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Inshura Privacy Policy

Effective Date: May 1, 2022

As used in this Privacy Notice, the terms “Inshura,” “we,” and “us” refer to Inshura, and its parents and affiliates, members, managers, officers, directors, employees, contractors, and agents. If you accept this Privacy Notice as an employee or representative of a company or other legal entity, the terms “you” and “your” will refer to both you, personally, and any entity you represent.

This Privacy Notice describes how we collect, use, protect and share information about you we obtain when you access and use our Website (defined below), including when you register for an account or request a quote. This Privacy Notice also applies to information we obtain when you communicate or interact with us outside of the Website, including by email, telephone, and otherwise.

Your use of our Website is also governed by our Inshura Portal Grant of Limited License and Terms of Use (the “Terms of Use”), any additional terms provided to you in connection with certain features, functionality, tools, content, and promotions available on or through the Website (“Supplemental Terms”), and any policies and rules referenced or, posted on the Website, or otherwise communicated to our Users (the “Website Policies”). If a provision of the Terms of Use, Supplemental Terms, or Website Policies conflicts with this Privacy Notice, such provision shall control.

Please read this Privacy Notice carefully before using our Website or communicating with us. Changes to this Privacy Notice are discussed at the end of this document.

For this Privacy Notice:

  • “Users” means any individuals that access or use the website, including applicants for health insurance, insurance agents, and other registered users. References to “access” and/or “use” of the Website (and any variations thereof) include the acts of accessing or browsing the Website and accessing or using the services, information, content, features, functionality, tools, and promotions available on or through the Website.
  • “Website” refers to any website owned, operated, or powered by Inshura (including the Website at https://www.inshura.com). References to the “Website” include any services, information, content, features, functionality, tools, and promotions available on or through each Website.

BY ACCESSING OR USING OUR WEBSITE OR COMMUNICATING WITH US OUTSIDE OF THE WEBSITE, YOU ARE ACCEPTING AND CONSENTING TO THE PRACTICES DESCRIBED IN THIS PRIVACY NOTICE, WHICH MAY BE UPDATED AND AMENDED FROM TIME TO TIME. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY NOTICE, YOU MUST NOT ACCESS OR USE OUR WEBSITE OR OTHERWISE COMMUNICATE WITH US.

INFORMATION WE COLLECT

Information You Provide to Us
We collect information you provide directly to us, including when you register for an account, solicit a health insurance quote, prepare or submit a health insurance application directly or on behalf of another individual, use the Website, update your contact information, respond to a communication from us, or contact us with questions.

We may also collect information about you when you opt-in to receive text messages from us (such as when you sign up for health insurance). You may opt-in to receive such updates and offers by providing your mobile telephone number through the Website.

We may also collect information about you if a company or organization authorizes you to manage its account or use our Website on its behalf.

Personally Identifiable Information
Some of the information we may collect through your use of our Website or communications with us may identify you (“Personally Identifiable Information”). The types of Personally Identifiable Information you may submit in connection with the Website include, but are not limited to:

  • contact information (such as name, address, email address, and telephone number);
  • date of birth;
  • gender;
  • account passwords for the Website;
  • payment card information and other billing information (such as card image, card number, cardholder name, expiration date, and card verification code) associated with your account;
  • social security number;
  • health or medical history;
  • dependent name; and
  • geographic location.

Information Generated from the Website
We also may collect certain technical information when you access, browse and use our Website, including information we automatically receive and record from your browser or mobile platform on our server logs. This technical information helps us operate and provide our Website to you and includes standard information about visits and system capabilities, such as:

  • information about the device(s) you use to access our Website, including MAC address, IP address, browser type and version, your location, time zone setting, browser plug-in types and versions, operating system and platform, device type, device and application identifiers, operating information, mobile carrier, and cookies;
  • information about your visits to the Website, including the full URL clickstream to, through, and from the Website, including dates and times;
  • information we need and use to facilitate your use of our Websites (including to provide access to third-party Websites and services), such as URL requests, destination IP addresses, or device configuration details;
  • pages you view, searches you run, length of time browsing search results, specific search results you select to view, length of visits to other pages, page interaction information (such as scrolling, clicks, and mouse-overs), your engagement with certain variable/dynamic elements of a page and methods used to browse away from the page;
  • page response times and download errors; and
  • information generated using cookies and beacons. See below for more details regarding our use of cookies and beacons and your choices regarding such tracking technologies.

Technical information from your use of the Website is treated as “Non-Personally Identifiable Information” unless it is combined with Personally Identifiable Information or otherwise required by applicable law.

