Revised December 1, 2024

This Privacy Notice describes the types of information that Digital Insurance, LLC and its affiliates (OneDigital, we, us, or our) may collect from you and/or your company or that you and/or your company may provide when you and/or your company visit our website http://onedigital.com (our “Site”) or otherwise interact with OneDigital and our practices for collecting, using, maintaining, protecting and disclosing that information. In addition to you and/or your company this Notice applies to information about the former and current employees, dependents, and other eligible plan participants for which we are providing services.

This Privacy Notice applies to information we collect on or through our Site, from electronic messages between you and/or your company and information collected through other means related to the Services provided by OneDigital except forNotice information collected by: (i) us offline or through any other means, including through any other website or platform operated by any third party; or (ii) any third party (including our affiliates), including through any application or content that may link to or be accessible from our Site.

This Privacy Notice does not apply to your use of a third-party site linked on our Site. The inclusion of a link to a third-party website does not imply endorsement of the linked site or service by us or our affiliates. These third-party websites will be governed by different terms of use (including privacy notices) and you and/or your company are solely responsible for viewing and using each such website in accordance with the applicable terms of use. OneDigital is not responsible for how your Personal Information is handled by such third-party websites.

Please read this Privacy Notice carefully to understand our policies and practices regarding your information. By accessing or using or seeking to access or use our Site or Services, you and/or your company agree to this Privacy Notice. You and/or your company may also withdraw your consent to the terms of our Privacy Notice at any time by contacting us.

California Residents: The California Consumer Privacy Act of 2018 (“CCPA”) applies solely to visitors, users, and others who reside in the State of California when you and/or your company visit our Site or subscribe to receive OneDigital Services. This Notice does not apply to our job applicants, employees, contractors, owners, directors, or officers where the personal information relates to their current, former, or potential role at OneDigital.

Information We Collect About You and/or Your Company

As you and/or your company navigate through and interact with our Site or use or seek to use our Services, we may collect, through automatic or manual data collection technologies, certain information about your equipment, IP addresses, browsing actions and patterns to improve our Site and deliver a better and more personalized service. The technologies we use for this automatic data collection may include cookies and web beacons.

We may use E-mail and SMS (Short Message Service) for communication purposes, including but not limited to account verification, notifications, and customer support. By providing your email address or phone number, you and/or your company consent to receive messages from us. Standard message and data rates may apply.

When you and/or your company receive SMS messages from us, we may collect certain information automatically, including the date and time of the message, the content of the message, and information about your device. This information is used for internal purposes such as improving our services and ensuring the security of our systems. We may also collect personal information you and/or your company provide to us during SMS interactions, such as your name, phone number, and any other information you and/or your company choose to share. This information is used in accordance with our Privacy Notice.

We do not share your personal information or mobile data obtained through SMS messages with third parties for marketing purposes unless required by law or with your explicit consent.

You and/or your company have the option to opt out of receiving messages from us. You and/or your company can opt out of SMS messages by replying to any of our messages with the word “STOP”. You and/or your company can opt out of email messages clicking unsubscribe in any of our messages.

If you and/or your company have any questions or concerns about our use of SMS and the collection of data, please contact us at [email protected].

California Residents: Additionally, we may collect or disclose the following the categories of personal information about California residents in the preceding 12 months. We obtain these categories of personal information:

• Directly from our clients or their agents. (e.g., from documents that our clients provide to us related to the services for which they engage us).
• Indirectly from our clients or their agents. (e.g., through information we collect from our clients in the course of providing services to them).
• Directly and indirectly from activity on our Site. (e.g., from submissions through our website portal or website usage details collected automatically).

General Population

California Residents

Personal Information or Data such as name, social security number, date of birth, postal address, e-mail address, telephone number, cookies, usage data, and other data that could directly or indirectly identify you and/or your company. Site Visit or Usage Data and Marketing Information such as interest in products or services, company demographics, and registration for or attendance of webinars or seminars. Transaction Details such as transactions relating to Notice coverage, insurance premiums, insurance claims and payment history. Cookies or browser cookies such as a small file placed on a user’s computer for record-keeping purposes. OneDigital uses both “session ID cookies” and “persistent cookies.” OneDigital uses session ID cookies to make it easier for you and/or your company to navigate the Site. A session ID cookie expires when you and/or your company close your browser. If you and/or your company check “remember me” when logging in to the Site, OneDigital also sets a persistent cookie to store your username passwords, so you and/or your company do not have to enter it more than once. The persistent cookie also enables OneDigital to track and target the interests of users to enhance the experience on the Site. You and/or your company may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you and/or your company select this setting you and/or your company may be unable to access certain parts of our Site. Unless you and/or your company have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you and/or your company direct your browser to our Site. Web Beacons such as small electronic files (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit OneDigital, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity)

Personal Information, Professional/Employment Information and Other Identifiers such as name, postal address, contact information, unique personal identifier, IP address, email address, account name, Social Security number, education, current or past employment, professional and financial information. Inferences drawn from other personal information such as profile reflecting person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Commercial information such as transaction information, purchase history, financial details, and payment information. Internet or other similar network activity such as browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement. Geolocation and Sensory Data such as physical location or movements, audio, electronic, visual, thermal, olfactory, or similar information. Protected Classification Characteristics such as age, ethnicity, citizenship, religion or creed, marital status, physical or mental illness, disabilities, gender, and veteran status).

