This Privacy Policy lets you know how we collect, use, share, and protect information about you when you interact with NationsBenefits, LLC., dba NationsHearing (including its subsidiaries, such as NationsOTC, LLC., NationsBenefits Insurance Sales, LLC., dba Nations Insurance Solutions (excluding Michigan); dba Nations Insurance Services in New York (collectively, “Company”, “us”, “our” or “we”), through our website, however accessed, (the “Site”) to use or obtain any of our products or services, (the “Services”). When we post this Privacy Policy, we explain what information we collect through the Site, how we use it, with whom we share it, and the choices you have to control, access, and update your information.

In some circumstances, our use of your information will be subject to the requirements of the Health Information Portability and Accountability Act (commonly known as “HIPAA”). For example, when you upload your audiogram or submit a hearing aid order, that information is subject to HIPAA requirements. In those circumstances, our Notice of Privacy Practices will also apply.

If you have questions about which policy applies to the information you have submitted, please do not hesitate to contact us.

By using our Services, you agree to the privacy practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please stop using the Services. By continuing to use the Services, you accept this Privacy Policy.

FOR CALIFORNIA CONSUMERS

If you are a California Consumer, please refer to YOUR CALIFORNIA PRIVACY RIGHTS section below.

INFORMATION WE COLLECT

The information we collect from you varies, depending on the way you use our Services. We collect information from or about you in the ways described below.

Information You Provide to Us
When you use our Site or Services, we collect information that you choose to share with us. We collect several types of personal information from and about you when you use our Site or Services. This information may include:

• Name
• Address
• Email address
• Telephone number
• Date of birth
• Credit or debit card information
• Audiogram or hearing aid information, and photos thereof
• Hearing provider information
• Insurance and health plan information, including ID number
• Your communications and interactions with our Services

We also collect any information you choose to provide to us.

Other Information We Collect When You Use the Services
Our Site may collect certain information automatically about you and your use of our Site and Services that does not necessarily personally identify you, your interactions with us and information regarding the device you use to access our Site and Services (collectively “Other Information”). This information includes:

• Device information, such as hardware setting, web browser type, and language
• IP address, MAC address
• Identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., device advertising ID)
• Times you have accessed pages
• Pages you have viewed
• Searches you have conducted
• Pages you visited before or after navigating to our Website

Information We Collect from Third Parties
We may collect information about you from third parties including social media networks, advertising providers, and analytics providers (see below) or publicly available sources. For example, we may receive information about you from a partner when we jointly offer services or from an advertiser about your experiences with them. We combine that with the information we collect through our Services.

HOW WE USE YOUR INFORMATION

We use your information to provide, analyze, administer, enhance, and personalize our Site and the Services we provide to you. We also use your information to communicate with you and to operate our business. More specifically, we may use your information to:

• Deliver our Services to you, including providing access to our Site’s online features, such as hearing tests and audiogram verification, completing and processing your online purchases or engaging in other transactions with us.
• Communicate with you about the Services, including to respond to your customer service requests or respond to any other inquiry or correspondence you send to us.
• Interact with you when you engage us on our Virtual Care and Live Chat feature.
• Present you with marketing relating to our Services.
• Provide you updates, reminders, or other informational or educational content.
• Analyze and improve the Site and Services, including developing and improving products and services, monitoring, and analyzing trends and usage.
• Prevent, detect, investigate, or remediate security or other legal concerns, including fraud.
• Protect the rights, property, or safety of us our users, or any other person or the copyright-protected content of the Services.
• Comply with applicable laws, regulations, or industry requirements, or respond to subpoenas or government requests.
• Fulfill any other purpose for which you provide or consent.

HOW WE SHARE YOUR INFORMATION

We may share information collected about you in the following situations:

• With service providers, sellers, and partners:
  • We share information about you with service providers to perform functions and process your data and to help provide our Services including hosting and storage providers, payment processors, etc.
• With third parties for legal or security reasons:
  • We may share information about you if we reasonably believe that disclosing the information is needed to:
    • Comply with any valid legal process, governmental request, or applicable law, rule, or regulation.
    • Investigate, remedy, or enforce potential violations of our Terms of Use of Privacy Policy.
    • Protect the rights, property, and safety of us, our users, or others.
    • Detect and resolve any fraud or security concerns.
• With third parties as part of an acquisition or liquidation:
  • We are involved in a merger, asset sale, financing, corporate divestiture, reorganization, or acquisition of all or some portion of our business to another company or if we undergo liquidation or bankruptcy proceedings, we may share your information in connection with such transaction or proceeding before and or after the transaction closes or the proceedings are completed.
• With your health plan or hearing provider to verify your information.
• With your consent or if you direct us to do so
• We do not share personal information with third parties for their marketing

Legal Disclaimer
Though we make every effort to preserve user privacy, we may disclose personal information when required by law or under the good-faith belief that such action is necessary or obligatory under applicable law. We may disclose personal information in order to establish or exercise our legal rights or defend against legal claims. We also share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, to protect our property or interests or that of our agents and employees, and to protect personal safety or the public.