Information from Other Sources
We may receive certain information about you from the organizations or entities on behalf of which we provide the Website to you and/or on behalf of which you access or use the Website. We may also supplement the technical information we collect from your use of the Website with information collected by third parties. Such third parties may include service providers, such as Google Inc., advertising partners, and ad networks that help us understand our Users and provide better service to our Users.

Occasionally, we may compare or combine Personally Identifiable Information from third-party sources to/with other information we have collected. For example, we may obtain contact information from other sources to contact you if we think you or the company you represent would be interested in our Website.

HOW INFORMATION MAY BE USED

Personally Identifiable Information
We may use the Personally Identifiable Information we collect to:

  • create and manage your account;
  • provide the Website to you;
  • operate our Website, including, without limitation, providing quotes, and submitting and monitoring health insurance applications, access management, payment processing, Website administration, internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • send you information that enables you to use our Website;
  • contact you about activity on your account;
  • provide you access to and updates regarding health insurance and other related offers via text message;
  • respond to your requests, feedback, or inquiries;
  • notify you about updates, information, or alerts regarding our Website;
  • process payments;
  • protect and enforce our rights and the rights of other Users against unlawful activity, including identify theft and fraud, and other violations of our Terms of Use;
  • protect and enforce our rights arising under any agreements entered into between you and us, including billing and collection;
  • protect the integrity and maintain the security of our Website, including secured areas of the Website;
  • operate, evaluate and improve our business, including conducting surveys and market research, developing new products, services, and promotions (such as special events, programs, offers, contests), analyzing and enhancing existing products, services, and promotions, managing our communications; performing accounting, auditing, and other internal functions;
  • provide you with information and advertisements about products, services, and promotions, from us or third parties that may interest you; and
  • administer your participation in such products, services, and promotions.

Additionally, we may use your information as described in any notice provided when you provide the information and for any other purpose for which you may provide consent.

Non-Personally Identifiable Information
Besides the uses described above, we may also use Non-Personally Identifiable Information to:

  • deliver content (including advertising) tailored to your interests and the manner in which you use our Website;
  • present content in a manner optimized for your device; and
  • measure and analyze the effectiveness we serve you.

We may also combine technical information, or Non-Personally Identifiable Information, about your use of our Website with information we obtain from other Users to use in an aggregate or anonymous manner for similar purposes.

HOW INFORMATION MAY BE SHARED

Personally Identifiable Information
We will not sell or share your Personally Identifiable Information with third parties for the third party’s own direct marketing purposes without your express consent. We may share your Personally Identifiable Information with:

  • the Centers for Medicare and Medicaid Services (“CMS”) to obtain an eligibility determination for you and to enroll you in health insurance plans offered on the federal healthcare exchange, under applicable laws and regulations and Inshura’s contractual obligations;
  • If applicable, the organizations or entities on behalf of which we are providing the Website to you and/or on behalf of which you access or use the Website, such as your employer, and other companies associated with those organizations or entities to enable their systems to operate with the Website;
  • third party insurance companies to which you apply for health insurance on or through the Website;
  • your employer(s), affinity group, and/or benefits administrators or consultants, if you are referred to the Website by such respective parties;
  • if you are a licensed insurance agent using Inshura’s agent platform, the designated administrator of your account, if you have an individual subaccount, regarding the Services by individual subaccounts;
  • your licensed insurance agent, if applicable;
  • our service providers to the extent reasonably necessary to enable us to operate our business and provide our Website to you, as described in this Privacy Notice (e.g., to an email service provider to enable us to email you);
  • a buyer or other successor in interest to Inshura in the event of a merger, divestiture, restructuring, reorganization, dissolution, liquidation, or other sale of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personally Identifiable Information held by us about our users is among the assets transferred;
  • other third parties with your express consent for any purpose disclosed by us when you provide the information; and
  • you, upon your written request.

    We may also share Personally Identifiable Information with law enforcement agencies, government officials, or other third parties for the purpose of:

    • complying with any court order, law, or legal process, including to respond to any government or regulatory request;
    • preventing fraud protection and credit risk reduction;
    • investigating potential unauthorized access or misuse of our Website or other breach of our Terms of Use, Supplemental Terms, Website Policies, or other agreements;
    • protecting the assets or property, and enforcing the rights of Inshura, including for billing and collection purposes; and
    • protecting the rights, property, or safety of our Users or others.

