Effective Date: 12.11.2019
Long Term Care Group, Inc. (“LTCG,” “we,” “our” or “us”) is committed to controlling the collection, use and disclosure of your personal information and protecting your privacy online.
Scope; Applicability to You
In the event that LTCG is not acting as a data processor, and your Personal Data is not otherwise excluded as set forth above, the following information applies to how we, collect, use, and share your Personal Data.
2. Information We Collect About You and How We Collect It
We collect the following types of information from and about users of our Website (“Personal Data”), specifically information:
· by which you may be personally identified, such as name and email address;
· that is about you but individually does not identify you, such as traffic data, location, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, search query (keywords entered into a search engine) and other communication data and the resources that you access and use on the Website; or
· about your Internet connection, the equipment you use to access our Website and usage details.
We collect this information:
· directly from you when you provide it to us; and
· automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies;
Information You Provide to Us
The information we collect on or through our Website is:
· information that you provide by filling in forms on our Website.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:
· details of your visits to our Website, such as traffic data, location, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, search query (keywords entered into a search engine) and other communication data and the resources that you access and use on the Website; and
· information about the equipment you use to access our Website, usage details and your Internet connection.
The information we collect automatically may include Personal Data, or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service to you. The technologies we use for this automatic data collection may include:
No Information from Children Under the Age of 18
Our Website is not intended for children under 18 years of age. We do not knowingly collect or solicit Personal Data from children under 18. If you are under 18, do not use or provide any information on our Website including, but not limited to, your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at.
3. How We Use Your Information
We use information that we collect about you or that you provide to us, including any Personal Data:
· to fulfill or meet the reason you provided the information;
· to provide, support, personalize, develop and improve the Website;
· to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
· to provide you with notices about your account and to contact you in response to a request;
· to help maintain the safety, security, quality, and integrity of our Website, databases and other technology assets, and business, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity, and to debug to identify and repair errors that impair existing intended functionality;
· to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
· to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of LTCG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by LTCG about our Website users is among the assets transferred in any other way we may describe when you provide the information; and
· for any other purpose with your consent.
4. Disclosure of Your Information
· To affiliates, contractors, service providers, and other third parties we use to support our business;
· 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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by LTCG about our Website users are among the assets transferred;
· to the insurance carrier who has ordered LTCG’s products or services;
· to fulfill the purpose for which you provide it;
· for any other purpose disclosed by us when you provide the information; and
· with your consent.
We may also disclose your Personal Data:
· to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
· if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of LTCG, our clients, or others.
If you have questions or concerns about the disclosure of your personal information, or if you believe your information has been improperly disclosed by LTCG, please contact us at the contact information below.
5. Choices About How We Use and Disclose Your Information
In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:
6. Your Rights Regarding Your Information and Accessing and Correcting Your Information
You may notify us at the contact information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect or if we don’t maintain sufficient Personal Data to validate you.
7. State-Specific Privacy Rights
Your California Rights
As of January 1, 2020, you have the additional rights described in the California Addendum if you are a California resident.
8. Security of Your Information
LTCG is committed to the security of your personal information and LTCG has policies and procedures in place to protect the privacy of your Personal Data. Personal Data shall be protected in a manner commensurate with its sensitivity and reasonable steps will be taken to secure it from accidental loss, and from unauthorized access, use, alteration and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to the Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
10. Contact Information
Attn: Privacy Officer
11000 Prairie Lakes Drive, Suite 600
Eden Prairie, MN 55344
Effective Date: January 1, 2020
Generally, LTCG acts as a service provider (as defined by the CCPA) and assists insurance carriers by acting as a third party administrator for long-term care insurance products. As part of our services, our clients (typically your long term care insurance provider) may share your information with us for LTCG to perform administrative support services including, but not limited to, application processing, commission administration, provider databases, underwriting, policy administration, claims and care management, and cognitive and functional assessments. To facilitate these services, we also host web portals, such as this Website, on behalf of our clients to provide services to you related to your long term care needs.
