Custom Benefit Consultants, Inc., Privacy Policy

I. Information that We Collect

Information that you provide to us:

We may collect information that you provide when using our website, such as when you: (1) create an account; (2) subscribe to our email lists; (3) participate in events or promotions; (4) send questions or comments via email or live chat; (5) interact with our sales or customer support team; (6) apply for a job with us online; (7) fill out surveys; or (8) otherwise communicate with us through or about our Product. The types of personal information that you provide may include your name, email address, telephone number, mailing address, credit card information, and other contact or identifying information that you choose to provide.

We do not store any credit card information we receive except as necessary to complete and satisfy our rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by you.

Information about use of our site:

Our servers automatically collect usage information about your use of the site including the web pages visited, number of log-ins, data displayed or clicked on, actions taken, your language preference, and other login information. We may collect automated error reports in the case of software malfunctions.

If you participate in a video conference with us, we may record the session and retain the recordings. We will notify you first that the session is being recorded so that you can choose not to participate.

We collect information from the device and application you use to access our site. Device data mainly means your IP address, operating system version, device type, device ID/MAC address, system and performance information, and browser type. If you are on a mobile device we also collect the UUID for that device.

We use a variety of technologies to collect this information, such as first party and third party cookies and tracking services that employ cookies and page tags (also known as web beacons). This data includes usage and user statistics. Emails sent by CBC may also include page tags that allow the sender to collect information about who opened those emails and clicked on links in them.

We provide more information in our Cookie Notice below.

When you visit the CBC website, cbcins.com, CBC and its service providers acting on its behalf automatically collect certain data using tracking technologies, for example, cookies, pixels, and web beacons. This notice describes our data collection and tracking practices.

We also partner with third-party ad networks to either display advertising on our website or to manage our advertising on other websites. Our ad network partners use cookies, pixels, and other ad-targeting technologies to collect information about your activities on our website to provide you with targeted advertising based upon your interests. Instructions for opting out of interest-based advertising is set forth in this policy, but you can opt-out of interest-based advertising using the Network Advertising Initiative’s opt-out tool.

Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps.

If you arrive at CBC from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.

How We Use the Information We Collect

Use of Information:

We may use the personal information collected through our Product to:

Operate and improve our site;
Send you advertising or promotional materials;
Provide and deliver the product or other services you request, process transactions, and send you related information;
Send you technical notices, updates, security alerts, and support and administrative messages;
Respond to your comments, questions, and requests and provide you with requested customer support;
Monitor and evaluate trends, usage, and activities in connection with our site;
Secure our systems, prevent fraud, and help us to protect the security of your account;
Prevent, detect, and investigate potentially prohibited or illegal activities and to enforce our terms and policies;
Personalize and improve the Product, and provide content, communications, or features that match users interests; and
Link or combine with other information we obtain from third parties to help understand your needs and provide you with better service.

Information we may share:

We will never “sell” your personal information (as that term is defined in the California Consumer Privacy Act). However, we may share your personal information with third parties as follows:

Service Providers: We use other companies, agents, or contractors to perform services on our behalf or to assist us with the provision of services to you. For example, we engage service providers to provide marketing, advertising, communications, security, payment processing, infrastructure and IT services, to customize, personalize, and optimize our site, to process payment transactions, to provide customer service, and to analyze and enhance data. While providing such services, these service providers may have access to your personal information. These service providers have agreed to maintain the confidentiality, security, and integrity of the personal information that they obtain from us and we do not authorize them to use or disclose your personal information except in connection with providing their services.
Protection of CBC and others: CBC and its service providers may disclose and otherwise use your personal information where we or they reasonably believe such disclosure is needed to (i) satisfy and applicable law, regulation, legal process, or governmental request; (ii) enforce applicable terms of use, including investigation of potential violations; (iii) detect, prevent, or otherwise address illegal or suspected illegal activity, security, or technical issues; or (d) protect against harm to the rights, property, safety of CBC, our users, or the public, as required or permitted by law.
Business transfers: In connection with any reorganization, restructuring, merger, or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your privacy in a manner that is consistent with our Privacy Policy.
With Your Consent: We may share your personal information when we have your consent.
Whenever in the course of sharing information, we transfer personal information to countries within the European Economic Area or other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by the applicable laws on data protection.

Whenever in the course of sharing information, we transfer personal information to countries within the European Economic Area or other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by the applicable laws on data protection.

Advertising and analytics services provider by others:

We may allow others to provide analytics services and display advertisements for our site. These providers (for example, Google Analytics) may use cookies, web beacons, device identifiers, and other tracking technologies that collect information about your use of our site. This information may be used by us and others to determine the popularity of our site, deliver advertising and content targeted to your interests in the site, and on other websites, apps, and other services, and to better understand your online activity. You can find out more about this practice or opt out of your web browsing activity for interest-based advertising purposes by visiting https://aboutads.info/choices. You can opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

Cookies

What are cookies and pixels?

A cookie is a small text file stored on a user’s device that may later be retrieved by a web server from the device. Cookies allow web servers to do certain things like remember the items you placed in a shopping cart or that you are logged in. Some cookies let us and service providers keep track of our website users’ browsing activities and connect certain activities into a session.