    Non-Personally Identifiable Information
    In addition, we may share Non-Personally Identifiable Information, including aggregated or anonymized data:

    • with our partners about how our Users collectively use our Website, so our partners may also understand how often people use their services and our Website;
    • with analytics companies, search engines, or other service providers that help us improve our Website;
    • to report to our affiliates, licensors and service providers, advertising partners, and ad networks about various aspects of the Website;
    • with other Users or prospective Users of the Website; and
    • to advertisers and advertising networks to select and serve relevant advertisements.

    Notice to California Residents / Your California Privacy Rights
    The California Consumer Privacy Act (“CCPA”) provides California residents with certain rights regarding their personal information collected by businesses. If you are a California resident, please review Inshura’s California Privacy Notice.

    COOKIES AND BEACONS
    We may use cookies, beacons, and similar automatic data collection technologies, now or to support the functionality of our Website. These technologies help us provide a better experience when you visit our Website and allows us to improve our Website. The technologies we may use for this automatic data collection may include:

    • Browser Cookies. A browser cookie is a small file placed on your computer’s hard drive. That cookie then communicates with our servers or those of other companies we authorize to collect data for us and allows recognition of your personal computer. We associate cookies with Personally Identifiable Information only if you use the logged-in areas of the Website, order a Service, use the personalization services available as part of the Website, or ask us to contact you with additional marketing information. We do not otherwise collect Personally Identifiable Information from browser cookies and do not associate browser cookies with your Personally Identifiable Information. You may use the tools available on your computer or other devices to set your browser to refuse or disable all or some browser cookies or alert you when cookies are being set. However, if you refuse or disable all browser cookies, you may not access certain parts or use certain features or functionality of our Website. Unless you have adjusted your browser settings so it refuses all cookies, we may use cookies when you direct your browser to our Website.
    • Beacons. Our Website and emails may contain small electronic files known as beacons (also called web beacons, clear GIFs, pixel tags, and single-pixel GIFs) that permit us to, for example, count Users who have visited those pages or opened an email and for other Website-related statistics. Beacons in email marketing campaigns allow us to track your responses and your interests in our content, offerings, and web pages. You may use the tools in your device to disable these technologies.
    • Other Tracking Technologies. Our Website may also use other tracking technologies such as embedded scripts, location-identifying technologies, and other similar technologies. These technologies execute on our Website or in your browser and allow us to recognize you when you return to the Website and understand how our users use and interact with our Website.

    Our service providers, advertising partners, and ad networks may use cookies, beacons, and similar tracking technologies to collect and share Non-Personally Identifiable Information about your activities on our Website and on other Websites, including to provide you targeted advertising based upon your interests. In addition, third parties unaffiliated with us may also collect information about you, including tracking your browsing history when you use our Website. We do not have control over these third-party collection practices. If you wish to minimize these third-party collections, and you can adjust the settings of your browsers or install plug-ins and add-ins.

    Ability to Limit
    You may request us to limit the collection, creation, disclosure, access, maintenance, storage, and use of your PII solely to obtain our assistance in applying for health insurance and obtaining an eligibility determination and for performing related functions authorized and specified in our agreements with the Centers for Medicare and Medicaid Services (“CMS”). To request this limitation, email to Support@Inshura.com.

    Email Communications
    You may have the opportunity to receive certain communications from us related to our Website. If you provide us with your email address to receive communications, you can opt-out of marketing emails at any time by following the instructions at the bottom of our emails and adjusting your email preferences. Certain emails may be necessary for operating our Website. You will continue to receive these emails, if appropriate, even if you unsubscribe from our optional communications.

    Cookies/ Beacons
    If you wish to minimize information collected by cookie or beacon, you can adjust the settings of your browsers to notify you when you receive a cookie, which lets you choose whether to accept it. You can also set your browser to automatically reject any cookies. You may also install plug-ins and add-ins that serve similar functions. However, please be aware that some features and services on our Website may not work properly if we cannot recognize and associate you with your account. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.

    Network Advertising Initiative
    Certain Websites you visit may provide options regarding advertisements you receive. If you wish to minimize the amount of targeted advertising you receive, you can opt-out of certain network advertising programs through the Network Advertising Initiative (NAI) Opt-Out Page. Even if you remove your information (opt-out), you will still see advertisements while you’re browsing online. However, the advertisements you see may be less relevant to you. For more information or to opt-out of certain online behavioral advertising, please visit https://www.aboutads.info.

    Additionally, many advertising network programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the targeted advertisements you may receive. The NAI Opt–out Page provides a tool that identifies its member companies with cookies on your browser and links to those companies.

