Cruz Benefits Consultants
Last Modified: August 31, 2018
Cruz Benefits Consultants
P.O. Box FY
Hagatna, Guam 96932-7510
Local Number: 1.671.472.3522
Toll-Free Number: 1.833.222.42
This notice provides information on how medical information about you may be used and disclosed and how you can get access to this information.
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:
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:
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.
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.
Cruz Benefits Consultants
P.O. Box FY
Hagatna, Guam 96932-7510
Local Number: 1.671.472.3522
Toll-Free Number: 1.833.222.4286
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
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
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.
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
We Never Sell Personal Information
We will never sell your Personal Information to any third party.
Use of Personal Information
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:
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
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
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
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.
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
6. Cookies and Similar Technologies
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
Third Party Tracking Technologies
7. How to Access & Control Your Personal Data
Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
To exercise any of these rights, please contact us at firstname.lastname@example.org 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 email@example.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.