LTCi Concierge PRIVACY POLICY

Last Updated: April 13th, 2018

LTCi Concierge, LLC and its affiliates (“LTCi Concierge,” “us”, or “we”) value your privacy, and want you to know what information we collect and what we do with it. We commit to treat your personal information with care and respect.

This policy applies to any information we collect from you via our online long term care insurance consulting services, however accessed (collectively, the “Service”) and our online websites and applications, including but not limited to www.ltciconcierge.com, (the “Site”), and any contests or promotions we host together with any data we gather via social media that we manage in support of the Site and Service, (collectively, the “Properties.”) In addition to this Privacy Policy, you should review our Terms of Use.

CHANGES TO THIS POLICY

We may make changes to this policy at any time, in which case we will notify you by posting an updated policy within applicable areas of our Properties and changing the “Last Updated” date at the top. We may also notify you via other channels, such as through the Service or by email. In all cases, the new terms will take effect at the posted “Last Updated” date. You should review this policy often, to make sure you have not missed any updates.

THE TYPES OF INFORMATION WE COLLECT

We have several areas where you can submit information to us, and we also have features that automatically collect information from users of our Properties. We may collect Personally Identifiable Information (“PII”) and Non-Personally Identifiable Information (“Non-PII”) from you. This policy is primarily concerned with our collection of PII. PII is any information that can be used to identify or locate a particular person or entity. This includes, but is not limited to: name, address, telephone number, or email address.

Non-PII is information that cannot, by itself, be used to identify a particular person or entity and also includes any usage information relating to the Properties that we have gathered, as long as any PII has been removed from it. This policy does not restrict our use of Non-PII and you agree that we may use or transfer any Non-PII that we collect from you or based on your usage, at our discretion. However, if we if we combine Non-PII we collect about you with PII that we collect about you, we will treat the combined information as PII.

Information You Provide to Us

We have certain areas where you directly provide information to us. These include Service registration and usage, such as consultation, account management and customer care. It also includes any interactive or community components we may offer (like comment areas) via the Properties, including any surveys, sweepstakes or promotions that we run. Finally, unless we tell you otherwise at the time, any other direct interaction with us would be covered. More specifically:

  • Browsing. If you are simply browsing our Properties, you are generally not required to register with us or provide any other personal data. However, we may track your usage via any data that we automatically gather (see below) for our own internal use or to share with third parties subject to this policy.
  • Service Registration and Use. To use the Service interactively, we generally require you to register with us, using your email address. We may also ask you to share your zip code, so we can determine what parts of the Service may be available to you and/or other information to help further tailor the Service for you. We will treat this as PII. In addition to any more general uses of PII that we may collect under this Privacy Policy, we may use you your email to contact you for Service-related purposes, such as Service notifications, order confirmations, delivery updates and customer care.
  • Transactions. To complete purchase transactions via the Service, you will need to provide additional billing and order related information. Billing information may include but not necessarily be limited to a billing card type, card #, expiration date and security code (“Billing Information”); however, we do not currently collect or store full payment card numbers and all transactions are processed on our behalf by our third party payment processor. Other transactional information will relate to your order and service, including delivery information, order specifics and follow-up. To the extent that we store this information in a way that is personally connected to you, we will treat it as PII and use it to manage and improve the Service. We may anonymize he information and use it as Non-PII.
  • Community. Our Properties may include social and community features that let you post information publicly or to other users. All information you send or post via community features becomes public information and not treated as PII, even if you included any personal information within it. For internal purposes, we may retain logs of all comments or messages but we will not be obligated to do so.
  • Mailing Lists. For additional information and offers, we may give you the option of joining our mailing lists and/or those of other promotional (see “With Whom We Share Your Information” below). If we do, you will be able to change your options in the account area of the Service. Each promotional e-mail from us will come with instructions for how to unsubscribe from the mailing list. Please note that we may send emails via third-party service providers that act on our behalf.
  • Contests and Sweepstakes. We may conduct contests or sweepstakes, as part of which we may request contact information from you when you enter. We will use the information you provide to conduct the contests or sweepstakes and for other purposes to which you consent. If we offer contests or sweepstakes with our partners, we may notify you that we will share the information we obtain from you with them and will give you the opportunity to choose whether or not to participate.
  • Surveys. We may occasionally ask you to participate in voluntary surveys. These surveys are intended to improve your service experience and any information you provide we may associate with your member name for future use. Any personally identifying information collected will be used only by us unless we specify otherwise. However, we may share aggregate survey result information with others.
  • Communications with Us. Our Service has features that allow you to submit information to us (such as when contacting us with a question or problem related to the Service). We may retain your emails and other information you submit to us for our internal purposes and to help us to serve you better.

