Privacy Policy and Practices

Cruz Benefits Consultants

CBC Guam  

Last Modified: August 31, 2018



Cruz Benefits Consultants, CBC Guam is a company that acts as an insurance broker to market, sell, and service partner company products to our customers - both employers and individuals.    Our company works under agreements with various insurance carriers in which we refer to as company partners to provide information, education, claims processing, and client servicing in the administration of the benefit plans for our customers.  This Privacy Policy describes our relationship with our customers and their benefit plans, our functions and our policy in handling private information.


Our company is committed to protecting your privacy.  This Privacy Policy applies to our company's customer database, our Websites, our Social Media pages, and our Subscription Service (the Subscription Service), including our associated mobile applications (Mobile Apps aileencruz.cardtapp.me) owned and/or controlled by CBC Guam.  Including our company website www.cruzbenefits.com, Facebook Business Page www.facebook.com/cbcguam671, Instagram www.instagram.com/cbcguam, LinkedIn www.linkedin.com/cbcguam, Pinterest Page www.pinterest.com/cruzbenefits, Twitter www.twitter.com/cbcguam, and Yelp Business www.yelp.com/biz/cruz-benefits-consultants-hagatna-3.


This Privacy Policy governs our data collection, processing and usage practices.  It also describes your choices regarding use, access and correction of your personal information.  If you do not agree with the data practices described in this Privacy Policy, you should not use the Websites or the Subscription Service.  


We periodically update this Privacy Policy.  We will post any privacy policy changes on this page.  If the changes are significant, we will provide a more prominent notice by sending you an email notification, or if you subscribe to the Subscription Service, through our subscription services notifications.  While we will notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically.  We will also keep prior versions of this Privacy Policy in an archive for your review.  


If you have any questions about Cruz Benefits Consultants, CBC Guam Privacy Policy and Practices as contained on this page below, please contact:


Contact

Cruz Benefits Consultants

P.O. Box FY

Hagatna, Guam 96932-7510 

Email:  privacy@cbcguam.com

Local Number:  1.671.472.3522

Toll-Free Number: 1.833.222.42

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Privacy Policy

This notice provides information on how medical information about you may be used and disclosed and how you can get access to this information.


PRIVACY POLICY AND PROCEDURES 


Protecting the privacy and confidentiality of information about our groups and participants is very important to CBC Guam.  We value your trust and strive to comply with each of the following policy and procedures: 



  • We do not sell, rent, lease or otherwise disclose personal information of our clients for purposes unrelated to our products and services.  The personal information of our clients is importance to us.    


  • We provide this information only to our employees, partner agents and company partners as required to allow them to help us develop and provide services. 


  • We work to ensure information integrity and security using technology tools and design our business practices to help protect the personal information of our clients is properly gathered, stored and processed.    


  • CBC Guam has business policies and practices in place to help ensure that our employees carry out these practices to protect personal information about our clients.  Employees are subject to censure, dismissal, or termination for violation of these policies. 


CBC Guam provides this notice to let you know about the current privacy practices and to inform you about how we safeguard your information. 



Collection of Information 


As part of our company's normal operating procedures, CBC Guam needs to obtain information to determine an individual’s eligibility for our products and services.    PPF may collect nonpublic personal health information about group and individual clients including: 



  • Information from clients and group including names, addresses, social security numbers and health information as required to process application, claims and other client service requests. 


  • Information about customers’ transactions with CBC Guam, our company partners, partner agents or plan administrators regarding claims and payment information. 


  • Information from employer (including salary and benefits to determine eligibility information), clients’ health care provider (including products and premium information), and family members.



Disclosure of Information 


CBC Guam may disclose the nonpublic personal information we collect as described above, as well as information about your transactions with us (such as your policy coverage, premiums, and payment history) to our partner agents or company partners who perform services or functions on our behalf.  We may also disclose the nonpublic personal information we collect as authorized by you, or as required or permitted by law.  



  • CBC Guam will use or share with other parties any nonpublic personal health information about you for any purpose other than disclosures for the performance of insurance functions, claims, and reimbursements, or disclosures that are permitted or required by law, or disclosures that the client authorized. 


  • CBC Guam will not disclose any nonpublic personal information about a former client of CBC Guam other than as may be required or permitted by law. 



Confidentiality and Security 


CBC Guam will safeguard, according to strict standards of security and confidentiality, any information we collect, receive or maintain about our groups and clients.  CBC Guam maintains administrative, technical, and physical safeguards to ensure the security and confidentiality of our client’s information and records, to protect against anticipated threats or hazards to such records, and to protect against unauthorized access to or use of such information or records. 


  • Internally, CBC Guam limits access to our clients’ information to only those employees who need access to the information to perform their job functions.   Employees who misuse information are subject to disciplinary actions.  


  • Externally, we do not disclose customer information to any third parties unless we have previously informed the customer of the disclosure, have been authorized to do so by the customer, or are required or permitted to make the disclosure by law. 


