Effective Date: 09/28/2023

Purpose and Scope

This Statement describes how American Benefits Consulting, an Alliant Insurance Services Inc. Company ("ABC"), and its affiliate American Benefits & Compensation Systems Inc., with a website located at http://www.abcsys.com and its corporate sites and applications that it maintains and hosts on behalf of its Clients, uses and discloses certain personally identifiable information that it receives on its application platforms within the context of providing Benefits Administration services to its clients. The use of information collected through our service offerings shall be limited to the purpose of providing the benefits administration services for which our clients have engaged us. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

ABC is dedicated to keeping any and all personally identifiable information private and secure. As an industry leading Insurance Benefits Consulting practice, we develop and host a variety of applications for our clients and their employees to facilitate and support the Benefit Administration services that we provide to said clients. This Privacy Policy describes how we collect and maintain personally identifiable information about users of our applications, the types of information we collect, the circumstances under which we may disclose that information, and our practices with regards to safeguarding the information we collect and maintain.

International Users

ABC’s applications and Web sites are hosted in the United States. If your country of residence is outside of the United States, for example the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of our applications and Web site, which are governed by U.S. law and this Privacy Policy, you are transferring your personally identifiable information to the United States and you consent to such transfer.

Data Security & Integrity

ABC has hosting centers that store and process Personal Data in various locations in the United States and follows the latest information security best practices to protect all Personal Data that passes through its systems and processing framework. ABC also takes significant precautions to keep Personal Data reliable for its intended use.

In order to safeguard your personal data such as your log in credentials, Employee ID, address etc we use custom software and other production infrastructure technologies that are designed to not only prevent unauthorized users from accessing our systems, but also to alert ABC personnel if any unauthorized access or suspicious activity is detected. These practices range from the implementation of encryption software such as HTTPS/SSL for all web traffic, password protected Web sites, specific policies around password strength, implementation of network firewalls to protect data residing within ABC’s network infrastructure, the implementation of sophisticated infrastructure technologies to monitor the production infrastructure that houses personal data, and well documented Information Security Policies and Procedures regarding the use and privacy of client and personal data as a whole.

In general, ABC makes best efforts and leverages industry best practices to safeguard and protect all personal, confidential and sensitive data that it manages on behalf of its clients and their respective employees. No method of transmission over the Internet, or method of electronic storage, is 100% secure however, therefore we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at privacy@abcsys.com.

Types of Data We Collect

ABC collects information under the direction of its clients, and it works with its clients to help them provide notice to their constituents concerning the purpose for which personally identifiable information is collected. ABC may use this personal data for a variety of business purposes, including facilitating the delivery or provision of insurance products or services that are offered to the employees of our clients as part of our benefit programs, to establish or maintain client and business relationships, or to conduct other activities in support of providing benefits administration services to its clients and their employees.

Most of the information we collect comes directly from information supplied on applications or forms submitted by or on behalf of our plan participants, or directly from client Human Resource or payroll systems. We also may receive Personal Data from Insurance Carriers and other vendors with whom we partner in order to better serve our clients and plan participants, as well as to provide for a more seamless and customer friendly experience to our end users.

In general, ABC may obtain Personal Data from several different sources, including generic information from website visitors and individual benefit plan participants, policy and premium information from Insurance Carriers, and payment and other related product information from its partners that provide other services as part of ABC's benefits service offering (for example Legal or Pet Insurance providers). We also obtain various types of Personal Data about plan participants from our clients directly.

Such data may include general contact information, first and last name, home address, phone and fax numbers, email address, and other personally identifiable information. It may also contain information about products and services ordered or provided, financial and payment information with regards to payroll deduction services that we provide, as well as user IDs, passwords, and other transaction or user registration related data.

The types and categories of information we collect on behalf of our clients about end users that use or products and services include:

• information we receive from end users of our systems on applications for insurance and other forms,
• information about your employment status and hire date from your employer, and
• information about your policy related transactions with us; such as your coverage amount and payment history.