In the event that we are not acting as a service provider, and your CCPA Covered Personal Information is not otherwise excluded as set forth above, the following information applies to how we, collect, use, and share your CCPA Covered Personal Information.
Further, this California Addendum does not apply to information or organizations excluded from the CCPA’s scope, including:
· Medical information governed by the California Confidentiality of Medical Information Act (CMIA), protected health information collected by a covered entity or business associate governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), or a provider of health care governed by the CMIA or covered entity governed by HIPAA to the extent the provider or covered entity maintains patient information in the same manner as medical information or protected health information under the CMIA or HIPAA, respectively;
· Publicly available information from government records;
· Deidentified or aggregated consumer information; and
· Other exclusions as set forth under applicable California law.
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 household (“ CCPA Covered Personal Information ” or “ personal information ”). In particular, this website(the “Website”), has collected the following categories of personal information from consumers within the last twelve (12) months:
A real name, online identifier, Internet Protocol address, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
*Note: Personal information included in this category may overlap with other categories.
C. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
LTCG obtains the categories of personal information listed above from the following categories of sources:
· We collect Category A and B directly from you when you provide it to us. For example, from forms or applications you complete.
· We collect Category A and C indirectly from you. For example, from observing your actions on our Website.
Use of Personal Information
We have used or disclosed all the above categories of personal information we collect for one or more of the following business purposes:
· To fulfill or meet the reason you provided the information.
· To provide, support, personalize, and develop our Website, products, and services.
· To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
· To help maintain the safety, security, quality, and integrity of our Website, products and services, databases and other technology assets, and business, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity, and to debug to identify and repair errors that impair existing intended functionality.
· For testing, research, analysis, and product development and demonstration, including to develop and improve our Website, products, and services.
· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of LTCG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by LTCG about our Website users is among the assets transferred.
· As described to you when collecting your personal information or as otherwise set forth in the CCPA.
LTCG will not collect additional categories of personal information or use the personal information we collected for additional purposes without providing you notice.
Sharing Personal Information
Disclosures of Personal Information for a Business Purpose
In the past twelve months, LTCG has disclosed identifiers and internet or other similar network activity to its affiliates, contractors service providers or other third parties we use to support our business.
Sales of Personal Information
LTCG does not sell consumers’ personal information and has not sold consumers’ personal information in the preceding twelve (12) months.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that LTCG disclose certain information to you about our collection of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights ), 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, two separate lists disclosing:
· sales, identifying the personal information categories that each category of recipient purchased; and
· 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 LTCG delete any of your personal information that we have collected or maintained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights ), 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 provider(s) to:
1. 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. 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:
· Emailing firstname.lastname@example.org .
· Mailing a request to: Long Term Care Group, Inc.
Attn: Privacy Officer
11000 Prairie Lakes Drive, Suite 600
Eden Prairie, MN 55344
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf (an “Authorized Agent”), 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.
Please note that LTCG is not obligated to provide information to a consumer in response to a request more than twice in a twelve (12) month period. The verifiable consumer request must:
· Provide sufficient information (first name, last name and address) that allows us to reasonably verify you are the person about whom we collected personal information or an Authorized Agent. Before completing your request to exercise the below, we will verify that the request came from you by validating your first name, last name and address.
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We are unable to fulfill 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. With few exceptions, we will only review and fulfill a request from your Authorized Agent if (a) you grant the Authorized Agent written permission to make a request on your behalf, (b) you or the Authorized Agent provides us notice of that written permission, and (c) we are able to verify your identity in connection with that notice and the request.
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 forty-five (45) days of its receipt. If we require more time (up to 45 additional 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 twelve (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.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.
Changes to Our Privacy California Addendum
LTCG reserves the right to amend this California Addendum at our discretion and at any time. When we make changes to this California Addendum, we will post the updated California Addendum on the Website and update the California Addendum’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes .
If you have any questions or comments about this California Addendum, the ways in which LTCG collects and uses your information described below, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Mailing Address:Long Term Care Group, Inc.
Attn: Privacy Officer
11000 Prairie Lakes Drive, Suite 600
Eden Prairie, MN 55344