 

If you have any questions about Cruz Benefits Consultants, CBC Guam Privacy Policy and Practices as contained on this page below, please contact:


Contact

Cruz Benefits Consultants

P.O. Box FY

Hagatna, Guam 96932-7510 

Email:  privacy@cbcguam.com

Local Number:  1.671.472.3522

Toll-Free Number: 1.833.222.4286

Archives

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Find out more

Online Privacy Policy

  1. Use of the Subscription Service by CBC Guam
  2. Information We Collect
  3. How We Use Information We Collect
  4. How We Share Information we Collect
  5. International Transfer of Information
  6. Cookies and Similar Technologies
  7. How to Access & Control Your Personal Data




1. Use of the Subscription Service by CBC Guam


The CBC Guam Subscription Service

Our online Subscription Service allows our company Cruz Benefits Consultants to create content and share it with our subscribers.  The Subscription Service can also be used to help our company organize our customer and sales data.   The information added to the Subscription Service, either by site visitors providing their contact information or when a Subscription Service user adds the information, is stored and managed on our service providers' servers. This information is then used to contact visitors about their interest in the company's products or services and interact with the company. CBC Guam provides the Subscription Service to our current and potential customers to provide updated information about the company and the insurance industry that will meet our customer service needs, and we use it to meet CBC Guam’s related needs. 


Use by CBC Guam

We use our own Subscription Service to build webpages that people can visit to learn more about Cruz Benefits Consultants, CBC Guam.  Information that we collect and manage using the Subscription Service for our own marketing belongs to us and is used, disclosed and protected according to this Privacy Policy. 


CBC Guam processes our customers' information as they direct and in accordance with our agreements with our customers, and we store it on our service providers' servers, but we do not have control over its collection or management. Our agreements with our customers prohibit us from using that information, except as necessary to provide and improve the Subscription Service, as permitted by this Privacy Policy, and as required by law.  We have no direct relationship with individuals who provide Personal Information to our customers.
CBC Guam acknowledges that you have the right to access your Personal Information.  We may work with HubSpot to provide notice to our customers and visitors to help them provide notice about their data collection, processing and usage. Our agreements with our customers prohibit us from using the Subscription Service to collect, manage, or process Sensitive Information. 


We collect information under our websites and social media pages for marketing purposes and education information dissemination.  If you are one of our customers and would no longer like to be contacted through the  use our Subscription Service, please unsubscribe and contact us directly.  We may transfer Personal Information to companies that help us provide our service. 


Use by Our Customers

Our customers use the Subscription Service to learn more about our business and industry news. CBC Guam does not control the content of these webpages or the types of information that our customers may choose to collect or manage using the Subscription Service. That information belongs to them and is used, disclosed and protected by them according to their privacy policies and is not subject to this Privacy Policy. 


"Sensitive Information"

This refers to credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver's license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.




2. Information We Collect


When You Visit our Websites

You are free to explore the Websites without providing any Personal Information about yourself. When you visit the Websites or register for the Subscription Service, we request that you provide Personal Information about yourself, and we collect Navigational Information. 


When You Use our Mobile Application

We use mobile analytics software to allow us to better understand the functionality of our Mobile Apps on your mobile device.  This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, where the application was downloaded from, and Navigational information when you view our websites. 


We send push notifications from time to time in order to update you about events or promotions.  If you no longer wish to receive such communications, you may turn them off at the device level.


We may link information we store within the analytics software to Personal Information you submit within the Mobile App.  We do this to improve services we offer you and improve our marketing, analytics and site functionality.


"Personal Information"

This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business.  


Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers


Personal Information also includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual.  Navigational information refers to information about your computer and your visits to this website such as your referral source, length of visit and pages viewed.  Please see the "Navigation Information" section below.  


We do not collect and process sensitive payment information (such as credit cards numbers and billing information) from you when you subscribe to the Subscription Service, or our websites.


Information we collect from third parties

From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites.


Information About ChildrenThe Websites are not intended for or targeted at children under 18, and we do not knowingly or intentionally collect information about children under 18.  If you believe that we have collected information about a child under 18, please contact us so that we may delete the information.




3. How We Use Information We Collect


Compliance with Our Privacy Policy

We use the information we collect only in compliance with this Privacy Policy. Customers who subscribe to our Subscription Services are obligated through our agreements with them to comply with this Privacy Policy.


We Never Sell Personal Information

We will never sell your Personal Information to any third party. 


Use of Personal Information

In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:

  • improve your browsing experience by personalizing the Websites and to improve the Subscription Service;
  • send information and content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
  • promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
  • provide other companies with statistical information about our users -- but this information will not be used to identify any individual user;
  • send information to you regarding changes to our Customer Terms of Service, Privacy Policy (including the Cookie Policy), or other legal agreements
  • meet legal requirements.

We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you.  In those cases, we do not transfer your Personal Information to the third party.  


We use the information collected through our Websites, Social Media, and Subscription Service by our customers for the following purposes:

  • to provide the Subscription Service (which may include the detection, prevention and resolution of security and technical issues);
  • to respond to customer support requests; and
  • otherwise to fulfill the obligations under the CBC Guam Customer Terms of Service. 


