- INFORMATION WE COLLECT AND HOW USE IT
Personal Identifiable Information (PII) Notice and Report of Consumer Consent. As required by Centers for Medicare and Medicaid Services (CMS) and the Individual Marketplace and SHOP Privacy & Security Agreements that all agents and brokers must submit a privacy notice to ensure openness and transparency about policies, procedures, and technologies that directly affect consumers’ PII. PII is any information that can be used to distinguish or trace a consumer’s identity (e.g., his or her name, Social Security Number, biometric records) alone or when combined with other personal or identifying information that is linked or linkable to a specific consumer (e.g., date of birth, place of birth, mother’s maiden name). Filling out this form will give Compass Insurance Advisors including all staff and licensed downline Agents and Agencies legal authority to collect your PII for purpose of data verification to submit potential applications to Insurance Carriers in an attempt to gain an insurance policy or limited benefits. This PII information will be disclosed to applicable Insurance Carriers, Compass’s third party technology affiliates, any Compass support staff in an effort for processing applications, client supports, Compass marketing system, email campaigns, texting campaigns, and other similar uses and platforms as outline by Compass now or with future changes and applications in technology. This request for PII from you is voluntary and not required by law. At any point you may request a copy of your PII information provided in this form which will be provided to you in the most timely manner possible given the time of year demand, or other factors outside of our control. This notice also serves as a Record of Consumer Consent and is subject to your right of withdrawal. By signing or submitting this form you are agreeing to the outline above as well as all other terms and conditions listed in this form.
I further understand that this form, and the information listed herein, constitutes a basic gathering of information intended for Compass and its affiliated agents to better understand my specific health benefit needs (including benefits through the Health Insurance Marketplace) and for entry in a health benefit plan application, and IS NOT an official application for a qualified health plan. I also acknowledge that this is a Privacy Notice Statement in an attempt to collect Personal Identifiable Information (PII) that may be used for any qualified or non-qualified insurance benefits. I hereby agree to indemnify and hold harmless Compass, its employees, agents and/or my Compass Agent from and against any and all actions, claims, lawsuits, demands, costs, expenses, liabilities and losses, including reasonable attorney’s fees (“Claims”), which may result against me by reason of any acts or omissions of Compass, its agents, employees, or my Compass Agent in connection with, but not limited to, the benefits received from my selected health benefit package, the loss and/or mishandling of information listed in this form. By submitting this form, I further acknowledge that I am not agreeing to be enrolled in any benefits but only providing information to assist Compass in researching potential health insurance options. This authorization includes, but is not limited to, the ability for any Compass Employee to utilize this information and enter such information onto any websites requiring such information for health benefit quotes and/or benefit information purposes.
2. INFORMATION SHARING
Specifically, we do not permit our Service Providers to sell any personal information we share with them or to use any personal information we share with them for their own marketing purposes or for any purpose other than in connection with the services they provide to us.
3. DATA SUBJECT RIGHTS AND CHOICES
Compass recognizes individuals’ data protection rights. You have the right to access, correct, update, port, or delete your personal information, and to restrict or object to the processing of your personal information (each of these a “Rights Request”). You may email us at [email protected] with any Rights Request, and we will respond within thirty (30) days. Customers and Administrative Users also can access, correct, export, or update their Account Information by editing their profile or organization record at Compass.com.
Please note that before we can complete your Rights Request, we will need to verify that your identity matches that of the data in which you are requesting to exercise your rights. You can expect a verification email under separate cover, to the email address associated with your personal information on file. If you are making a Rights Request on behalf of another individual as an authorized agent, we require that either (a) the data subject must verify their identity and directly confirm with Compass they provided the authorized agent permission to submit the Rights Request, (b) the authorized agent must be provided power of attorney by the data subject in accordance with the law of the data subject’s jurisdiction, or (c) the Rights Request must otherwise be submitted in accordance with applicable privacy law.
For any Rights Request, we will need to verify a requestor is inquiring about their own information before we can assist. Where a Rights Request may implicate the personal information of another individual, we must balance the request against the risk of violating another person’s privacy rights.
4. COMMUNICATION PREFERENCES
Compass will send you commercial communications based on the communication preferences in your account settings. Compass also will send you service-related communications. You may manage your receipt of commercial communications by clicking on the “unsubscribe” link located on the bottom of such emails, through your account settings if you have a Compass account, or you may send a request to [email protected].