There also may be occasions where specific personal data is requested before an individual can enter certain sections of our applications or Web sites, or for participation in a certain benefits program. In all such cases, we will collect only personally identifiable information that is voluntarily provided by the user and in all cases consider such information strictly confidential.

In no way will your personally identifiable information ever be used, sold, or disclosed without your consent, except as set forth herein.

Data Changes and Opting Out

Our clients, their respective employees, or agents of our clients may contact us if they wish to make any changes to their personal data, or if they would like to access and correct personal data that we maintain about them. Users also have the ability to opt-out of having ABC store personally identifiable information if they desire. In any of these cases, such persons can contact ABC by sending an email to privacy@abcsys.com or by following the instructions at the end of this privacy statement.

Also, to the extent that any of these individuals receives marketing communications from ABC and wishes to unsubscribe or otherwise stop receiving such communications, an individual can contact us at privacy@abcsys.com, and ABC will remove that person from all such communications going forward.

However, please contact your HR Administrator directly to update or remove/delete your personally identifiable information if you see that any basic employee information is incorrect (name, address, email address, employee ID #, etc) or if you do not wish to participate in the Voluntary or other Benefits programs that ABC provides since client Human Resources or payroll systems are in almost all cases the source of such Personal Data for ABC, and personal data maintained by ABC is updated and synchronized from these systems on a regular basis.

We will respond to all such requests for Opting Out or Personal Data changes typically within 5 business days, but in no case more than 30 calendar days from the date of the request.

Our Clients and Services

ABC provides a wide variety of services and solutions to its business clients ("Clients") that facilitate Benefits Planning and Administration services. These services include, but are not limited to:

• employee eligibility processing,
• product enrollment processing,
• automated payroll deduction services, and
• online benefits enrollment, administration and support

Those eligible to participate in the Benefits Programs administered by ABC (“End Users”) normally have some direct or indirect employment relationship to our clients. Often Personal Data about the End Users is obtained from the clients’ Human Resources or payroll systems. In other cases, Personal Data is obtained directly from the End Users; for example, during End Users’ enrollment or registration on our Benefits Portals. Data collected may include personally identifiable information such as Social Security number, Employee ID, name and address. Wherever we obtain access to Personal Data about individuals or End Users, we are acting as a data processor on behalf of our clients, and we therefore conduct such activities strictly in accordance with their instructions and pursuant to our contractual arrangements with them.

If you are an End User with an existing direct relationship with one of our clients, you should refer to the client's (your employer or former employer's) provided information to understand the privacy practices that apply to personal data that they retain about you. Furthermore, if you would like to access and review your personal data, you should contact your employer with any such requests. If you would like to access and review your personal data maintained at ABC, we will cooperate as appropriate with these requests and will respond to such requests typically within 5 business days but in no case more than 30 calendar days. In such cases ABC can be contacted through regular support and account management channels, or reached directly at privacy@abcsys.com.

Other Necessary Disclosures

ABC may disclose personal data to business partners and subcontractors as necessary in connection with the performance of its services or solutions, or as otherwise appropriate in connection with a legitimate business need. If you do not want us to share your personal information with these companies, contact us at privacy@abcsys.com. We may for example disclose such information to an email service provider who sends service related emails to you on our or our clients' behalf, to the owner of your applicable insurance policy (if you are not the owner), or to authorized members of your company’s Human Resources department as necessary. These service providers are authorized to use your personal data only as necessary to provide these services to us and are approved by our clients beforehand. If authorized by you, we will also share your information with your financial and/or legal advisors. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreement with our Clients.

ABC may also disclose personal data as necessary in connection with the sale or transfer of all or part of the business. In these situations, ABC will require the recipient of the data to protect the data in accordance with the relevant principles in the Data Privacy framework, or otherwise take steps to ensure that the personal data is appropriately protected.

