FINWELL BENEFITS
PRIVACY POLICY

Last Updated: October 2020

Finwell Benefits respects the privacy of our users and members, and has developed this privacy policy to demonstrate our commitment to protecting your privacy. This privacy policy (“Policy”) describes how Finwell, Inc., d/b/a Finwell Benefits, and its related companies (collectively “Company,” “we,” “us,” or “our”) collect, use, and share your personal information whenever you use our  website www.finwellbenefits.com (the “Site”), or services that we offer (the “Services”).

By accessing or using our Site or Services, you are accepting the practices described in this Policy. If you do not agree with this Policy, delete all cookies from your browser cache after visiting our Site and do not visit or use our Site or Services. Your continued use of our Site or Services signifies your acceptance of this Policy.

 

WHAT WE COLLECT

We get information about you in a range of ways.

Information You Give Us. We may collect information you enter on our Site or in email, text, or other electronic messages between you and our Site. This includes personal information that can identify you, such as your‎ name, email address, and phone number, or any other information we collect that is defined as personal or personally identifiable information under applicable law or by which you may be contacted online or offline (“Personal Information”), and other information that does not identify you, such as age, and gender, or information about your employer. If you enroll in our Services, we may rely on Third-Party cloud-based software platforms (“Third-Party Platforms”) to collect additional information such as your date of birth, financial information such as net worth, assets, income, bank account information and balances, and other information that enables us to provide you the Services. Any information you provide through a designated Third-Party Platform will be stored only on that Third-Party Platform in accordance with that Third-Party Platform’s privacy policy and practices.

Information We Get From Others. We may get information about you from other sources. We may add this to information we get from this Site.

Information Automatically Collected. We automatically log information about you and your computer. For example, when visiting our Site, we may log your computer operating system type, browser type, browser language, IP address, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site.

Cookies. We may log information using cookies, web beacons and other tracking technologies. Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site.  This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.  For more information, see How We Use Cookies and Tracking Technologies below.

Mobile Information.  We may collect additional information from you if you access our Site through a mobile device (e.g., your unique device identifier, device’s operating system, mobile carrier, location or GPS/geo-location).

 

CHILDREN’S ONLINE PRIVACY PROTECTION ACT

Our Site and Services are not directed to children under the age of 13. No one under age 13 may provide any Personal Information to or on the Site.  We do not knowingly collect information from children under 13 years of age or have any reasonable grounds for believing that children under the age of 13 are accessing our Site or using our Services. If we learn that we have inadvertently collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 13, please contact us at membership@finwellbenefits.com.

 

HOW WE USE YOUR PERSONAL INFORMATION

We may use information that we collect about you or that you provide to us, including your Personal Information, collected through our Site or through a designated Third-Party Platform as follows:

  • to present our Site and its contents to you
  • to provide and deliver products and services you request from us
  • to operate, maintain, and improve our sites, products, and services
  • to respond to comments and questions and provide customer service
  • to send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages
  • to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners
  • to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity

We may also use your personal information in any other way we may describe when you provide the information, or for any other purpose with your consent.

 

SHARING OF PERSONAL INFORMATION

We do not sell or rent your Personal Information to any third parties for marketing or other purposes, and only disclose Personal Information to nonaffiliated third parties as permitted by law. For example, we may share or disclose your Personal Information as follows:

  • We may share your Personal Information with your consent. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their privacy policies.
  • We may share your Personal Information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
  • We may share your Personal information for legal, protection, and safety purposes.
    • We may share information to comply with laws.
    • We may share information to respond to lawful requests and legal processes.
    • We may share information to protect the rights and property of Finwell Benefits, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
    • We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
  • We may share your Personal Information with contractors, service providers, or other third parties we use to support our business, including Third-Party Platforms, who need it to do work for us.
  • We may also share aggregated and/or anonymized data with others for their own uses without restriction.

 

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

If you do not want to receive communications from us about promotions, upcoming events, and other news about products and services offered by us and our selected partners, you may unsubscribe by following the link on the email that you receive. If you unsubscribe, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.

You can also opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI's website.

You may send requests about changing contact choices or opt-out of our sharing with others using the Contact Information below.

You can typically remove and reject cookies from our Website with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Website works for you.

 

ACCESSING AND CORRECTING YOUR INFORMATION

Any updates to your Personal Information provided to us through this Site, such as your name, telephone number, or email address, may be provided to us using the Contact Information below.  Updates to all other Personal Information should be provided by logging into your account profile.

