Privacy Policy

Your privacy is important to us. This privacy policy (the "Privacy Policy") describes how Assured Inc. and its affiliates (collectively, "us," "we," "Assured," and "Assured Allies") collect, use, and disclose personal data you submit through our programs (e.g., AgeAssured and NeverStop) collect, use, and disclose personal data you submit through our programs (e.g., AgeAssured and NeverStop) and other offerings, sites, applications, or services made available or otherwise utilized by Assured (collectively, the "Offerings").

This Privacy Policy operates in conjunction with Assured’s Terms of Service and the NeverStop Wellness Program Terms, if applicable, which are incorporated herein by reference, and govern your use of the Offerings.

Personal information is data that can be used, whether on its own or in combination with other data, to identify or contact a single person.

You may be asked to provide your personal information when you are in contact with Assured, and Assured and its affiliates may share this personal information with each other and use it in a manner that is consistent with this Privacy Policy. We may also combine your information with other information to provide and improve our products, services, and content. You are not required to provide personal information, but if you choose not to, we might be unable to provide you with our products or services or respond to queries you may have.

To better protect your privacy, we provide this notice explaining our privacy practices. If you do not agree to be bound by the terms in this Privacy Policy, you should cease submitting any personal data, and, if necessary, cease use of our Offerings.

We reserve the right to make changes to this Privacy Policy from time to time, and those changes will be posted on this web page. The amended Privacy Policy will be effective immediately upon posting, and your continued use of our Offerings will confirm your acceptance of the changes. If you do not agree to the amended Terms, you must stop accessing and using the Services. If any of these Terms shall be deemed invalid, void, or for any reason unenforceable, that Term shall be deemed severable and shall not affect the validity and enforceability of any remaining Term.

Here are some examples of the types of personal information Assured may collect and how we may use it:

Personal information we collect and how we collect it

• When you participate in our Offerings we may collect a variety of information, including without limitation your name, mailing address, phone number, email address, contact preferences, device identifiers, IP address, and location information.
• When you share your content with family and friends or invite others to participate in Assured’s services or forums, Assured may collect the information you provide about those people such as their names, mailing addresses, email addresses, and phone numbers. Assured will use such information to fulfill your requests, provide the relevant Offering, or for anti-fraud purposes.
• As explained below, when you utilize any of our Offerings, whether or not you are logged in or registered, we collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, application program interfaces, and web beacons.

How we use your personal information

We may process and disclose your personal information:

• for the purposes described in this Privacy Policy
• for any purpose that you approved
• for compliance with a legal obligation to which Assured is subject
• for the performance of a contract to which you are party
• when we have assessed it is necessary for the purposes of the legitimate interests pursued by Assured or any third party, including but not limited to your insurer, to whom it may be necessary and/or appropriate to disclose information.

If you have questions about any legal basis noted in this Privacy Policy, you can contact us at [email protected].

In addition:

• We use personal information for internal purposes, which include helping us create, develop, operate, deliver, and improve our Offerings and content, to provide you with personalized content and experiences, to send you offers and promotions related to our Offerings, or to send you information for loss prevention and anti-fraud purposes. We limit our use of data for anti-fraud purposes to those that are necessary and within our assessed legitimate interests to protect our customers and our Offerings.
• We may use personal information for internal testing purposes, including system integrity, quality assurance, and a/b testing.
• From time to time, we may use your personal information to send important notices, such as communications about changes to our terms, conditions, and policies. Because this information is important for your interaction with Assured, you may not opt out of receiving these communications.
• The personal information we collect allows us to keep you posted on Assured’s latest product announcements, services, and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by emailing us at [email protected].
• For research and development purposes, we may use datasets. When acquiring such datasets, we do so in accordance with applicable law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to identify individuals who may appear therein.
• If you enter into a sweepstakes, contest, or similar promotion, we may use the information you provide to administer those sweepstakes and contests.
• If you apply for a position at Assured or we receive your information in connection with a potential role at Assured, we may use your information to evaluate your candidacy and contact you.

Sourcing your personal information when they are not collected from you

We will either receive your personal information directly from you or from your long-term care insurance carrier. We may also acquire data from third-party vendors. When we do so, we comply with all applicable laws and regulations. We primarily use such information for research and development purposes; however, Assured is permitted to share personal information and related data with your long-term care insurance carrier.

Collection and Use of Non-Personal Information

We also collect and process data in an anonymized and aggregated form that does not, on its own, identify or associate with any specific individual. We may collect, use, transfer, and disclose non-personal, aggregated, and anonymized information for any purpose at our sole discretion.