A pixel is a very small image that may be found within web pages and emails that requires a call to our servers in order for the pixel to be rendered in those web pages and emails—this call provides information about your device and visit. We use pixels to learn more about your interactions with email content or web content, such as whether you interacted with ads or posts. Pixels can also enable us and third parties to place cookies on your browser.

Are there different types of cookies?

Cookies typically are classified as either session cookies or persistent cookies. Session cookies disappear from your device or browser when you turn off your device. Persistent cookies remain on your browser even if you turn off your device. We use both persistent cookies and session cookies.

Can you stop us from setting cookies?

Yes, you can prevent a website, including ours, from setting cookies. However, if you do so, some parts of the website may not function properly or at all. Please see the Cookie Options section, below.

Does the CBC Website respond to Do Not Track Signals?

Our website and services do not collect personal information about your online activities over time and across third-party websites or online services. Therefore, “do not track” signals transmitted from web browsers do not apply to our Product or services, and we do not alter any of our data collection and use practices upon receipt of such a signal.

Where can I learn more about cookies?

You can learn more about cookies at:

Cookie Options

You have a choice about the placement of cookies on our website. You can use your web browser to directly block all cookies, or just third-party cookies, through your browser settings. Using your browser settings to block all cookies, including strictly necessary ones, may interfere with proper site operation. Guidance on how to control cookies in popular browsers is contained here:

You can also find additional information on cookie controls and advertisement here:

Network Advertising Initiative
Digital Advertising Alliance
Google allows users to opt out of tracking by Google Analytics and Google Analytics Demographics and Interest Reporting services. You can adjust your setting here, or download the
Google Analytics Opt-Out Browser Add-on.
LinkedIn allows users and non-users to opt-out of targeted advertising here.
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising and participate in the opt-out programs established by the Digital Advertising Alliance, the Digital Advertising Alliance of Canada and the European Interactive Digital Advertising Alliance. You can opt out from all participating companies through these sites.
Rollworks/NextRoll Privacy information it is located here: https://www.nextroll.com/privacy
Twitter: https://twitter.com/en/privacy
iContact: https://www.icontact.com/legal/privacy

II. THIRD PARTY WEBSITES

Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website's own terms and policies.

Third-Party Providers

Through the course of using any Custom Benefit Consultant electronic system, you may be directed to an external resource not managed by the company, to fulfill services not directly managed by or provided by the company. In these cases, information you provide through these external resources is not housed by or managed by Custom Benefit Consultants. The Company therefore will not be liable for any data entered into or stored in systems not directly controlled by or managed by Custom Benefit Consultants, Inc.

Non-Personal Information

This Privacy Statement does not restrict our collection, use or disclosure of any aggregated information or information that does not identify, or cannot be reasonably linked to, any individual. However, any such non-personal information will not be sold for direct marketing purposes.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories referenced in State Legislation in select states.	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under specific states or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, IP Address, Geolocation data, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

Personal information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the scope of state or federal legislation, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data, or any similar state-specific legislation in specific states that have passed such legislation;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
Directly and indirectly from activity on our websites (*.cbcins.com or *.controlsourceinc.com). For example, from submissions through our website portal or website usage details collected automatically.
From third-parties that interact with us in connection with the services we perform. For example, from a third party administrator regarding premium deductions or payroll deductions for programs in which you may participate.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities.
To provide you with information, products or services that you request from us.
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
To improve our website and present its contents to you.
For testing, research, analysis and product development.
As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in state legislation enacted in specific states.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:     Identifiers.
Category B:     Customer Records personal information categories.
Category C:     Protected classification characteristics under certain states or federal law.
Category I:       Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties:

Our affiliates.
Service providers.
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

III. YOUR RIGHTS AND CHOICES

Certain state legislation allows consumers who reside in those specific states with specific rights regarding their personal information. This section describes your state legislated rights and explains how to exercise those rights, if your state has enacted such legislation.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we disclosed your personal information for a business purpose,
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with other state or federal legislation that requires such information be retained.
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 800.309.9029.
Visiting cbcins.com/CCPA

Only you or a person registered with the Secretary of State of your primary state of residence that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to contact you to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your state legislated rights. Unless permitted by state or federal legislation, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

IV. CHANGES TO THIS PRIVACY POLICY

We will post any changes we make to this Privacy Statement on our website. If we make material changes to how we treat personal information we collect from you, such updates will be reflected in the updated privacy statement available on the company’s public website. The date this Privacy Statement was last revised is identified above. To ensure you are aware of the most current privacy notices and any updates, it is advised to periodically visit this Privacy Statement on our website to check for any changes.

V. CONTACT INFORMATION

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

CBC Health Insurance Marketplace

Phone: 800.309.9029
Website: cbcins.com
Email: privacy@cbcins.com
Postal Address:
Custom Benefit Consultants, Inc.
Attn: Brandon Russell, Vice President of Operations and Technology
300 S. Fourth St., Suite 700
Las Vegas, NV 89101