How We Use and Disclose Your Information

We may use and process information that we collect about you and/or your company or that you and/or your company provide to us for our legitimate business interests, including any personal information or data. We may disclose aggregated information and other anonymous data to third parties without restriction. We may use, process, or disclose personal information or data without your permission under the following circumstances:

How We Use Your Information General Population & California Residents

Disclosure of Your Information General Population & California Residents

To present our Site and its contents to you and/or your company. To provide you and/or your company with information, products or services that you and/or your company request from us. To notify you and/or your company about changes to our Site or any products or services we offer or provide through it. To fulfill any purpose for which you and/or your company provide such information. For OneDigital’s internal business purposes. To carry out our obligations and enforce our rights arising from any contracts entered into between you and/or your company and OneDigital. In any other way we may describe when you and/or your company provide the information. For any other purpose with your consent.

To third party service providers such as entities providing customer service, email delivery, auditing, hosting our website and other services. To a medical care institution or medical professional to verify coverage or benefits, to inform you and/or your company of a medical problem of which you and/or your company may not be aware or to conduct an audit that would enable us to verify treatment. To our affiliates, contractors, service providers and other third parties we use to support our business or deliver insurance-related services to you and/or your company. To third parties involved with events that you and/or your company register for, to facilitate your participation in those events. To fulfill any purpose for which you and/or your company provide such information. For any other purpose disclosed by us when you and/or your company provide the information. To an insurance carrier, agent or credit reporting agency to detect, prevent or prosecute actual or potential criminal activity, fraud, misrepresentation, unauthorized transactions, claims or other liabilities in connection with an insurance transaction. To comply with any court order, law or legal process, government or regulatory request. To enforce or apply our Terms of Use and other agreements between you and/or your company and OneDigital. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of OneDigital, our affiliates, customers or service providers. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of OneDigital’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by OneDigital about user of our Site is among the assets transferred. For any other purpose with your consent.

California Residents: OneDigital has not sold personal information as defined or contemplated by the CCPA in the preceding 12 months.

Your Data Privacy Rights

Generally, you and/or your company have certain rights in relation to your personal information. Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, as a resident of the EEA, you and/or your company have certain rights in relation to your personal information. For California residents, CCPA grants certain rights in relation to your personal information.

General Population	California Residents	European Economic Area
Right to Opt-Out: You and/or your company can opt-out if you and/or your company do not wish to have your contact information used by OneDigital to promote our own products or services. Right to Correct: You and/or your company may request correction or destruction of any of your personal information or data maintained by us to the extent that any such request would not violate any law or legal requirement or cause the information to be incorrect.	Right to Know: You and/or your company have the right to know what specific pieces of personal information OneDigital has collected and retained about you and/or your company over the preceding 12 months. Right to Receive: You and/or your company have a right to receive a copy of your personal information. Right to Delete: You and/or your company have a right to delete your personal information. Right to Exercise Rights: You and/or your company have a right to exercise your rights under the CCPA without discrimination. Right to Correct: You and/or your company may request correction or destruction of any of your personal information or data maintained by us to the extent that any such request would not violate any law or legal requirement or cause the information to be incorrect. *OneDigital does not sell your personal information, so we do not offer an opt-out.	Right to Access: You and/or your company have the right to obtain information on what personal data of yours the data controller is being processed, for what purpose the data is being disclosed, to whom it has been or will be disclosed, and how long the data will be store.. Right to Rectify: You and/or your company have the right to request the data controller rectify inaccurate personal data. Right to Erase: You and/or your company have the right to request the data controller erase your personal data where the data is no longer necessary, you and/or your company have withdrawn your consent to processing, or in other circumstances as outline in Article 17 of GDPR. Right to Restrict: You and/or your company have the right to restrict the processing of your personal data. Right to Data Portability: You and/or your company have a right to receive your personal data and transmit those data to another controller. Right to Object: You and/or your company have a right to object at any time to processing of your personal data. Right to Object to Automated Decision-Making: If utilized, you and/or your company have the right not to be subject to a decision based solely on automated processing, including profiling.
How to Submit a Request
Submit your request via the Data Subject Request Form. Request to be omitted from future e-mail distributions by following the opt-out instructions in the promotional email or by sending us a return e-mail with your request to be omitted from future e-mail distributions.	You and/or your company can exercise these rights by contacting us at 1-800-364-7575 or submitting the Data Subject Request Form. We will respond to requests in accordance with the CCPA if we can verify your identity or the identity of your authorized agent submitting the request. A California resident may designate an authorized agent registered with the California Secretary of State to submit a disclosure or deletion request on behalf of the California resident. For OneDigital to respond to a request from an authorized agent, we may: (1) Request a copy of the written permission granting the authorized agent to make such a request on the California resident’s behalf; and (2) Verify the identity of the California resident. We may deny a request from an authorized agent that does not submit proof that they have been authorized by a California resident to act on their behalf.	If you and/or your company want to exercise any of the rights outlined above, please submit a Data Subject Request Form. We may ask you and/or your company for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you and/or your company. We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you and/or your company if we require further information in order to fulfill your request. 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. For more information on the General Data Protection Regulation, see more resources at https://gdpr-info.eu and http://gdprandyou.ie.