Disclosure to Third Parties/Service Providers

While the majority of our usage of personal data is internal, from time to time Assured may provide third parties, including your insurance carrier, with certain personal information to deliver our Offerings, to provide or improve upon our products and services, to carry out one or more of our programs, or to help Assured market to consumers. When we do so, we require those third parties to process such personal data in accordance with applicable laws and regulations.

Without limiting the generality of the foregoing, Assured also shares personal information with companies that provide services such as information processing, fulfilling customer orders, delivering products or information to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your personal information at all times.

Without limiting the generality of the foregoing, Assured reserves the right to share data with insurance carriers and third-party administrators with which Assured has entered into contractual relationships.

It may also be necessary—by law, legal process, litigation, and/or requests from public and governmental authorities—for Assured to disclose your personal information. We may also disclose information about you if we determine that for purposes of your safety, the safety of others, national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale, we may transfer any and all personal information we collect to the relevant purchaser/surviving entity.

Mobile Communications

By providing us with your mobile phone number, or by sending an SMS (containing a pre-designated number or word) to a phone number that we indicate, you are expressly opting in to receive telephone calls to your mobile phone or text messages from us, some of which may be considered marketing and may be delivered by us using auto dialer systems/technologies. You represent that you are the owner or authorized user of the mobile phone number you supplied to us and that you are authorized to approve the applicable charges and rates resulting from such SMS and/or MMS messages incurred by such device. Message and data rates may apply. You (and not Assured) will be responsible for all messaging and data charges that may apply. Your consent to receive text messages is not a condition of purchase. Message frequency may vary.

Data obtained from you in connection with our mobile marketing programs may include your cell phone number, your carrier’s name, and the date/time/content of any text messages that you send us. We reserve the right to use this data in the same manner and for the same purpose(s) as other data that we may collect pursuant to this Privacy Policy, including, without limitation, to provide the services you request of us, and to otherwise operate, develop, and improve our products and services.

You can opt out of receiving marketing-related text messages from us at any time by texting “STOP” (or some other SMS message designated by us) from the mobile device receiving the messages. If you choose to opt out, you will be unsubscribed from our marketing text messaging program. You will receive one SMS that confirms you have successfully opted out. After that you will receive no further messages for this system unless/until you opt in again.

Please know that even if you opt out of receiving marketing-oriented text messages from us, we may still contact you via text message or phone call for transactional or informational purposes regarding your enrollment in and/or use of our Offerings. Some examples are contacts for customer service, product information, service, or reminder notices.

Communications; Privacy Questions

You acknowledge and agree that Assured may communicate with you regarding your use of any of our Offerings by regular mail, electronic communications (email/SMS), telephone, and any other means of communication described in our policyholder materials. The communications we send you may include information regarding your participation as well as advertisements and promotions. In addition to our unsubscribing instructions above regarding SMS messages, you may also opt out of receiving marketing communications (via email or otherwise) by clicking on the unsubscribe link located in the footer of each email message or by writing to us at [email protected]. Even after you’ve opted out, you will continue to receive certain email communications that are not of an advertising or promotional nature.

If you have any questions or concerns about Assured’s Privacy Policy or data processing and you would like to contact us, please contact us either by sending an email to [email protected] or by letter to Assured Inc. 160 Gould St., Suite 207, Needham, MA 02494, Attention: Privacy Officer.

Children

Assured does not knowingly collect Personal Data from children under the age of 18. If you are under the age of 18, please do not submit any Personal Data through the Services.

Protection of Personal Information

The security, integrity, and confidentiality of your information are important to us, and we take appropriate precautions to protect your personal data by implementing technical, administrative, and physical security measures that are designed to protect it from unauthorized access, disclosure, use, and modification, and to comply with applicable laws and regulations. Although we have invested in leading-edge security software, systems, and procedures, no security system is impenetrable. Accordingly, we will continually monitor the effectiveness of our security system and refine and upgrade our security technology as new tools become available. If you have any questions about the security measures we employ, please contact us by sending an email to [email protected].

Retention of Personal Information

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and/or as required by applicable law.

Health Information

It is very likely that if you enroll in any of our programs and/or utilize any of our Offerings, Assured will come into contact with and will process Health Information about you ("Health Information"). This information may be regulated under applicable state law and/or the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"). Set forth below is a summary of our assumed duties and privacy practices regarding your Health Information, namely, your rights with respect to your Health Information, and how we may use and disclose such information about you.

