(877) 474-8322

Privacy Policy

Last updated March 31, 2024

This privacy notice for Solidarity Health Network, Inc. (“we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you:

  • Visit our website at https://my-benefits.net, or any website of ours that links to this privacy notice
  • Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about the personal information you disclose to us.

Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about the sensitive information we process.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by visiting __________, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in full.

TABLE OF CONTENTS

  • 1. WHAT INFORMATION DO WE COLLECT?
  • 2. HOW DO WE PROCESS YOUR INFORMATION?
  • 3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  • 4. HOW LONG DO WE KEEP YOUR INFORMATION?
  • 5. HOW DO WE KEEP YOUR INFORMATION SAFE?
  • 6. DO WE COLLECT INFORMATION FROM MINORS?
  • 7. WHAT ARE YOUR PRIVACY RIGHTS?
  • 8. CONTROLS FOR DO-NOT-TRACK FEATURES
  • 9. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  • 10. DO WE MAKE UPDATES TO THIS NOTICE?
  • 11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  • 12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • mailing addresses
  • email addresses
  • phone numbers
  • names
  • bank account and routing number
  • date of births

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

  • social security numbers or other government identifiers
  • financial data
  • contents of mail, email, and other correspondence

    Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy notice link(s) here: Privacy Policy (stripe.com).

    All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

    2. HOW DO WE PROCESS YOUR INFORMATION?

    In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and comply with the law. We may also process your information for other purposes with your consent.

    We process your personal information for a variety of reasons, depending on how you interact with our Services, including to improve our services, the operation and management of our website; providing content to you, and detecting, preventing, and investigating fraud.

    3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

    In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

    Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties“) who perform services for us or on our behalf and require access to such information to do that work. The categories of third parties we may share personal information with are as follows:

    We also may need to share your personal information in the following situations:

    • Business Transfers. We may share or transfer your information in connection with or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
    • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

    4. HOW LONG DO WE KEEP YOUR INFORMATION?

    In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

    We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). In addition, if any relevant legal claims are anticipated/brought, we may continue to retain your personal information for such additional periods as are necessary in connection with that claim. No purpose, except a legal claim, in this notice will require us to keep your personal information for longer than 1 year.

    When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

    5. HOW DO WE KEEP YOUR INFORMATION SAFE?

    In Short: We aim to protect your personal information through a system of organizational and technical security measures.

    We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

    6. DO WE COLLECT INFORMATION FROM MINORS?

    In Short: We do not knowingly collect data from or market to children under 18 years of age.

    We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under the age of 18, please contact us at Data Request Form – My Benefits (my-benefits.net).

    7. WHAT ARE YOUR PRIVACY RIGHTS?

    In Short:  You may review, change, or terminate your account at any time.

    Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

    However, please note that this will not affect the lawfulness of the processing before its withdrawal nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

    8. CONTROLS FOR DO-NOT-TRACK FEATURES

    Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

    9. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

    In Short: If you are a resident of California, you are granted specific rights regarding access to your personal information.

    What categories of personal information do we collect?

    We have collected the following categories of personal information in the past twelve (12) months:

    CategoryExamplesCollected
    A. IdentifiersContact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name  YES
    B. Personal information as defined in the California Customer Records statuteName, contact information, education, employment, employment history, and financial information  YES
    C. Protected classification characteristics under state or federal lawGender and date of birth  NO
    D. Commercial informationTransaction information, purchase history, financial details, and payment information  NO
    E. Biometric informationFingerprints and voiceprints  NO
    F. Internet or other similar network activityBrowsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements  NO
    G. Geolocation dataDevice location  NO
    H. Audio, electronic, visual, thermal, olfactory, or similar informationImages and audio, video or call recordings created in connection with our business activities  NO
    I. Professional or employment-related informationBusiness contact details to provide you with our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us  NO
    J. Education InformationStudent records and directory information  NO
    K. Inferences are drawn from collected personal informationInferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics  NO
    L. Sensitive Personal InformationSocial security numbers  YES

    We will use and retain the collected personal information as needed to provide the Services or for:

    • Category A – 1 year
    • Category B – 1 year

    Category L information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.

    We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

    • Receiving help through our customer support channels;
    • Participation in customer surveys or contests; and
    • Facilitation in the delivery of our Services and to respond to your inquiries.

    How do we use and share your personal information?

    Learn about how we use your personal information in the section, “HOW DO WE PROCESS YOUR INFORMATION?”

    Will your information be shared with anyone else?

    We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

    We may use your personal information for our business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be the “selling” of your personal information.