Exception to Disclosure to Comply with Law

OneDigital will not use or disclose protected health information (PHI): (1) to conduct a criminal, civil, or administrative investigation into or impose criminal, civil, or administrative liability on any person for the mere act of seeking, obtaining, providing, or facilitating reproductive health care, where such health care is lawful under the circumstances in which it is provided; and (2) for the identification of any person for the purpose of conducting such investigation or imposing such liability.

Data Retention

OneDigital will retain and use your personal information or data no longer than is necessary for the purposes outline in this Privacy Notice, or as required to comply with our legal obligations under HIPAA or other applicable laws. OneDigital may also retain and use your personal information and data to the extent needs to resolve disputes and enforce legal agreements. Subject to the foregoing, OneDigital will retain and use your personal information or data no longer than 10 years from its last use.

Data Security

We have security measures in place to protect against the loss, misuse and unauthorized alteration of personal information under our control, including physical, electronic and procedural safeguards that meet or exceed applicable federal and state standards. Although we use commercially reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of Personal Information or data is at your own risk.

Children Under the Age of 13

Our Site is not intended for children under 13 years of age. No one under age 13 may provide any information through our Site. If you are under 13, do not use or provide any information on our Site or on or through any of its features. We do not knowingly collect personal information from children under 13; however, if we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. Please contact us if you believe we might have personal information about a child under age 13.

Notice of Financial Incentives

California residents have a right to receive Notice of Financial Incentive, as defined in the CCPA. This Notice provides you and/or your company with information regarding any financial incentive or “price or service difference” that we may provide in exchange for your personal information.

When using our services, you and/or your company may provide personal information from time to time or on an ongoing basis, directly or indirectly, in exchange for cash, gifts, or other financial incentives, or price or service difference, the amount or nature of which will be specified in each instance at the time the personal information is provided. You and/or your company can opt into the financial incentive or price or service difference by providing your personal information. If you and/or your company wish to opt-out of the financial incentive or price or service difference, do not provide your personal information or you and/or your company may request withdrawal on an ongoing basis by submitting a Data Subject Request Form.

Each financial incentive or price or service difference related to submission and use of consumer personal information is based upon our reasonable but sole determination of the estimated value of such information, which takes into consideration, without limitation, estimates of the anticipated revenue generated from the information, the anticipated expenses which might be incurred in the collection, storage, and use of the information in the operation of our business, and other relevant factors related to the estimated value of the information to our business, as permitted under the CCPA.

Processing Personal Data under General Data Protection Regulation (GDPR)

OneDigital is a United States based corporation with its principal place of business at 200 Galleria Parkway, Suite 1950, Atlanta, GA 30339. OneDigital’s Site is managed and operated solely on servers within the United States. Accordingly, OneDigital does not purposely avail itself of the European Economic Area (EEA). However, if you and/or your company reside in the EEA, OneDigital may be a data controller of all personal data collected on our Site. The personal data of any individual who resides outside of the United States provided to us will be transferred to and processed in the United States. Our Privacy Notice above describes which “Information We Collect Automatically When You and/or Your Company Use Our Site,” “How We Use Your Information,” and our policies on “Disclosure of Your Information.”

Changes to Our Privacy Notice

We may update our Privacy Notice from time to time. Any changes we make will be posted on our Site, and we will revise the version date located at the top of this page. It is our Notice to post any changes we make to this Notice on this page with a notice that the Notice has been updated on our Site home page. All changes to this Privacy Notice become effective when posted and your continued use of our Site after we post such changes is deemed to be an acceptance of those changes. You and/or your company are responsible for periodically visiting our Site and this Privacy Notice to check for any changes.

Contact Information

Please direct any questions or comments about this Privacy Notice to [email protected].