INFORMATION WE AUTOMATICALLY COLLECT

As you use our Properties, we may use a variety of technologies that automatically or passively collect information, including but not limited to tracking your movement through the Properties, your Internet connection and device type, operating system, pages served to you, the time of use, how many users are online, what elements of the Properties you use, your purchases, your preceding page views and other data related to your session. We may also track and collect information on your and other Users’ IP address. Relative to your phone and other mobile devices, our apps may collect additional information that includes but is not limited to your unique device identifiers (such as advertising identifiers), geo-location information, mobile browser or operating system, interactions with our apps and other technologies.

We will use this data (i) on an aggregated basis with that of other users for general business purposes, (ii) to enhance the Properties, and (iii) in combination with data we collect relative to your use of the Properties, in order to help us analyze and personalize your own experience and for other service-related purposes.

This automatically collected information is normally not stored in a way that would identify it to you or to your PII and so it is Non-PII. However, if we do connect any of this automatically collected information specifically with your account and/or other PII, then we will treat it as your PII. In that case, we will use it for more limited purposes, such as to enhance your own Service experience, to service your account and/or for our own internal analysis.

The data collection tools that we use to automatically or passively gather information from you include:

  • Server Logs. Our servers automatically record certain log file information.
  • Cookies. Cookies are small pieces of data that are stored on your device.
  • Tags/Pixels/Beacons. These are generally used synonymously, describing small blocks of code on webpages that do things like allow another server to measure viewing of a webpage.
  • JavaScript. We or third parties may send instructions to your device using JavaScript or other computer languages to store or gather the sorts of information described above and other details about your interactions with the Sites.
  • Mobile. Our apps may directly or via your device’s functionality collect some of the information referenced. With your consent, we may also collect information about the location of your device and access and collect information from certain native applications on your device (such as your device’s camera) to facilitate your use of certain features of the Sites.
  • Other. We may use technology available on your device, technology similar to cookies and pixels and technology that is later developed, all for similar purposes.

We will use these technologies to store your registration data and preferences so that we can:

  • identify you, personalize and otherwise enhance your experience with our Properties;
  • to manage your purchases, deliveries and account service;
  • help us analyze the Properties and your experience;
  • help us facilitate any promotions or surveys that we facilitate;
  • help us to make our Properties more secure, protect against fraud, unauthorized transactions and other liabilities, and manage risk exposure;
  • help us to make our Properties run better;
  • Display relevant advertising to you (if we choose to do so) on our Sites and across the Internet; and
  • Comply with and enforce applicable legal requirements, industry standards and our policies and terms, such as our Terms of Use.

We may also use these technologies within the emails that we send to our members or advertisements for our service or sites.

Analytics

We sometimes utilize third party service providers to help us track the activity and user flows within our service or sites. These third parties may use temporary cookies and/or web beaconing technology to facilitate such tracking. Such tracking would track an individual user’s movements but the data would not be tracked in a personally identifiable way. Such data would be stored and analyzed on an aggregated basis for purposes of internal analysis by LTCi Concierge to improve the Properties.

Advertising

Data about your activities on our Properties may be collected for use in providing advertising tailored to your individual interests on other websites and online services. You may choose whether to have your information collected for that purpose. We may participate in advertising services administered by third parties. The ad services may track your online activities over time by collecting information through automated means, including through the use of the automated technologies described above, and they may use this information to show you advertisements for LTCi Concierge or others that are tailored to your individual interests or characteristics and/or based on prior visits to our Properties. We and third-party vendors may use first-party cookies and third-party cookies together, as well as other automated means and the data collected through such means, (1) to inform, optimize, and serve ads (including ads based on past visits to our Sites) and (2) to report on our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services (including how they are related to visits to our Properties). To learn more about interest-based advertising generally and your opt-out options, see: http://www.aboutads.info/choices/. You also may use your device settings to indicate certain preferences regarding the serving of advertisements based on your mobile device’s advertising identifier. For the most effective method of doing so on your particular device and operating system, you should consult your device settings and instructions.

INFORMATION WE RECEIVE FROM THIRD PARTIES.

There are instances where we may receive information from third parties.