• Healthcare Operations. We may use Health Information for our customer service activities, quality improvement, performance evaluation, product development, and other internal business management purposes.
• De-Identified Data. We may use an individual’s Health Information to create de-identified data, which is stripped of identifiable data and can no longer identify a particular individual, even when such data is combined with other data sets.
• Subcontractors. We may contract with third parties to perform certain services for us, such as billing services or consulting services. These third-party service providers, referred to as subcontractors, may need to access your Health Information to perform services for us, and in such cases, we will undertake commercially reasonable efforts to ensure they are required by contract and law to protect your information and only use and disclose it as necessary to perform the contracted services for us.
• To Communicate with Individuals Involved in Your Care or Payment for Your Care. We may disclose your Health Information to a family member, other relative, close personal friend, or any other person you designate. If a person has the authority by law to make health care decisions for you, we will generally regard that person as your "personal representative" and treat him or her the same way we would treat you with respect to your Health Information.
• Health Oversight Activities. We may disclose your Health Information to an oversight agency for matters authorized by law, such as audits, investigations, inspections, and credentialing.
• Judicial and Administrative Proceedings. If you are involved in a lawsuit or a dispute, we may disclose your Health Information in response to a court or administrative order, a subpoena, discovery request, or other lawful process instituted by someone else involved in the dispute. We will make a reasonable effort, if permitted under law, to notify you prior to disclosing your Health Information if it is in connection with any of the foregoing.

Your Health Information Rights:

• Inspect and obtain a copy of your Health Information. With a few exceptions, you have the right to access and obtain a copy of the Health Information that we maintain about you in any format in which such information is maintained. To inspect or obtain a copy of your Health Information, you must send a written request to [email protected]. You may also ask us to send a copy of your Health Information to other individuals or entities that you designate. We reserve the right to deny your request if we have a legal basis to do so.
• Request an amendment of Health Information. If you feel that the Health Information we maintain about you is incomplete or incorrect, you may request that we amend it. To request an amendment, you must send a written request to [email protected]. You must include a reason that supports your request and the specific modification that you would like made. If we deny your request for an amendment, we will provide you with a written explanation of why we denied it.
• Notification of a Breach. In the event we experience a data breach that involves the unauthorized disclosure of your Health Information, we will notify you in accordance with law and otherwise comply with applicable state and federal laws following such breach.

Your Privacy Rights

We will provide you with access (including a copy) to the personal information we hold for any purpose including to request that we correct the data if it is inaccurate or to delete the data if Assured is not required to retain it by law or for any legitimate business purpose. We may decline to process requests that are frivolous, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by law.

California/Delaware "Do Not Track Disclosures"

California and Delaware law require us to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. Assured adheres to the standards set out in this Privacy Policy and does not monitor or respond to Do Not Track browser requests.

Third-Party Sites and Services

Assured’s websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

International Transfers

We operate globally. As such, the information you provide us may be transferred to or accessed by our foreign affiliate, which will comply fully with this Privacy Policy. Wherever your personal information is transferred, stored, or processed by us, we will take reasonable steps to safeguard the privacy of your personal information.

Cookies

Our Offerings use cookies and similar tracking technologies that access and store information from your browser and device. Some cookies are necessary to help our Offerings work properly and cannot be denied, and some are optional, used primarily to enhance your experience or analyze usage and performance. For example, these technologies enable us to: (i) authenticate sessions; (ii) better secure our Offerings by detecting fraud; (iii) identify technical issues and improve the overall performance of our Offerings and the services associated therewith; (iv) monitor and analyze the performance of our Offerings, including our marketing efforts; and (v) create a more personalized experience. Based on the foregoing, we’ve adopted this cookie policy ("Cookie Policy") to explain how we use cookies and your related rights. In this Cookie Policy, we use the term "cookies" to refer to any tracking technologies we use as described herein.

What Are Cookies

Cookies are small text files that are stored on your device to help websites and mobile apps remember things about you. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. To learn more about cookies, visit http://www.allaboutcookies.org.

Pixel Tags (also known as web beacons or clear GIFs) are transparent images, iFrames, or JavaScript placed on a website or in marketing emails that are used to understand how you interact with such websites or emails.

Further, social media features, such as the Facebook "like" button, may collect your IP address and which page you are visiting on a website, and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing the relevant social media features. Single sign-on allows you to log in to certain websites or mobile applications using sign-in services provided by third parties, such as Facebook Connect or Google. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form.