    Do Not Track
    Some browsers support a “Do Not Track” (or DNT) feature, a privacy preference that Users can set in certain web browsers, which is intended to be a signal to Websites and services you do not wish to be tracked across different Websites or online services you visit. Our Website does not currently recognize or respond to DNT signals, so DNT settings do not change the way the Website operates.

    We cannot control how third-party Websites or online services you visit through our Website respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.

    Text Alerts
    You may have the opportunity to receive certain information, updates, and/or offers from us via text communications. If you provide us with your mobile number to receive such communications, you can opt-out of receiving text messages at any time by contacting us at Support@Inshura.com.

    Updating Information
    The accuracy of the information we have about you is important. To review, correct, or delete your Personally Identifiable Information, please update your account profile on the Website. or contact us as stated in the “Contact Us” section of this Privacy Notice.

    We will retain your information for as long as your account is active or as needed to provide the Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

    SECURING YOUR INFORMATION
    The security of your information is important to Inshura, and we have established administrative, technical, and physical safeguards designed to protect your Personally Identifiable Information against unauthorized alteration, access, loss, theft, use, or disclosure. Unfortunately, no system can guarantee complete security of your information. Inshura cannot ensure or warrant that your information, including your Personally Identifiable Information, is secure from unauthorized third parties. Thus, your use of the Website and communication with us about them is at your own risk.

    You protect your password(s), and for the security of information, you transmit to us over the internet.

    CHILDREN
    Our Website is directed to and is intended to be used only by persons 18 years of age or older. We do not knowingly collect information from children under 18. If you are under 18, you may not register for an account or otherwise submit any Personally Identifiable Information to us, including your name, address, or email address. By registering for an account or submitting any Personally Identifiable Information to us, you represent and warrant you are 18 years of age or older.

    If we discover that we have received any Personally Identifiable Information directly from a child under the age of 18, we will suspend the associated account and remove that information from our database soon. By registering for an account or submitting any Personally Identifiable Information to us, you represent and warrant that you are 18 years of age or older. To avoid doubt, this restriction does not apply to information collected from a parent or legal guardian who provides information regarding a dependent child under the age of 18 with a health insurance application or other related purpose.

    LINKS TO THIRD-PARTY WEBSITES
    Our Website may contain links to third-party Websites and services, including those of third-party insurance providers and advertisers. These links are provided, and information and the Websites and services may operate independently from us and have their own privacy policies or notices, which we strongly suggest you review. This Privacy Notice applies to Inshura and our Website only. We accept no responsibility or liability for the policies or practices of any third parties. If you access any Websites or services linked from our Website, please check the applicable policies before you use or submit any personal data to such Website or service.

    INTERNATIONAL JURISDICTIONS
    The Website is hosted in the United States of America and is subject to U.S. state and federal law. The Website is not intended to subject Inshura to the privacy laws or jurisdiction of any state, country, or territory other than that of the United States, including the European Union. Inshura does not represent that the Site is appropriate for any particular jurisdiction. Those who access the Site do so at their own initiative and comply with all local laws, rules, and regulations. If you are accessing our Website from other jurisdictions, you are transferring your personal information to us in the United States, and by using our Website, you consent to that transfer and use of your personal information under this Privacy Notice. You also agree to abide by the applicable laws of applicable states and U.S. federal law about your use of the Website and your agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use, and disclosure, different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction. If your use of the Website would be unlawful in your jurisdiction, you may not use the Website.

    CHANGES TO OUR PRIVACY NOTICE
    Inshura may change this Privacy Notice occasionally. Any changes to this Privacy Notice will be reflected on this page, and the Effective Date will be stated at the top of this Privacy Notice. Unless stated otherwise, our current Privacy Notice applies to all information we have about you and your account. Users should regularly check this page for any changes to this Privacy Notice. Inshura will always post new versions of the Privacy Notice on the Website. If an amendment materially alters your rights or obligations, we may notify you of the amendment, such as by posting a notification to the home page of the Website or sending a notification to you at the address we have on file for you, if any.

    Your continued use of the Website or communication with us after the updated Privacy Notice has been posted (or any other indication of your consent) will constitute your acceptance of the updated Privacy Notice.

    We may condition your continued access to our Website on your consent to changes to this Privacy Notice.

    CONTACT US
    If you have questions relating to this Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by email at Support@Inshura.com, call us at 888-306-2590, or write to us at:

    Inshura
    2400 Louisiana Blvd. NE, Building 3
    Albuquerque, NM  87110