Effective January 1, 2020.
1. Information We Receive About You
1.1 Information You Provide to Us. We may collect information that you provide to us in connection with your use of the Service. The information you may provide could include your name and contact information, demographic information such as income and occupation, health information, financial information, driver’s license, social security number, social media data, Health IQ quiz answers, fitness/exercise/activity data, recordings of telephone calls, and a profile picture.
The purpose of collecting this information is to help you apply for insurance and otherwise provide you with the Services, execute transactions requested by you, enhance the Services, prevent and detect fraudulent or prohibited activity, assist with our marketing activities, develop new products, conduct internal business analyses, or for any other lawful purpose. We may share this information as described in Section 2 below.
1.2 Information Automatically Collected Through the Service. Hi.Q, along with our third-party service partners, vendors and business partners may automatically collect information about you when you use the Service. The information automatically collected about you may include, but is not limited to, device ID, device type, browser type and version, geo-location information, computer and connection information, statistics on page views, traffic to and from the Service, ad data, IP address and standard web log information.
The purpose of collecting this information is to provide you with the Services, enhance the Services, prevent and detect fraudulent or prohibited activity, assist with our marketing activities, or conduct internal business analyses, or for any other lawful purpose. We may share this information as described in Section 2 below.
1.3 Information We Collect From Third Parties and Publicly Available Sources. We may also collect information from third parties and publicly available sources. Examples of these information sources include medical, credit, or background check vendors that you authorize us to receive information from, business partners that assist us with marketing activities, or publicly available health and activity data.
The purpose of collecting this information is to help you apply for insurance and otherwise provide you with the Services, execute transactions requested by you, enhance the Services, prevent and detect fraudulent or prohibited activity, assist with our marketing activities, develop new products, or conduct internal business analyses, or for any other lawful purpose. We may share this information as described in Section 2 below.
Cookies are small bits of information that are transferred to and stored in separate files within your computer’s browser. The Service uses both “persistent cookies” which remain on your computer after you have closed your browser as well as “session cookies” which exist only during a visitor’s online session and disappear from your computer when you close your browser.
Locally stored objects or “flash cookies” are data files that can be created on your computer by the websites you visit and are a way for websites to store information for later use. Locally stored objects are different than cookies because they are stored in different parts of your computer than cookies.
Web beacons are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data.
You can set your browser to reject or disable cookies or to notify you when you are sent a cookie. However, if you reject or disable cookies, you may not be able to use all portions or all functionality of the Service. Additionally, you may opt out from receiving some targeted advertising via certain of our partners by visiting the opt-out pages for the following: Network Advertising Initiative opt-out page (www.networkadvertising.org/choices), the Digital Advertising Alliance (www.aboutads.info), and the European Interactive Digital Advertising Alliance (http://youronlinechoices.eu).
2. Hi.Q’s Disclosure of Information to Third Parties.We may share information as follows:
- We may share information with third-party service providers who help us operate and support the Service, assist with marketing activities, conduct research and analytics, or assist with product development and actuarial analyses. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.
- We may share information with the company for which you have asked us to apply for insurance or any other product, including any reinsurers and medical exam vendors.
- For information you post on the Service, such as photos, comments, or your profile, we may share this information with other users of the Service.
- We may share information with our parent company, subsidiaries and corporate affiliates, joint venturers or other companies under common control with us.
- We may share information with companies that acquire our business or assets.
- We may share information with business partners who may wish to offer you products or services that may be of interest to you.
- We may use and share non-personal, de-identified, pseudonymous, or aggregated information we collect under any of the above circumstances. We may also share it with other third parties to develop and deliver targeted advertising on our Site and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated, non-personal information, or personal information in hashed, non-human readable form, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis or other business purposes.
- We may share information with law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Hi.Q user to legal liability, or to protect our rights or property, or during emergencies when safety is at risk. We may also share your information in response to court orders, subpoenas, or other legal or regulatory requests, and we may provide access to your information to our legal counsel and other consultants in connection with actual or potential litigation.
- We may share information with third parties when we forward Digital Millennium Copyright Act (“DMCA”) infringement notifications and counter-notifications as described in the Terms. DMCA infringement notifications and counter-notifications (including any personal information included as part of the notifications) will be forwarded as submitted to us without any deletions.
- We may share information at your direction or with your authorization.
3. No Spam, Spyware or Spoofing. Hi.Q and our users do not tolerate spam. To report Hi.Q-related spam or spoof emails to us, please forward the email to firstname.lastname@example.org. You may not use our communication tools to send spam or otherwise send content that would violate the Terms.