You may also send us an email at membership@finwellbenefits.com to request access to, correct or delete any personal information that you have provided to us.  We cannot delete your Personal Information except by also deleting your user account.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, enforce our Terms of Service, or take other actions permitted by law.  Likewise, if your account or membership is terminated or suspended, we may maintain some information to prevent reregistration.

 

HOW WE USE COOKIES AND TRACKING TECHNOLOGIES

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of our Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

A few additional important things you should know about our use of tracking technologies (e.g., cookies, HTML-5 stored technologies):

  • We offer certain features that are available only through the use of tracking technologies.
  • We use both session and persistent tracking technologies.  Tracking technologies (e.g., cookies) can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser).  You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of the Site.  Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
  • With your prior consent as obtained through your use of this Site.
  • We encode and protect the tracking technologies that we set, so that only we can interpret the information stored in them.
  • We may target and track any videos you view on the Site.  You consent to our tracking of your video viewing through the Site or third-party social media for up to one year or as permitted by applicable law or until consent is withdrawn.

The following table sets out details of the individual tracking technologies we use and the purposes for which we use them. We provide the chart below as a courtesy for all users but we are not obligated to maintain or update it. We are not responsible for third-party sites and their privacy practices as it relates to opt-outs from tracking activities. The following third-parties that collect information from you on our Website have given us notice that you may obtain information on their policies and practices, and in some instances opt-out of certain of their activities.

 

 

Party

Service

For More Information

Use of Tracking Technologies

Privacy Choices

Google Analytics.

Google acts as our data processor on our behalf.

Google Analytics for Display Advertisers, Ads Preferences Manager, Google Tag Manager, and Google Analytics Opt-out Browser Add-on

 

 

Information generated to better understand how to improve the Site.

Identifies user when they return to specific websites store.

http://support.google.com/analytics/bin/answer.py?hl=en&topic=2611283&answer=2700409

Yes. 

http://www.google.com/intl/en/privacypolicy.html

SumoMe

Advertising Server

https://sumo.com/about

Yes

https://help.sumo.com/hc/en-us/articles/218958727-Privacy-Policy

 

NOTICE TO CALIFORNIA RESIDENTS

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to membership@finwellbenefits.com.  For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code.  In the body of your request, please provide enough information for us to determine if this applies to you.  You need to attest to the fact that you are a California resident and provide a current California address for our response.  Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

How We Respond to Do Not Track Signals for California Residents

California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings.  We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed.  We continue to review new technologies and may adopt a standard once one is created.

 

PROTECTION OF INFORMATION; USE OF THIRD-PARTY PLATFORMS

We take reasonable steps to protect all Personal Information we collect directly on our Site or in email, text, or other electronic messages between you and our Site. We maintain strict administrative, technical, and physical procedures to protect information stored in our servers. Access to information is limited (through user/password credentials and software systems) to those employees who require it to perform their job functions. However, no system can be 100% secure. Therefore, although we take these steps to secure your information, we do not promise, and you should not expect, that your Personal Information, searches, or other communications will always remain secure. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on this Site or on any Third-Party Platform. Where we have given you (or where you have chosen) a password for access to certain parts of our Site or a Third-Party Platform, you are responsible for keeping this password confidential.

If you enroll in our Services, we provide you with a link to a Third-Party Platform to collect and store information you provide, via a designated portal and/or built-in document transfer/storage function, in each case maintained by the Third-Party Platform. All information collected through the Third-Party Platforms is stored solely on the Third-Party Platform. Our access to information stored on these Third-Party Platforms is limited (through user/password credentials and software systems) to those employees who require it to perform their job functions.

These Third-Party Platforms do not operate under this Policy and may independently solicit and collect information from you. While we believe that the Third-Party Platforms we use to collect, store and access your information take similar steps to protect any Personal Information collected through these Third-Party Platforms, we do not have any control over the data security practices of these Third-Party Platforms. As such, we cannot guarantee the security of your Personal Information transmitted to these Third-Party Platforms. We recommend that you consult the privacy policies of all Third-Party Platforms you visit.

 

CONTACT INFORMATION.

We welcome your comments or questions about this privacy policy. You can submit any comments or questions, request to change contact choices, opt-out of our sharing with others, or update Personal Information provided to us through his Site by emailing us at membership@finwellbenefits.com.

You may also contact us at our address:

Finwell Benefits
16030 Ventura Blvd #240
Encino, California 91436

For all other changes or updates to Personal Information, please log into your account profile.

 

CHANGES TO THIS PRIVACY POLICY.

We may change this Policy. It is our policy to post any changes we make on this page. The date the Policy was last revised is identified at the top of the page.  Your continued use of this Website after we make changes is deemed to be acceptance of those changes. You are responsible for periodically visiting our Site and this Policy to check for any changes.