Effective Date: May 22, 2018
ebenefit Marketplace, LLC., including its affiliates (collectively, “ebm”, “we” or “us”) respects your privacy and is committed to protecting it through our compliance with this ebm Privacy Statement (the “Privacy Statement”). This Privacy Statement describes what information ebm collects from you, and how we use that data. We also describe the measures we take to safeguard the security of the information and how individuals can contact us about our privacy practices.
This Privacy Statement only covers our privacy practices with respect to information obtained: (i) through the ebm website at www.getebm.com (“Website”); (ii) in connection with the use of our Software as a Service and other applications (collectively, the “Subscription Service”) and related support services (“Support Services”) that we provide to Clients. In this Privacy Statement, the Subscription Service and Support Services are collectively referred to as the “Services.” This Privacy Statement is subject to the terms of any ebm Terms and Conditions and/or any other agreement entered into between ebm and the Client (collectively, the “Client Service Agreement”).
For the purposes of this Privacy Statement:
- “Client” means any entity that purchases the Services.
- “Client Data” means data submitted through the Services by or for Client or its Users.
- “Visitor” means a visitor of the Website.
- “User” means an individual authorized by Client to access and use the Services.
- “Personal Information” means the personally identifiable information you provide to ebm to access and use the Website and Services.
As further described below, we collect several types of information from and about our Users and Visitors. This may include:
- When establishing an account for the Subscription Service or using the Services, we collect Client Data.
- When filling out forms on our Website, including the “Contact Us” page and our “Chat” function, we collect personal information, including without limitation, name, mailing address, email address, company name and phone number.
- When you request a demo of our Subscription Service.
- When you subscribe to our email newsletter, or download content (e.g. whitepapers) from our Website.
- When you post material to our Website, participate in chat rooms, blogs or other interactive features of our Website, or request further information or services from us.
- When you participate to an event we sponsor, or register for a webinar.
- When you attend one of our events, during phone calls with ebm’s sales representatives, or when you contact ebm’s client service.
- When you report a problem with our Website or Service.
- When you contact us, or complete our surveys.
- Other information (e.g.: System logs) you may submit to us related to your use of our Website and Subscription Service. System logs include information such as your IP address, browser type, operating system, and device information.
ebm may collect and use information we receive from third parties in connection with your use of the Website. For instance, ebm uses a third party such as Google Analytics for reporting and analytics to measure the effectiveness of our Website and marketing efforts, and to identify areas for improvement.
We may combine information that we collect outside of the Services and the Website with information we collect online. For example, some of our Clients may submit User information through email. We may also combine information you submit or that we track across multiple devices. We may also combine information we collect from you with information we get about you from others.
As you navigate through the Website and the Services, we may also passively collect details about your use of our Website and Services through tracking tools. We may also collect information about your installation and use of our mobile applications. We collect information about you over time when you use the Website and the Services. We also work with third parties who help gather this information.
When you use our Services, the types of Client Data we collect may include:
- Personal Information of the User, including the User’s name, email address, phone number, day of birth, month of birth, profile picture and employee ID or other identifiers supplied by the Client.
- Employment data, including company name, start date, department, job title, job location, manager’s contact information.
- Personal Information you provide to us on behalf of another individual: If you are entering Personal Information on behalf of another individual, you warrant to us that individual authorized you to enter the Personal Information onto our system, and that that information is accurate and correct. If any non-compliance by you with respect to this provision results in any loss or damage being incurred by us, you may be required to compensate us in respect of such loss.
- Contact information, such as your name, address, phone number, email address, and company name.
- Your employment information, including your title and what company you work for.
- Information you submit to us, including survey results and any other information you post on our Website and social media channels.
- Chat and messaging transcript.
We may also collect other information in connection with your use of our Website and Services:
- We may collect your IP address or other device identifier, usage patterns, traffic data, location data, logs and other communication data and the resources that you access, as well as information about your computer and internet connection, including your operating system and browser type.
- If you use our Website, we might look at what site you came from or what site you visit when you leave us.
- If you use our mobile application, we might look at how often you use the mobile application and where you downloaded it.
We may use information that we collect to facilitate our legitimate interest in operating the Website and providing you with the Services. ebm uses the Personal Information collected for the following purposes:
- To provide you with our Website and Services.
- To ensure compliance with and enforce the Client Agreements and/or any other contractual or legal obligations with respect to use of the Services.
- To carry out our obligations from any contracts entered into between Clients and us.
- To better administer your accounts and to serve you better.
- To respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our Website and Services.
- To notify you about changes to our Website and Services, or obtain any required consent.
- To track your browsing behavior, such as the pages you visited over time.
- To improve our Website and Services, including for statistical and analysis purposes. We may also use your information to customize your experience with us.
- To understand your interests, including using your information to better understand what Services may interest you.
- For security purposes.
- For marketing purposes. In particular, we might provide Visitors with ads about products and offers. We may provide you with information about new products and special offers. We might tell you about new features or updates to our Services. We may also use your personal information to send you electronic or paper communications. For more information about your choices related to these communications, see the Communication Choices section below.
We may disclose personal information that you provide to us via the Website and Services, to the following third parties:
- Our Affiliates. We may disclose personal information to our Affiliates for the purposes described in this Privacy Statement.