Legal basis for processing Personal Information

Our company operates only within Guam and the United States.  Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.  However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to contact or perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.  In some cases, we may also have a legal obligation to collect personal information from you.


If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).  Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.


Use of Navigational Information

We use Navigational Information to operate and improve the Websites and the Subscription Service.  We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about Cruz Benefits Consultants, CBC Guam. 


Customer Testimonials and Comments

We post customer testimonials and comments on our Websites, which may contain Personal Information.  We obtain each customer's consent via email prior to posting the customer's name and testimonial.


Use of Credit Card Information

If you give us credit card information, we use it solely to check your financial qualifications and collect payment from you.  We may collect payment information on behalf of our company partners and carriers who require payments to process your policy applications and contracts.  Our company partners and carriers may use a third-party service provider to manage credit card processing.  This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.


Security of your Personal Information

We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure.  We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.  All Personal Information is protected using appropriate physical, technical and organizational measures.


Social Media Features

Our Websites may include Social Media Features, such as the Facebook Like button and Widgets, such as the Share This button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly.  Social Media Features and Widgets are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features.  Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.


External Websites

Our Websites provide links to other websites.  We do not control, and are not responsible for, the content or practices of these other websites.  Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices.  This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.


Public Forums

We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others.  We will correct or delete any information you have posted on the Websites if you so request, as described in "Opting Out and Unsubscribing" below.


Retention of Personal Information

How long we keep information we collect about you depends on the type of information as described in further detail below.  After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible. We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about the Subscription Service or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).


When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in "To Unsubscribe from Our Communications" below.


If you provide information to us as part of our use of the Subscription Service, our company may  decide how long to retain the personal information we collect from you.  If a customer terminates its use of the Subscription Service, then we will provide customer with access to all information stored for the customer by the Subscription Service, including any Personal Information provided by you, for export by the customer according to our agreement with our customer.  After termination, we may, unless legally prohibited, delete all customer information, including your Personal Information, from the Subscription Service.


If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us.  We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created. 




4. How We Share Information we Collect


Service Providers

We employ other companies and people to provide services to visitors to our Websites, our customers, and users of the Subscription Service and may need to share your information with them to provide information, products or services to you.  Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service or support. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.


CBC Guam Partners

In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support.  Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. We partner with trusted third parties to provide you with co-marketing content that we think may be relevant to you.  When you engage with these co-marketing partners, we will tell you who we are sharing data with, and provide a link to the co-marketing partner’s privacy policy so you can learn more about how to opt-out of the partner’s communications. These co-marketing partners are required to adhere to our privacy and data protection policies.  


Corporate Events

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by CBC Guam on the Websites and the Subscription Service.  In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.


Compelled Disclosure

We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process. 




5.International Transfer of Information


International transfers to third parties

Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside.  When we share information of customers in the European Economic Area or Switzerland, we make use of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer. 




6. Cookies and Similar Technologies


Cookies

Cruz Benefits Consultants, CBC Guam use cookies or similar technologies (such as web beacons) to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole.  


Navigational Information Collected by Our Customers

Our customers can use the tools we provide, as well as tools provided by third parties, to collect Navigational Information when you visit their webpages on the Subscription Service. CBC Guam does not control our customers' use of these tools, nor do we control the information they collect or how they use it. 


Flash Cookies and Other Third Party Tracking Technologies

The Adobe Flash Player (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies but these are managed through a different interface than the one provided by your Web browser.  This technology creates locally stored objects that are often referred to as "Flash cookies." CBC Guam does not use Flash cookies. However, our customers of our software platform may create pages on the CBC Guam platform that employ Adobe Flash cookies.   For more information on "Flash cookies" and how you can manage them please visit our Cookie Policy.  


Advertising

We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites.  Our ad network partner uses cookies and Web beacons to collect information about your activities on this and other Web sites to provide you targeted advertising based upon your interests.  If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here (or if located in the European Union, please click here).  Please note this does not opt you out of being served advertising.  You may continue to receive generic ads.


Third Party Tracking Technologies

The use of cookies and web beacons by any tracking utility company is not covered by our Privacy Policy or Cookie Policy. 




7. How to Access & Control Your Personal Data


Reviewing, Correcting and Removing Your Personal Information

You have the following data protection rights:

  • You can request access, correction, updates or deletion of your personal information.
  • You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
  • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information.  Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.)

To exercise any of these rights, please contact us at privacy@cbcguam.com or by submit a written request through postal mail.  We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.


To Unsubscribe From Our Communications

You may unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, updating your communication preferences, or by sending us email us at privacy@cbcguam.com or by submitting a written request through postal mail.  Customers cannot opt out of receiving transactional emails related to their account with us or the Subscription Service. 


To Unsubscribe from Our Customers' Communications

You can unsubscribe from our customers' marketing communications by clicking on the "unsubscribe" link located on the bottom of our emails, or by contacting us directly.

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