Aggregated De-Identified Information
We may also share with third parties—such as advertisers—aggregated, or de-identified information and we do not limit our thirdparty providers from using, selling, licensing, distributing, or disclosing de-identified data.

How We Use Cookies and Other Tracking Technologies

We and our research, technology, and marketing partners, affiliates, analytics, or service providers use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. Cookies are small amounts of data which are sent to your browser from a website’s computers and stored on your computer or device.

• Remembering your preferences and allowing you to enter your username less frequently;
• Uniquely identify each user session when you access the Services;
• Compile aggregated statistics to analyze how the Services are used;
• Present you and communicate to you information that is targeted to your interests, including our content presented on another website and across devices; and
• Measure the effectiveness of our sites, services, content, communications, and advertising, including by placing web beacons (sometimes called single-pixel gifs) which emails, and links have been opened by recipients.

We may let third parties use cookies, web beacons, and similar tracking technologies on our Services. They may collect information about how you use our Services and other websites and online services over time and across different services. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

Interest-Based Advertising
Some companies may use information collected on our Site to deliver advertisements on behalf of us or other companies, targeted to your interests and preferences, on our Site or on other websites or applications you may visit, on your various devices, or on your social media feed and to gauge their effectiveness.

You can understand which third parties have currently enabled cookies for your browser or mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative’s website at http://optout.networkadvertising.org/#!/ or the Digital Advertising Alliance’s website at http://optout.aboutads.info/#!/ or, if you’re located in the European Union (“EU”), at http://www.youronlinechoices.eu from your browser. For more information on mobile specific opt-out choices, please visit http://www.networkadvertising.org/mobile-choices and from your mobile device.

On your mobile device you may have features that allow you to opt-out of some targeted advertising (“Limit Ad Tracking” (on iOS devices) or “Opt-out of Interest-Based Ads” (on Android). To learn more about how these opt-out features work, please review your device settings.

Even if you disable the tracking, keep in mind that you may still receive interest-based advertising, including from third parties with whom your information had been previously disclosed and that you may still receive advertising from third parties, though such advertising may not be based on your interests and preferences.

Third Party Analytics
We may use automated devices and applications, such as Google Analytics, to evaluate traffic to our Services. Google Analytics is a web analysis service provided by Google that utilizes cookies to monitor and provide us with aggregate data about traffic. We use these tools to help us improve our Services, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not combine the information collected through the use of Google Analytics with personally identifiable information. We do not share or combine the information collected through the use of Google Analytics or any other thirdparty with personally identifiable information.

HOW WE PROTECT YOUR INFORMATION

We take reasonable precautions to protect your information. Please keep in mind that the Internet is not a 100% secure medium for communication, and we cannot guarantee that the information collected about you will always remain private when using our Services. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk.

Security
We seek to use reasonable physical, technical, and administrative safeguards to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account with us has been compromised), then please immediately contact us.

You are responsible for maintaining the confidentiality of your use of our Services and access information and personal information and for restricting access, and you agree to accept responsibility for all activities that occur under access.

YOUR ACCESS AND CHOICES ABOUT YOUR INFORMATION

By logging in or by submitting your necessary information, you agree that it is your responsibility to:

• Authorize, monitor, and control access to and use of your account, if applicable;
• Promptly inform us of any need to deactivate your account, if applicable;
• Safeguard any payment information submitted in accordance with your purchase, if applicable;
• Input your correct demographic information and shipping address; and
• Send your hearing test results unencrypted via email to the email address you provide.

To protect your privacy, before we give you access or let you update your information, we may ask you to verify your identify or provide additional information.

How You May Opt-Out
We are committed to your privacy rights and your privacy considerations. You have a right not to provide us with your personal information, by not submitting your personal information to us. At any time, you may withdraw your consent that you previously gave us and must communicate this to us in writing.

Upon receipt of this communication, we will no longer contact you by phone or email. However, we may still contact you for administrative and/or transactional purposes.

Emails, postal mail: You can stop receiving post or email communications from us by following the unsubscribe or opt-out instructions in the email communication. You may also contact us directly by phone to speak with a representative. We will retain your email address in order to be able to abide by your opt-out choice. We make efforts to promptly process unsubscribe or opt-out requests. You may not opt-out of service-relation communications (e.g., purchase and billing confirmations and reminders, chances/updates to features of the Site or Services, and technical and security notices)

CHILDREN’S PRIVACY

This Site is not directed at or intended for use by children under 13 years old. This Site and Services are neither intended for nor designed to attract minors. We do not knowingly collect or solicit any information from anyone under the age of 13. I we are made aware of such a situation; we will delete such information.

EXTERNAL LINKS

Our Services may contain links to other webapps, or websites maintained by third parties. Please be aware that we exercise no control over linked apps and are not responsible for the privacy practices or the content of such third parties. Each link maintains its own independent privacy and data collection policies and procedures, and you are encouraged the privacy policies of these other websites or apps before providing any personal information to view.

