may also ask you to consent to providing your mobile phone number (for example, so that we can send you push notifications).

Categories of personal information we may collect, disclose, and "sell" (as defined underapplicable law).

The types and categories of personal information we collect about you depends on the nature of theservices we provide to you and our interactions with you. Additionally, we may disclose personalinformation to third parties and services providers for the purposes identified below.

In general, we do not disclose or share personal information to third parties in exchange for theirmonetary payment to us. However, certain laws including the California Consumer Privacy Act("CCPA") define "sale" broadly to include disclosing or making available personal information to thirdparties in exchange for monetary payment or some other thing of value. For purposes of the CCPA,we may disclose or make available personal information in order to receive some benefit or value(i.e., a "sale" under the CCPA).

The categories of information we may collect, disclose and "sell" are as follows:

Categories of personal information Specific types of of personal information Category of sources from which this personal information is obtained Is this personal information collected? Is this personal information disclosed for business people? Is this personal information sold?
Name, contact and identifiers Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers Referring Partners, Website enrollment, customer service center and claims management Yes Yes No
Customer Information and records Paper and electronic customer records containing personal information, such as name, signature, address, telephone number, email, or, insurance policy number, bank account number, credit card number, expiration and code, debit card number, or any other financial information. Lead Referring Partners, Customers via phone, mail, website, fax, Veterinarians Yes Yes No
Purchase history and tendencies Commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies Referring Partners, Customers via phone, mail, website, fax, Veterinarians Yes Yes No
Usage data Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an Internet website, application, or advertisement. Referring Partners, Customers via phone, mail, website, fax, Veterinarians Yes Yes No
Profiles and Inferences Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes Referring Partners, Customers via phone, mail, website, fax, Veterinarians Yes Yes No


How do we use your personal information?

The following is a summary of the purposes for which we use personal information. More information about the personal information collected for each of our services, together with the purpose and legal basis for collecting the information will be provided to you below.

Performing services for our customers

We process personal information which our customers provide to us in order to perform our services. The precise purposes for which your personal information is processed will be determined by the scope and specification of our customer engagement, and by applicable laws, regulatory guidance and professional standards.

The categories of information we use to perform our services include Name, Contact and Identifiers, Customer Information and Records, Purchase History and Tendencies, Usage Data and Profiles and Inferences

We process personal information which our customers provide to us in order to perform our services. The precise purposes for which your personal information is processed will be determined by the scope and specification of our customer engagement, and by applicable laws, regulatory guidance and professional standards.

Administering our customer engagements

The categories of information we use to administer our customer services include Name, Contact and Identifiers, Customer Information and Records, Purchase History and Tendencies, Usage Data and Profiles and Inferences.

Contacting and marketing our customers and prospective customers

We process personal information about our customers in order to:

The categories of information we use to contact and market to our customers and prospective customers include Name, Contact and Identifiers, Customer Information and Records, Purchase History and Tendencies, Usage Data and Profiles and Inferences.

Conducting data analytics

We are an innovative business, which relies on developing sophisticated products and services by drawing on our experience from prior engagements. We are not concerned with an analysis of identifiable individuals, and we take steps to ensure that your rights and the legitimacy of our activities are ensured through the use of aggregated or otherwise de-identified data. The categories of information we use to conduct data analytics include; Name, Contact and Identifiers, Customer Information and Records, Purchase History and Tendencies, Usage Data and Profiles and Inferences.

If we wish to use your personal information for a purpose which is not compatible with the purpose for which it was collected for, we will request your consent. In all cases, we balance our legal use of your personal information with your interests, rights, and freedoms in accordance with applicable laws and regulations to make sure that your personal information is not subject to unnecessary risk.

Legal basis

All processing (i.e. use) of your personal information is justified by a "lawful basis" for processing. In the majority of cases, processing will be justified on the basis that:

In limited circumstances, we will use your consent as the basis for processing your personal information, for example, where we are required to obtain your prior consent in order to send you marketing communications.

Before collecting and/or using any personal information, or criminal record data, we will establish a lawful basis which will allow us to use that information. This basis will typically be:

All processing (i.e. use) of your personal information is justified by a "lawful basis" for processing. In the majority of cases, processing will be justified on the basis that:

Do we collect information from children?

We do not directly provide services to children, and we do not knowingly collect personal information from children.

How long do we retain your personal information?

How long we retain your personal information depends on the purpose for which it was obtained and its nature. We will keep your personal information for no more than the time required to fulfil the purposes described in this privacy notice unless a longer retention period is permitted by law. We have implemented appropriate measures to ensure your personal information is securely destroyed in a timely and consistent manner when no longer required.

