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PRIVACY POLICY

Last Updated and Effective Date: [11/13/2023]
This Privacy Policy describes how Sonata Care LLC. (“Sonata Care,” “we,” or “us”) collects, uses, and discloses personal information about you and your choices. Personal information is sometimes also referred to as personal data, personally identifiable information or other like terms to mean any information that directly or indirectly identifies you or is reasonably capable of being associated with you or your household. This Privacy Policy applies to personal information we collect online and offline, such as when you use our website or interact with us to conduct business dealings, including the personal information we obtain from business partners and service providers and contractors who provide us certain business services (“B2B Dealings”) (collectively, our “Services”).
Please note that this Privacy Policy does not apply to any information we collect from consumers or customers that is covered by the federal Gramm-Leach-Bliley Act (“GLBA Covered Data”). For GLBA Covered Data, please see our privacy policy http://healthenrollmentplans.com/glba.
We may provide different or additional notices of our privacy practices with respect to other personal information collection practices not within the scope of this Privacy Policy, in which case this Privacy Policy will not apply. For example, this Privacy Policy does not apply to personal information we collect from prospective employees, employees or subcontractors.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. We may also provide you with an additional notice (such as by adding a statement to the Services or sending you a notification), in connection with making material changes to this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
Please note that our Services and this Privacy Policy are directed only to users in the United States.