STORAGE OF PERSONAL INFORMATION IN THE UNITED STATES

Our Services are designed for users from, and are controlled and operated by us from, the United States. All of the information that you provide to us will be stored and processed in the United States. While you may access our Site from a location outside of the United States, you agree not to transfer any of your information to us from outside the United States. The laws in the United States may not offer the same degree of privacy protection as the laws in your jurisdiction.

YOUR CALIFORNIA PRIVACY RIGHTS

This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to the “personal information” that is subject to the CCPA. This section applies only to individuals residing in the State of California who are considered “Consumers” under the CCPA and from whom we collect “Personal Information” as described in the CCPA (“Consumers”). This Section sets forth our privacy practices as required by the California Consumer Privacy Act of 2018 (“CCPA”) in those limited circumstances where we are not interacting with you as a NationsBenefits Customer or providing you products or services that are subject to HIPAA.

Information We Collect
We may collect Personal Information from you in a variety of different situations, including, but not limited to on our website, your mobile device, through email, through the mail, and/or over the telephone. “Personal Information” is 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. In the last 12 months, we have collected the following categories of Personal Information:

• Identifiers
• Categories of Personal Information described in subdivision (e) of Section 1798.80 of the California Civil Code
• Characteristics of protected classifications under California or federal law
• Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
• Internet or other electronic network activity information
• Geolocation data
• Professional or employment-related information
• Education information

Personal Information does not include:

• Publicly available information from government records;
• De-identified or aggregated consumer information;
• Information excluded from the CCPA’s scope, like:
  • Protected Health 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; and
  • Other information collected by us as a Covered Entity under HIPAA to the extent we maintain patient information in the same manner as Protected Health Information covered by HIPAA.

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or information you provide to us when you interact with us.
• Indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website or mobile applications, among other things.
• Third parties. For example, we may receive information about you from our affiliates or other third parties we work with to provide you our products and services.

How We Use Personal Information
We may use or disclose the Personal Information we collect from you or about you to do one or more of the following:

• To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to ask us a question or inquire about our products or services, we will use that personal information to respond to your inquiry
• To contact you and to inform you about products, services, promotions, special offers, and/or events that may interest you
• To provide, support, personalize, and develop our website, products, and services.
• To present our Site and Services to you
• To process your requests and prevent transactional fraud
• 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 carry out our obligations and enforce our rights arising from any contracts or transactions between you and us, including billing and collection
• To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business
• For research, analysis, and business development, including to develop and improve our Site, products, and services
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
• For other purposes with your consent.

We may also use your information to contact you about our own and third parties’ goods and services that may interest you. You may opt-out of such communications if you do not want to receive them as outlined above.

How We Share Personal Information
We do not sell your Personal Information to anyone. We may disclose aggregated user information or information that does not identify any individual without restriction. We may disclose Personal Information that you provide as described in this policy:

• To our subsidiaries and affiliates
• 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 in which Personal Information held by us is among the assets transferred
• To fulfill the purpose for which you provide it
• For any other purpose disclosed by us when you provide the information
• With your consent
• To comply with a court order, law or legal process, including in response to a governmental or regulatory request
• To enforce our Terms and Conditions and other agreements.
• If we believe disclosure is necessary or appropriate to protect the rights, property or safety of NationsBenefits, our customers, or others

Sales of Personal Information
In the preceding twelve months, we have not sold personal information.

Your Consumer Rights and Choices
The CCPA provides Consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. If the information you request is Protected Health Information governed by HIPAA, you will be required to submit either a HIPAA Access Form or a HIPAA Authorization Form, which will be provided by emailing [email protected] or by calling 877-391-1553.

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 (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 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
• If we disclosed your Personal Information for a business purpose, a list disclosing the 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 (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.

In accordance with the CCPA, we may deny your deletion request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction or service 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
• 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 877-391-1553 or
• Emailing [email protected]

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.

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

• Provide sufficient information that allows us 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 fully 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 forty-five days of its receipt. If we require more time (up to an additional forty-five days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12month 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.

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

Other California Privacy Rights
California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. We do not disclose your Personal Information to third parties for their direct marketing purposes.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless otherwise 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

CONTACT US

If you have any questions about this Privacy Policy of the Services, please contact us at:

Mail:
NationsBenefits, LLC
1700 North University Drive
Plantation, FL 33322
Attention: Compliance Department

Email: [email protected]

CHANGES TO OUR PRIVACY POLICY

We may make changes to this policy from time to time, in our sole discretion. We will provide you notice of material changes by indicating that the Privacy Policy has been updated on our homepage and will indicate the date we made the updated below. Your continued use of any of the Services after the changes have been made will constitute your acceptance of the changes. Please therefore make sure you read any such notice carefully. If you do not wish to continue using the Services under the new version of the policy, please uninstall the mobile application and cease using the Services.

Updated: July 18, 2023.