  • You may also separately provide registration and purchasing information to websites, apps, product or service providers through which we provide access to registration for our Service. Depending on the particular promotion, when you register for the Service through such a promotional partner of ours, that partner may provide us with a user/member name that you already use with that partner’s products or services or that you or it have otherwise pre-selected as part of the promotion. For example, when you use an external social network (like your Facebook account) to log in to the Service or to interact with us in another way, we may collect your name and other details from your social network profile and account (please see your social network’s privacy policy or support documents for more information about their sharing of information with connected accounts).
  • As you are using our Properties, you may click through certain links or promotions that will enable you to purchase products or use services provided by promotional partners or other sites or commerce providers. Some of those entities may share with us certain information that you provide to them. By clicking through to those links or promotions, you agree to allow us to receive and use any information, except for credit card information (account number, expiration date) that you may provide to such entities, under the same terms as if you provided it to us directly.
  • You may also separately share your information with other sites or entities, such as those that create professional marketing lists, to receive special offers and promotions from its partners. These entities or sites may agree to share your information with us. Whether or not any third party actually shares your information and to what extent they do share with us will depend on their agreement with us and their individual privacy policy. LTCi Concierge is not responsible and will assume no liability if another site or commerce provider collects, uses or shares, any information about you in violation of its own privacy policy, or applicable law.
  • We may purchase marketing data from third parties and add it to our existing user database, to better target our advertising and to provide pertinent offers in which we think you would be interested. To enrich our profiles of individual customers, we may tie this information to the personally identifiable information they have provided to us.

WITH WHOM WE SHARE YOUR INFORMATION

We will never share, sell rent or trade your registration and personal information with any marketing or promotional partners without your consent.

The following are the ONLY exceptions, with respect to whom we may share your personal information with:

  • any of our parent, subsidiary, affiliated or successor companies;
  • Persons or entities providing services to us or acting as our agents as part of our provision of the Service or other Properties (such as hosting, credit card processing, customer/support services, email providers or others) to you;
  • entities into which our company is merged, or to which our assets, site or operations have been transferred, will be able to use your personal information under the terms of this privacy policy. We will notify you if any of these events occur by updating this Privacy Policy and, if practically possible, via other means.
  • any entity with whom we believe we are required to do so by law or as part of a legal or regulatory process or request of regulatory or law enforcement agency; and
  • in cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who is violating our terms of use or otherwise may be causing injury to or interference with (either intentionally or unintentionally) our rights or property.

You should also be aware that courts of equity, such as U.S. Bankruptcy Courts, may have the authority under certain circumstances to permit your information to be shared or transferred to third parties without your permission.

SECURITY

LTCi Concierge endeavors to protect the security of your personal information and your choices for its intended use. We try to follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of online transmission, or method of electronic storage, is 100% secure, however. We store your personal information on a secure server, and use procedures designed to protect the information we collect from loss, misuse, unauthorized access or disclosure, alteration or destruction. However, we cannot and do not guarantee, in any way, that your information will be fully secure and/or safe from accidental loss or malicious action by any party.

ACCESS/CHOICE

You can access and modify your registration information at any time in the “My Account” area within the Service. If you choose to have your information deleted, please contact us as instructed herein. To the extent that certain exceptional circumstances apply (including but not limited to, active legal proceedings, security matters…etc., where your information is needed), we may not be able to delete your information immediately but in all cases, we will reply to you within 60 days. All promotional e-mails from us will come with instructions for unsubscribing from the email mailing list. Finally, your device and/or browser may offer functionality that lets you block, limit or otherwise control the use of cookies, geo-location, access to native apps and similar technologies, including ours. Please read your own device or browser instructions if you are interested in using these tools. However, please also note that if you do block or limit any of the technology or data requests that we employ, it may limit or even entirely block your ability to use all or part of the Service.

THIRD PARTY WIDGETS AND LINKS

We may display links to other sites and we may provide tools and widgets from other sites and services, including but not limited to tools that allow you to share, distribute or otherwise publish or make available your favorite meals or other highlights from the Service. We are not responsible for those other sites and services, their privacy policies or how they treat information about their users. We advise you to check their privacy policies to find out how they are treating your personal information. If you click through any third party links or use any third party tools or widgets you are totally responsible for your data and you agree (i) LTCi Concierge has no responsibility for what those sites or services do with any data of yours and (ii) that you will indemnify LTCi Concierge and its affiliates for any claims that may arise or that you may have in relation to what those sites or services do with your data.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident and you decide that you do not want us to share your personal information with third party companies for their marketing and promotional purposes, please send an email to info@ltciconcierge.com. In this e-mail, state that you do not want LTCi Concierge to share your personal information with third parties for their marketing purposes. Your request will be processed within thirty (30) days of the date of which we receive it.

INTERNATIONAL CONSIDERATIONS

Consent to Processing and Transfer of Information.

The Services are operated via services located in the United States and are not intended for use abroad. However, if you do use them elsewhere, if you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be transferred to and processed in the United States. By using the Services, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to, those in the country where you reside and/or are a citizen.

CONTACT US:

If you have any questions about this privacy policy or otherwise about our privacy practices, you can email info@ltciconcierge.com or write to: LTCi Concierge, 6 Office Park Circle, Suite 116, Birmingham, Alabama, 35223, Attn: Privacy Officer.