In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

Do we disclose your personal information?

Within Aon

We may share your personal information with other Aon entities, brands, divisions, and subsidiaries to serve you, including for the activities listed above.
We do not rent, sell or otherwise disclose personal information with unaffiliated third parties for their own marketing use. We do not share your personal information with third parties except in the following circumstances discussed below.

Business Partners

We disclose personal information to business partners who provide certain specialized services to us, or who co-operate with us on projects. These business partners operate as separate controllers and are responsible for their own compliance with data protection laws. You should refer to their privacy notices for more information about their practices.

Examples include:

Authorized Service Providers

We may disclose your information to service providers we have retained (as processors) to perform services on our behalf (either in relation to services performed for our customers, or information which we use for its own purposes, such as marketing). These service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements. These activities could include any of the processing activities that we carry out as described in the above section, 'How we use your personal information.'

Examples include:

These third parties appropriately safeguard your data, and their activities are limited to the purposes for which your data was provided.

The categories of information shared with our authorized service providers include Name, Contact and Identifiers, Customer Information and Records, Purchase History and Tendencies, Usage Data and Profiles and Inferences.

Legal Requirements and Business Transfers

We may disclose personal information (i) if we are required to do so by law, legal process, statute, rule, regulation, or professional standard, or to respond to a subpoena, search warrant, or other legal request. (ii) in response to law enforcement authority or other government official requests, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iv) in connection with an investigation of suspected or actual illegal activity or (v) in the event that we are subject to a merger or acquisition to the new owner of the business, or in the event of the dissolution of our business. Disclosure may also be required for company audits or to investigate a complaint or security threat.

Do we transfer your personal information across geographies?

We are a global organization and may transfer certain personal information across geographical borders to our, authorized service providers or business partners in other countries working on our behalf in accordance with applicable law. Our affiliates and third parties may be based locally, or they may be overseas some of which have not been determined by the European Commission to have an adequate level of data protection.

When we do, we use a variety of legal mechanisms to help ensure your rights and protections travel with your data:

Examples of countries we transfer personal information to include, but are not limited to, the United States of America, the United Kingdom, Ireland, Singapore, India and the Philippines.

If you would like further information about whether your information will be disclosed to overseas recipients, please contact us as noted below. You also have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments, which may be redacted for reasons of commercial confidentiality) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

Do we have security measures in place to protect your information?

The security of your personal information is important to us and we have implemented reasonable physical, technical and administrative security standards to protect personal information from loss, misuse, alteration or destruction. We protect your personal information against unauthorized access, use or disclosure, using security technologies and procedures, such as encryption and limited access. Only authorized individuals access your personal information, and they receive training about the importance of protecting personal information.
Our service providers and agents are contractually bound to maintain the confidentiality of personal information and may not use the information for any unauthorized purpose.

What choices do you have about your personal information? We offer certain choices about how we communicate with our customers and what personal information we obtain about them and share with others. When you provide us with personal details, if we intend to use those details for marketing purposes, we will provide you with the option of whether you wish to receive promotional email, SMS messages, telephone calls and postal mail from us.

You may also choose not to receive marketing communications from us by clicking on the unsubscribe link or other instructions in our marketing emails, visiting the My Account section on our website, or contacting us as noted below.


How can you update your communication preferences?

We take reasonable steps to provide you with communication about your information. You can update your communication preferences in the following ways.


Profile

If you have created a profile or account on one of our websites, you can update your contact information after you log into your account.


Newsletters

If you request electronic communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in the communication.


Mobile Devices

If you previously chose to receive push notifications on your mobile device from us but no longer wish to receive them, you can manage your preferences either through your device or the application settings. If you no longer wish to have any information collected by the mobile application, you may uninstall the application by using the uninstall process available on your mobile device.


Email

Contact us by e-mail or postal address as noted below. Please include your current contact information, the information you are interested in accessing and your requested changes. If we do not provide you with access, we will provide you with the reason for refusal and inform you of any exceptions relied upon.


Other rights regarding your data

Data protection laws vary among countries, with some providing more protection than others. Subject to certain exemptions, and in some cases, particularly if you reside in a jurisdiction with applicable privacy laws, dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information.


Right to Access

You have right to access personal information, and the categories thereof, which we hold about you. If you have created a profile, you can access that information by visiting your account or making a request online or by phone (as provided below).


Right to Rectification

You have a right to request us to correct your personal information where it is inaccurate or out of date.