How We Use Cookies

The cookies we use can be classified into one of the following categories:

1. Strictly Necessary Cookies - These cookies are set to provide the service, application, or resource requested. Without these cookies, your request cannot be properly delivered. They are usually set to manage actions made by you, such as requesting website visual elements, page resources, or due to user logon/logoff. We can also use these cookies to set up essential functionalities to guarantee the security and efficiency of the service requested, like authentication and load balancer requests.
2. Functional Cookies - These cookies are set by us or by third-party service providers we use to implement additional functionalities or to enhance features and website performance; however, they are not directly related to the service you requested. Services and functionalities implemented by these cookies support features like automatically filled text boxes, live web chat platforms, non-necessary forms, and optional security parameters like a single sign-on (SSO).
3. Performance Cookies - These cookies are set to provide quantitative measures of website visitors. Information collected with these cookies is used in operations to measure website or software performance. Cookies enable us to count visits and traffic sources to improve the performance of our site and application. If you do not allow these cookies, we will not know if or when you have visited our site.
4. Targeting Cookies - These cookies are set by our advertising partners to provide behavioral advertising and remarketing analytical data. They collect any type of browsing information necessary to create profiles and to understand user habits in order to develop an individual and specific advertising routine. The profile created regarding your browsing interest and behavior is used to customize the ads you see when you access other websites.

You can opt out of some (but not all) of third-party tracking technologies we use throughout our Offerings by following the instructions provided by the relevant third-party service providers listed in the table below, in their privacy policies:

Google Adwords - Analytics
This cookie allows us to measure performance to improve the relevancy of advertising and to reduce the number of ads you receive.
https://policies.google.com/privacy?hl=en&gl=uk

Facebook - Analytics
This cookie allows us to measure performance to improve the relevancy of the ads you receive.
https://www.facebook.com/about/privacy/

Outbrain - Analytics
This cookie allows us to measure performance to improve the relevancy of the ads you receive.
https://www.outbrain.com/legal/

Taboola - Analytics
This cookie allows us to measure performance to improve the relevancy of the ads you receive.
https://www.taboola.com/privacy-policy

Your Rights

1. Strictly Necessary Cookies - Because these cookies are essential to operate our Offerings and related services, there is no option to opt out of these cookies.
2. Targeting and Advertising Cookies
   • You can opt out of interest-based targeting provided by participating ad servers through the Network Advertising Initiative at network advertising or the Digital Advertising Alliance at www.aboutads.info.
   • You may be able to change your device settings (on your iPhone, iPad, or Android) to control whether you see online interest-based ads.
   • You can opt out of some (but not all) of third-party tracking technologies by following the instructions provided by the applicable third-party service providers listed in the table below in their privacy policy.
   • You can learn more about your options by visiting www.youradchoices.com or www.youradchoices.eu.
3. Other Cookies - You can follow the instructions provided by your browser (usually located within the "Help," "Tools," or "Edit" facility) to modify your cookie settings.

We may also use a tracking technology (pixels) in emails to understand how often our emails are opened and clicked on by our users/visitors. If you do not wish this tracking to be affected, please change your email software or service (such as Outlook, Gmail, etc.) settings to not automatically download images (to the extent it is not already your default). In some instances, depending on your email or browser settings, cookies in an email may be automatically accepted (for example, when you have added an email address to your address book or safe senders list). Please refer to your email browser or device instructions for more information.

In some of our email messages, we use a “click-through URL” linked to content on the Assured Sites. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our Sites. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

DELETING ALL WEB BROWSER COOKIES

All of the web browser cookies we use are stored on your browser's local memory. Therefore, by deleting such cookies from your local memory, we will not be able to associate any information we have about you unless you log in to our services as a registered customer.

DO NOT TRACK

We do not currently commit to responding to your browser’s ‘Do Not Track’ signals with respect to our Platform, in part, because no common industry standard for ‘Do Not Track’ has been adopted by regulators, including no consistent standard of interpreting a user’s intent. We are committed to monitoring the developments around ‘Do Not Track’ and the implementation of a standard.

CHANGES TO THIS COOKIE POLICY

We may update this Cookie Policy from time to time. We encourage you to periodically review this Cookie Policy to stay informed about our use of cookies, the information we collect via cookies, and any updates in relation thereto. If we make any changes to this Cookie Policy that significantly impact the way we use cookies, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Website. Your continued use of our Platform constitutes your agreement to this Cookie Policy and any updates.

CONTACT US

If you have any questions about our use of cookies, please contact us at [email protected].

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Last Updated: November 2024