4. Security. Hi.Q takes reasonable measures to protect the information you provide to Hi.Q or submit through the Service against loss, theft and unauthorized use, disclosure, or modification. However, we cannot guarantee or warrant the security of any information you transmit to Hi.Q or submit through the Service and you do so at your own risk. No internet or email transmission is ever fully secure or error-free. Emails sent to or through the Service may not be secure. You should use caution whenever submitting information online and take special care in deciding what information you send to us via email. If you have reason to believe that your interaction with us is no longer secure, please notify us of the situation as soon as possible by contacting us at the addresses listed below; if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the situation, even in those situations in which it is appropriate for use to do so. Users should take care with how they handle and disclose their Personal Information and should avoid sending Personal Information through insecure communication channels, such as email. Please refer to the Federal Trade Commission’s website at https://www.consumer.ftc.gov/topics/online-security for information about how to protect yourself online.
5. Accessing, Changing and Managing Your Information (for Non-California Residents). You may change and update the information you provide through the Service, or change your preferences concerning how we use your information, as follows:
A. Changing or Updating Your Information. You may make changes to the user information you have provided in connection with your Hi.Q account by logging in to your account and changing the applicable information or by contacting us at email@example.com. If you choose to terminate your account, you may also request that we delete your public-facing information by contacting us at firstname.lastname@example.org. Following receipt of a request from you, we will take reasonable steps to update or correct your information, or delete your public-facing information if requested. However, unless prohibited by applicable law, postings or comments you provided and which are associated with your public profile prior to closing your account, will remain accessible.
B. Email Communications. You can make changes regarding receiving email communications from us within your Hi.Q account. You can also choose not to receive email communications from us by following the “unsubscribe” instructions in any email communication you receive from us.
7. Third Parties. The Service may contain links to websites that are not owned or operated by Hi.Q. Please be aware that we are not responsible for the privacy practices of these websites. If you visit these websites or provide any information directly to parties other than Hi.Q (even if those websites display the Hi.Q brand), different policies may apply to the collection and use of your information. We encourage you to investigate and ask questions before accessing third-party websites or disclosing information to third parties.
8. No Use by Children. The Service is not intended for use by children under the age of 13. We will never knowingly collect information directly from children under the age of 13. If you are under the age of 13, you may not use the Service and please do not provide us with information of any kind whatsoever. If we become aware that a user is under the age of 13 and has submitted information to the Service, we will remove his or her information from our files and deactivate his or her account. We encourage parents and guardians to spend time with their children online and to be familiar with the websites they visit. If you have reason to believe that we may have accidentally received personal information from a child under the age of 13, please contact us immediately at email@example.com.
11. HIPAA. Some of the information we collect from users may be subject to laws and regulations governing the use and disclosure of health information, including the Health Insurance Portability and Accountability Act of 1996, as amended from time to time, together with the regulations adopted thereunder (“HIPAA”). When we store, process or transmit “individually identifiable health information” (as defined by HIPAA) on behalf of a healthcare provider, we do so as its “business associate” (as also defined by HIPAA). Notwithstanding any other provision in this Policy, for any information we collect from you that is subject to HIPAA, we will comply with all applicable HIPAA law and regulations.
A. Eligible Requests. You have the right under the CCPA to request one or more of the following: (1) to know the categories of personal information we collect, the source of that information, the business purpose for collecting it, and the categories of third parties with whom we share such information; (2) to receive a file containing certain personal information we have about you; (3) to opt out of the sale of your personal information; and/or (4) to delete the personal information we have about you (“CCPA Request”). We will not discriminate against you if you make a CCPA Request.
B. Procedure for Requests. In order to make a CCPA Request, please click this link and follow the instructions for submitting a request. You may also call (888) 561-7749. In order to make a valid request, you must verify your identity by providing information that matches that information we have in our file, including name, date of birth, address, email, and telephone. For requests to download or delete data, we may also require additional levels of verification, such as a sworn declaration that you are who you claim to be.
D. Authorized Agent. You have the right to authorize a third-party agent to submit CCPA requests on your behalf. If you use an authorized agent, the agent must submit a request through the link provided above, and also provide a sworn declaration stating they have received authority from you to submit a request on their behalf and to receive the information we provide. We may also contact you directly to confirm that the authorized agent has authority to act on your behalf and receive your personal information.
E. Legal Exceptions Under the CCPA. The CCPA includes certain exceptions, which if they apply, exempt your personal information from the CCPA. This is not an exhaustive list, but the following types of data are exempt from the CCPA and may apply to personal information we have about you: (i) personal information or PHI covered by HIPAA; or (ii) personal information covered by the Gramm-Leach-Bliley Act. If you make a CCPA Request that is subject to an exception, we will notify you of the basis for the exception in response to your request.
Last updated January 1, 2020.