    We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

    • Category A. Identifiers
    • Category B. Personal information as defined in the California Customer Records law

    The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

    We have sold or shared the following categories of personal information to third parties in the preceding twelve (12) months:

    • Category A. Identifiers
    • Category B. Personal information as defined in the California Customer Records law

    The categories of third parties to whom we sold personal information are:

    • None.

    The categories of third parties to whom we shared personal information are:

    • Data Analytics Services

    California Residents

    California Civil Code Section 1798.83, also known as the “Shine The Light” law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

    If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request the removal of unwanted data that you publicly post on the Services. To request the removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

    CCPA Privacy Notice

    This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below.

    The California Code of Regulations defines a “residents” as:

    (1) every individual who is in the State of California for other than a temporary or transitory purpose and

    (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

    All other individuals are defined as “non-residents.”

    If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

    Categories of Personal Information

    Personal identifiers, including those listed in other California statutes: Real name; alias; Social Security number; passport number; other government issued number; Green Card number; driving license number; telephone number; email address; postal address; account name; online identifier; device identifier; IP address.

    Sensitive Personal Information: includes certain government identifiers (such as SSN, driver’s license, passport number); an account log-in, financial account, debit or credit card number with any required security code, password, or credentials allowing access to an account; precise geolocation (which means within 1,850 feet of a particular person); contents of mail, email, and text messages; genetic data; biometric information processed to identify an individual; information concerning an individual’s health, sex life; sexual orientation; or information about racial or ethnic origin, religious or philosophical beliefs, or union membership.

    Categories of Sources of Personal Information

    • Directly from you, when you provide it to us digitally or physically (e.g., where you contact us via email or telephone, or by any other means)
    • From other sources (such as Company affiliates and/or business partners; advertising providers; analytics providers; marketers; public data bases; consumer data resellers; researchers; payment processors; and surveys)
    • Through your use of the Services

    We collect and use Personal Information from or about California residents for the following business and/or commercial purposes:

    Operation of our websites: operation and management of our websites; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our websites.

    Security: physical security of our premises (including records of visits to our premises and CCTV recordings); and electronic security (including login records and access details, where you access our electronic systems)

    Legal compliance: compliance with our legal and regulatory obligations under applicable law

    Legal Proceedings: establishing, exercising, and defending legal rights

    Improving our products and services: identifying issues with existing products and services; planning improvements to existing products and services; and creating new products and services

    Risk Management: Audit, compliance, controls, and other risk management

    Fraud prevention: Detecting, preventing and investigating fraud

    Your rights with respect to your personal data

    Right to request deletion of the data — Request to delete

    You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

    Right to be informed — Request to know

    Depending on the circumstances, you have a right to know:

    • whether we collect and use your personal information;
    • the categories of personal information that we collect;
    • the purposes for which the collected personal information is used;
    • whether we sell or share personal information to third parties;
    • the categories of personal information that we sold, shared, or disclosed for a business purpose;
    • the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
    • the business or commercial purpose for collecting, selling, or sharing personal information; and
    • the specific pieces of personal information we collected about you.

    In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

    Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

    We will not discriminate against you if you exercise your privacy rights.

    Right to Limit Use and Disclosure of Sensitive Personal Information

    If the business collects any of the following:

    • social security information, driver’s licenses, state ID cards, passport numbers
    • account login information
    • credit card numbers, financial account information, or credentials allowing access to such accounts
    • precise geolocation
    • racial or ethnic origin, religious or philosophical beliefs, union membership
    • the contents of email and text, unless the business is the intended recipient of the communication
    • genetic data, biometric data, and health data
    • data concerning sexual orientation and sex life

    you have the right to direct that business to limit its use of your sensitive personal information to that use which is necessary to perform the Services.

    Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes.

    Please note that sensitive personal information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as the publicly available information.

    To exercise your right to limit use and disclosure of sensitive personal information, please visit: __________.

    Verification process

    Upon receiving your request, we will need to verify your identity to determine you are the same person with whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

    We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additional provided information as soon as we finish verifying you.

    Other privacy rights

    • You may object to the processing of your personal information.
    • You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
    • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent who does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

    You can opt out from the selling or sharing of your personal information by disabling cookies in Cookie Preference Settings and clicking on the Do Not Sell or Share My Personal Information link on our homepage.

    To exercise these rights, you can contact us by visiting Data Request Form – My Benefits (my-benefits.net), or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

    10. DO WE MAKE UPDATES TO THIS NOTICE?

    In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

    We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

    11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

    If you have questions or comments about this notice, you may contact us by post at:

    Solidarity Health Network, Inc.

    4853 Galaxy Pkwy, Suite K, Cleveland, OH 44128

    Cleveland, OH 44128

    United States

    12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

    Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit: Data Request Form – My Benefits (my-benefits.net).