In certain situations, ABC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also reserve the right to disclose personal data and/or other information about you that we believe, in good faith, is appropriate or necessary to enforce our agreements, to take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of our applications and Web sites, and to protect the rights, property, or personal safety of us, our users and others associated with our organization.

Tracking Technologies

Technologies such as COOKIES, beacons, tags and scripts are used by ABC and some of the companies we partner with in providing Voluntary Benefits offerings to our Clients and end users. These technologies are used in analyzing and auditing user behavior, tracking user sessions and data, and in limited cases to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by some of our partner companies on an individual as well as aggregated basis.

We use cookies to store user preferences and other individual session related information as well as for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited.

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you however we may combine this automatically collected log information with other information we collect about you for security, marketing or other business purposes.

A Word on Links to Other Sites

We are not responsible for the privacy policies of any business partner or other vendor sites that are linked to any of the web portals or applications developed or maintained by ABC. We have no control over these sites. Please consult the respective privacy policies associated with these sites for more information on their practices, and for instructions on how to opt-out of certain practices if desired. Our privacy policy does not apply to, and we cannot control the activities of, such other Web sites.

In the Event of Merger, Sale or Bankruptcy

In the event that we, or a part of our company related to ABC’s applications or Web sites, are acquired by, or merged with a third party entity, you agree that we may transfer or assign the information we have collected from you as part of such merger, acquisition, or other change of control, provided we arrange for the continued protection of your information. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control, due to legal or regulatory requirements, how your personally identifiable information is treated, transferred, or used.

In the event of these events occur we will provide you with notice 30 days prior.

Changes to this Privacy Policy

We may change this privacy policy from time to time as Privacy laws and regulations evolve and as our contractual agreements with our Clients evolve from which we gain access to your Personal Data. If we have a significant change to our privacy practices which affects the way we store, manage share or otherwise handle your Personal Data, we will provide you with notice accordingly. All changes to this privacy policy will be published to our home page as well as to our Client Benefit portal applications and other places we deem appropriate so that you aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

The latest revision date of the Privacy Policy will always be posted at the top of this document. If there is a change in how we use your personally identifiable information, we will notify you here, by email, or by means of notice on our home page or via links on our applicable web sites and applications prior to the change becoming effective.

Data Retention

Subject to our agreement with our clients, ABC will retain personal data we process on behalf of our clients for as long as needed to provide services to our clients and End Users. ABC will retain and use this personally identifiable information as necessary to comply with our legal obligations and our agreements with our clients to manage, store and process your data on your behalf or as directed by End Users in specific situations upon request conformant to the Privacy Policy described herein.

EU-U.S. Data Privacy Framework and Dispute Resolution

American Benefits Consulting, an Alliant Insurance Services Inc. Company (as well as its affiliate American Benefits & Compensation Systems, Inc.) (“ABC”) complies[comply] with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) as set forth by the U.S. Department of Commerce. ABC has[have] certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov.

ABC is responsible for the processing of personal data it receives, under the Data Privacy Framework EU-U.S. DPF, and subsequently transfers to a third party acting as an agent on its behalf. ABC complies with the Data Privacy Framework Principles EU-U.S. DPF for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Data Privacy Framework EU-U.S. DPF, ABC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, ABC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF, ABC commits [commit] to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.

For complaints regarding EU-U.S. DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

General Questions or Requests for Changes to Personal Data

If you have any questions about this Privacy Statement, or if you would like to request access to Personal Data that we maintain about you, please contact us as follows:

American Benefits Consulting
101 Park Ave, 14th Floor
New York, NY 10178
(212) 716-3410
privacy@abcsys.com

If your personal data changes, or if you no longer desire our service, you may correct, update, delete inaccuracies, or have your account removed and/or deactivated from our systems by emailing our Customer Support at support@abcsys.com, or at privacy@abcsys.com. Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. We typically will respond to your request within 5 business days but in no case more than 30 calendar days. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Thank you,

ABC Privacy Team