Right to be Forgotten (Right to Erasure)

You have the right to request under certain circumstances to have your personal information erased. Your information can only be erased if your data is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the data


Right to Restrict Processing

You have the right to restrict the processing of your personal information, but only where:


Right to Data Portability

You have the right to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party.


Right to Object to Processing

You have the right to object the processing of your personal information at any time, but only where that processing is has our legitimate interests as its legal basis. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.


Do-Not-Sell

We do not sell your personal information without your prior consent.


International Transfers

As noted above, you can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.


If applicable, how do you exercise these rights?

You can exercise your rights by contacting us at corporate.compliance@healthypawspetinsurance.com or by calling +1-855-898-8991 (toll free). Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfill your request

To verify your identity, please be prepared to offer the following information: you name, zip code, date of birth, and any other information you have previously provided to Healthy Paws We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

You may also be able to designate an authorized agent to make a request regarding these rights on your behalf. If you would like to do so, please have your authorized agent use the contact email or number above and state within their request they are your authorized agent. If needed, Aon will inform the authorized agent of any additional verification data needed to process such request at that time.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Discrimination: If consumers exercise their rights under CCPA, businesses may not discriminate against them, such as by denying or providing a different level or quality of goods or services or charging or suggesting that a business will charge different prices or rates or impose penalties (unless doing so is reasonably related to the value received from the consumer personal information).

Disclosure of Incentives: If businesses offer any financial incentives for the collection, sale or deletion of their personal information, consumers have the rights to be notified of any financial incentives offers and their material terms, as well as the to not be opted into such offers without prior informed opt-in consent and to be able to opt-out of such offers at any time. Businesses may not offer unjust, unreasonable, coercive or usurious financial incentives.

For Minnesota Residents The disclosure of personal information among Healthy Paws Pet Insurance, LLC and affiliates is authorized under the Minnesota Insurance Fair Information Report Act, § 72A.502, subdivision 8, which allows for disclosure without written authorization where i) the personal information is used for a limited purpose and ii) the affiliate agrees not to disclose the information for any other purpose or to unaffiliated persons.

For Montana Residents The disclosure of personal information among HEALTHY PAWS PET INSURANCE, LLC and affiliates is authorized under Montana's Insurance Information and Privacy Protection Act, MCA 33-19-306 (12)(a) and (b), which allows for disclosure without written authorization where i) the personal information is used in connection with an audit or to enable HEALTHY PAWS PET INSURANCE, LLC to perform an insurance function and ii) an appropriate agreement is executed with the affiliate to limit the affiliate's use and disclosure of the personal information.

For North Dakota Residents NDCC 26.1-02-27 permits HEALTHY PAWS PET INSURANCE, LLC to disclose personal information pursuant to NDCC 45-14-01-11, which sets forth North Dakota's rules promulgated in accordance with NAIC's Privacy of Consumer Financial and Health Information and allows for disclosure where appropriate opt-out notice and opportunity has been given.

For Vermont Residents HEALTHY PAWS PET INSURANCE, LLC is authorized to disclose personal information under Vermont's Privacy of Consumer Financial and Health Information Regulation Article IV, Sections 14(A), (B) and (C), which provide an exception to the general "opt-in" rule (which requires consumers to affirmatively agree to disclosure) where HEALTHY PAWS PET INSURANCE, LLC executes an appropriate agreement with the third party that limits the third party's use and disclosure of the personal information. HEALTHY PAWS PET INSURANCE, LLC is further authorized to disclose personal information under Sections 15(A) and (B) which provide an exception to the "opt-in" requirement where the disclosure of personal information is necessary to affect, administer or enforce a transaction that the customer authorizes. Our release of personal information is also authorized where permitted by law under Section 16(A).

Contact Us

If you have any questions, would like further information about our privacy and information handling practices, would like to discuss opt-outs or withdrawing consent, or would like to make a complaint about a breach of the law or this Privacy Notice, please contact the Compliance Director corporate.compliance@healthypawspetinsurance.com or call +1.855-898-8991 (toll free). Alternatively, you have the right to contact your local Data Protection Authority.


Healthy Paws Pet Insurance LLC
P.O. Box 50034
Bellevue, WA 98015
corporate.compliance@healthypawspetinsurance.com

Phone: (855) 898-8991


Changes to this Notice

We may update this Notice from time to time. When we do, we will post the current version on this site, and we will revise the version date located at the bottom of this page.

We encourage you to periodically review this Notice so that you will be aware of our privacy practices.

This Notice was last updated on December 17, 2019.