5. DATA SECURITY, DATA INTEGRITY AND ACCESS
We take all reasonable steps to protect information we receive from you from accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access. We have put in place appropriate physical, technical and administrative measures to safeguard and secure your information, and we make use of privacy-enhancing technologies such as encryption. If you have any questions about the security of your personal information, you can contact us at [email protected].
6. DATA RETENTION
We store your personal information for a period of time that is consistent with the business purposes set forth and required by your resident state department of insurance and the Centers for Medicare Services (CMS) along with all required licensed agent certifications including America’s Health Insurance Plans (AHIP) certification and the Federal Facilitated Marketplace (FFM) certification as required by CMS for licensed agents to service clients with Medicare and Marketplace (www.healthcare.gov) insurance plans.
7. NOTIFICATION OF CHANGES
If we make changes to this Policy that we believe materially impact the privacy of your personal information, we will promptly provide notice of any such changes (and, where necessary, obtain consent), as well as post the updated Policy on this website noting the effective date of any changes.
8. BUSINESS TRANSACTIONS
We may assign or transfer this Policy, as well as information covered by this Policy, in the event of a merger, sale, change in control, or reorganization of all or part of our business.
9. ENGLISH LANGUAGE CONTROLS
Non-English translations of this Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.
10. DISPUTE RESOLUTION
If you have an unresolved privacy or data-use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
11. NOTICE TO CALIFORNIA RESIDENTS
This section applies only to California residents. It describes how we collect, use, and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household as defined in the CCPA. It does not include information exempted from the scope of the CCPA.
How We Collect, Use, and Share Your Personal Information under the CCPA
We may collect, use, and disclose for our business and commercial purposes, the following categories of Personal Information:
- Payment and customer records information of our Customers;
- Protected classification characteristics (e.g., age, ethnicity, race, languages spoken, or gender) to the extent these characteristics are voluntarily disclosed to us or contained in any content transmitted across or stored on our network;
- Commercial information (e.g., records of products or services purchased, obtained, or considered, or other purchasing or usage histories);
- Professional or employment information;
- Internet or other electronic network activity information; and
- Inferences (e.g., information about your interests or preferences).
Your California Privacy Rights
As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- Knowledge. You can request information about what personal information we have collected about you, including:
- the categories of personal information;
- the categories of sources from which the personal information is collected;
- the business or commercial purpose for collecting, selling, or sharing personal information;
- the categories of third parties to whom we disclose personal information;
- the specific pieces of personal information that we have collected about you.
- Access. You can request a copy of the Personal Information that we have collected about you.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
- Correction. You can ask us to rectify inaccurate personal information and, taking into account the purpose of processing the personal information, ensure it is complete;
- Opt-out of sales or sharing. You can ask that we do not “sell” or “share” your Personal Information as “sell” and “share” are explicitly defined under the CCPA. For more information, please refer to the section titled “Right to Opt Out of the Sale and Sharing of Your Personal Information” below.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you the Services; increasing the price/rate of the Services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.
In order to submit a request to exercise your right of information, access, or deletion pursuant to the CCPA, please follow the instructions for the submitting a Rights Request. Please note, we reserve the right to confirm your California residence to process your requests and may need to confirm your identity to process certain requests using the verification methods described. For example, we take reasonable precautions to verify the identities of those California residents submitting requests to delete or access Personal Information.
Right to Opt Out of the Sale and Sharing of Your Personal Information
Compass does not sell your Personal Information in the conventional sense (i.e., for money). Like many companies, however, we use services that help deliver interest-based ads to you and may transfer Personal Information to business partners for their use. Making Personal Information (such as online identifiers or browsing activity) available to these companies may be considered a “sale” or “sharing” of your Personal Information under the CCPA.
You can request to opt out of such “sale” or “sharing” of your Personal Information using the “Do Not Sell or Share My Personal Information” link in the footer below.
In addition, some internet browsers offer the option to enable opt-out signals such as Global Privacy Control that lets you tell websites that you do not want to have your online activities tracked. Compass responds to these signals by processing them as a request to opt out of the “sale” or “sharing” of your Personal Information as discussed above.
Please note that you will still see some advertising, regardless of your selection. We do not impose verification protocols for processing opt out requests unless we have reason to question the authenticity of a requester’s identity, in which case we may request evidence of identity and California residency.
12. CONTACT INFORMATION
Compass Insurance Advisors LLC
38 E Scenic Pointe Drive, Suite 140
Draper, Utah 84020
Phone: 801.901.3519 / (801)900-5445 Fax: 801.994.1558
Attention: Data Protection