Contents

I. NOTICE AT COLLECTION
A. Collection of Personal Information

1. Personal Information You Provide to Us

2. Personal Information We Collect Automatically

3. Personal Information We Collect from Other Sources

4. Personal Information We Derive

B. Purpose and Use of Personal Information

C. Disclosure of Personal Information

D. Retention of Personal Information

II. ADVERTISING AND ANALYTICS

III. TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

IV. YOUR CHOICES

A. Cookies

B. Communications Preferences

V. CHILDREN

VI. “DO NOT TRACK”

VII. Additional Disclosure for California Residents

VIII. CONTACT US

  1. NOTICE AT COLLECTION
    2. This Notice at Collection describes how we handle personal information collected about you when you engage our Services.
  2. Collection of Personal Information
  3. Personal Information You Provide to Us
    4. We may collect personal information you provide directly to us. For example, we may collect information directly from you when you provide your personal information on our website or conduct B2B Dealings with us. The types of personal information that we may collect directly from you include the following:
    • Contact Information: We collect certain identifiers and contact information from you, such as name, phone number, business name, your title, email address, geolocation/postal address, and other similar identifiers.
    • Personal Information We Collect Automatically
    We may automatically collect certain personal information about your interactions with us or our Services, including:
    1. Activity Information: We may collect information about your activity on our Services, such as your use of our website or other online Services.
    2. Device and Usage Information: We may collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, and browser type. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.
    3. Information Collected by Cookies and Similar Tracking Technologies: We and others that control collection of personal information may use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see Your Choices below in Section IV.
  4. Personal Information We Collect from Other Sources
    5. We may obtain personal information from other sources. For example, we may collect information from advertising networks, data analytics providers, operating systems and platforms, lead providers, social networks, and other advertising partners. This information includes your name, address/location (state and/or zip code), email address, phone number, gender, birth date, Medicare/Medicaid coverage status, IP address, and/or lead identification number and usage data collected through cookies and other trackers described in Advertising and Analytics in Section II below.
  5. Personal Information We Derive
    6. We may derive personal information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer that you are interested in certain services based on your use of our website.
  6. Purpose and Use of Personal Information
We may use the categories of personal information identified in Collection of Personal Information in Section I.A above for the following purposes:
  1. Provide, maintain, and improve our Services;
  2. Conduct business dealings with our partners, service providers or contractors;
  3. Process transactions and send you related information, including confirmations, receipts, invoices, and customer experience surveys;
  4. Personalize and improve your experience on our Services;
  5. Send you technical notices, security alerts, and support and administrative messages;
  6. Respond to your comments and questions and provide customer service;
  7. Communicate with you about products, services, and events offered by Sonata Care LLC and others and provide news and information that we think will interest you (see Your Choices in Section IV below for information about how to opt out of these communications at any time);
  8. Monitor and analyze trends, usage, and activities in connection with our Services;
  9. Personalize the advertisements you see on third-party platforms and websites (for more information, see Advertising and Analytics in Section II below);
  10. Personalize the advertisements you see when you use our Services based on information provided by our advertising partners;
  11. Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Sonata Care LLC and others;
  12. Debug to identify and repair errors in our Services;
  13. Comply with our legal and financial obligations; and
  14. Carry out any other purpose described to you at the time the information was collected.
  1. Disclosure of Personal Information
    2. We disclose personal information in the following circumstances or as otherwise described in this policy:
    1. Our Service Providers and Contractors: We may disclose personal information to service providers and contractors who provide us services, such as web hosting, data management, advertising and marketing vendors, and other service providers.
    2. Legal Disclosures: We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. We may also disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Sonata Care LLC, our users, the public, or others.
    3. Disclosed to Advisors and Lawyers: We may disclose personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
    4. Disclosed During Change of Ownership: We may disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
    5. Among Our Family of Companies: Personal information may be disclosed between and among Sonata Care LLC and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
    6. With Your Consent: We may disclose personal information with your consent or at your direction.
    7. Disclosure of Non-Personal Information: We may also disclose aggregated or de-identified information that cannot reasonably be used to identify you. If we do so, we publicly commit to maintain and use the information in an aggregated or de-identified form and not attempt to re-identify the information, unless permitted or required by law.
    8. Retention of Personal Information
    We store personal information for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
  2. ADVERTISING AND ANALYTICS
    3. We may allow others to provide analytics services and serve advertisements on our behalf across the web. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.
    We may also work with third parties to serve ads to you as part of customized campaigns on third-party platforms. As part of these ad campaigns, we or the third-party platforms may convert information about you into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.
  3. TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES
    4. Sonata Care LLC is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction.
  4. YOUR CHOICES
  5. Cookies
    6. Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.
  6. Communications Preferences
    7. You may opt out of receiving text messages or promotional emails from Sonata Care LLC by following the instructions in those communications or through the contact methods described in Contact Us below. If you opt out, we may still send you non-promotional emails, such as those about our ongoing business relations.
  1. CHILDREN
    2. This website is not intended for or directed at children under the age of 13. In addition, we do not knowingly collect personal information from children under the age of 13.
  2. “DO NOT TRACK”
    3. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the websites you visit indicating that you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the do not track signal, we currently do not respond to the browser do not track signals.
  3. Additional Disclosure for California Residents
    4. California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at 1-866-284-6668.
  1. CONTACT US
If you have any questions about this Privacy Policy, please contact us at 1-866-284-6668. Note to Client: Per the information you provided, we understand that you do not meet the requirements of the CCPA and as amended by the CPRA (see below). For this reason, this privacy policy does not include CCPA/CPRA disclosures. Instead, it covers general web usage. Note, however, that the information you collect from individuals for insurance coverage will be covered by the separate GLBA notice which we also provide. As such, this website notice is more limited in scope.

Standard for CCPA/CPRA

-Do business in CA;

-Collect Californians' personal information; and

-Meet one of the following three criteria:

(1) As of January 1 of the calendar year, had annual gross revenues in excess of $25 million. OR

(2) Alone or in combination, annually buys, sells, or shares the personal information of 100,000 or more Californians or households. OR

(C) Derives 50 percent or more of its annual revenues from selling or sharing Californians’ personal information.

In addition, you can be subject to the CCPA/CPRA if you control or are controlled by a business that meets the above requirements.

Lastly, another way to be subject to the CCPA/CPRA is if you are a joint venture or partnership composed of businesses in which each business has at least a 40 percent interest and meets the above requirements.

Note to Client: We prepared this without an independent data inventory. Please review each section carefully to assess whether it accurately reflects your data collection, use and disclosure practices, along with other statements herein.

Note to Client: Please confirm that the Services will only be directed to US individuals. If not, you can delete this statement.

Note to Client: Please insert hyperlinks to relevant sections below.

Note to Client. Here we are addressing B2B contacts that you have a relationship with. We moved the data you collect from people requesting quotes over to the GLBA notice. This would cover commercial dealings and B2B. Please check if this covers the type of data you will collect from B2B contacts or if anything else should be added.

Note to client: All underlined references to section headers should hyperlink to those sections.

Note to Client: This is intended to address the California Shine the Light Law. This law applies if you have: (1) 20 or more employees, (2) an established business relationship with a customer who is a California resident, and (3) shared customer personal information with other companies for their direct marketing use within the immediately preceding calendar year. Please let us know if you believe this law does not apply to Sonata Care LLC.