- Business Partners. We partner with a variety of businesses and work closely with them to market or sell our Services. Some of our business partners may co-sponsor events and other offerings with ebm. We may share personal information with these co-sponsors when you sign up for events or offerings to allow our partners to send you marketing communications and information that may be of interest to you, as permitted under applicable law.
- Service Providers. We contract with service providers to perform certain business functions on our behalf and may share your personal information with them to provide such services. This may include service providers that help us with data hosting, rewards management solutions, and email management.
- Business Transfers. In the event of merger, acquisition, or any form of sale or transfer of some or all of our assets (including in the event of a reorganization, dissolution or liquidation), in which case personal information held by us about our Visitors, Clients and Users will be among the assets (including as a stand-alone asset) transferred to the buyer or acquirer.
- Legal and Harm. Notwithstanding anything to the contrary in this Privacy Statement, we may release personal information when we believe that release is necessary or appropriate:
- Under applicable law, including laws outside your country of residence;
- To comply with legal process;
- To respond to requests from public and government authorities including public and government authorities outside your country of residence;
- To enforce or apply our conditions of use and other agreements;
- To protect our operations or those of any of our Affiliates;
- To allow us to pursue available remedies or limit the damages that we may sustain; and
- To protect the rights, privacy, property, or safety of ebm, our employees, our Affiliates, our users, or any other person or entity
We use “cookies”, web beacons (also known as “tracking pixels”) and similar technologies for the following purposes:
- To help us improve our Website and Services;
- To estimate our audience size and usage patterns;
- To authenticate your access to various areas of our Services;
- To recognize you when you return to our Website or Services; and
- To present you with advertising about products and offers.
- Where strictly necessary. These cookies and similar technologies are essential in order to enable the Website and Services to provide the feature you have requested, such as remembering you have logged into the Subscription Service.
- For performance and analytics. These cookies and similar technologies collect information on how users interact with the Website and Services and enable us to improve how the Website and Services operate. For example, we use Google Analytics cookies to help us understand which are the most frequently visited pages on the Website and Services, help us record any difficulties you have with the Website and Services, and show us whether our advertising is effective or not.
- Advertising Cookies. These cookies are set to display targeted promotions or advertisements based upon your interests on the Website or to manage our advertising. These cookies collect information about your activities to provide you targeted advertising.
- Social Media Cookies. These cookies are used when you share information using a social media sharing button or “like” button on our websites or you link your account or engage with our content on or through a social media site. The social network will record that you have done this. This information may be linked to targeted advertising.
You will not be able to opt-out of any cookies or other technologies that are “strictly necessary” for the Services.
You may wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html or http://www.aboutcookies.org for information on commonly used browsers.
To opt-out of Google Analytics tracking for the Website and Services, you can visit the following opt-out link https://tools.google.com/dlpage/gaoptout
To control flash cookies, which we may use from time to time, you can go to the following link:
Why? Because flash cookies cannot be controlled through your browser settings.
Additionally, you may be able to opt-out of receiving personalized advertisements from other companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info/choices/ ,
http://optout.networkadvertising.org/ , and http://www.youronlinechoices.eu/
Some browsers have “do not track” or “DNT” features that allow you to tell a website not to track you. These features are not all uniform. ebm does not currently commit to responding to browsers’ DNT signals with respect to its Website and Subscription Service, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent.
We provide certain choices regarding the information Visitors and Users provide to us. We have created mechanisms to provide you with the following control over your information when using our Website and Services.
If you wish to opt-out of having your e‑mail address used for promotional purposes by ebm, you may:
- Click on the “unsubscribe” link located in the emails sent by ebm; or
- Change your preferences via the ebm Email Preferences Center
Should you need further assistance, please contact us at firstname.lastname@example.org. We will respond to such requests as soon as reasonably practicable.
Overview of Rights
We want to draw your attention on the rights you keep regarding your Personal Information you provided us with:
- You can request ebm to access to and rectify or erase your Personal Information, or to restrict or object to their processing;
- You can request ebm to exercise your right to data portability;
- You can withdraw at any time your consent to the processing of your Personal Information of other purposes than (i) the execution of an agreement between yourself, and ebm or (ii) the compliance of ebm with legal obligation to which it is subject, it being specified that such withdrawal shall not affect the lawfulness of processing based on such consent before such withdrawal;
- You can lodge a complaint to us using the information listed below or within your local data protection authority;
You may send us an e‑mail at email@example.com to request access to, correct or delete any personal information that we may maintain about you in connection with the Website and Services. Client will be notified of your request as required by Client Agreement. In some circumstances, only Client, and not ebm, may have the authority to approve the update, correction, or deletion of your personal information.
For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before processing your request.
You may send us an e‑mail at firstname.lastname@example.org to request a download of the information you have shared through our Website and Services. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before processing your request. Client will be notified of your request as required by Client Agreement. In some circumstances, only Client, and not ebm, may have the authority to update, correct, or delete your personal information.
Personal information we maintain may be stored in the United States. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. ebm will continue to treat Client Data transferred from the European Union into the United States according to relevant EU privacy laws. We will take measures to ensure that any transfers of Client Data comply with applicable data protection laws.
We will retain your information for as long as your account is active or as long as the data is necessary for the purpose for which it was collected. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
ebm maintains reasonable and appropriate measures that are designed to protect the personal information obtained through the Website and Service from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Despite ebm’s reasonable and appropriate security measures, the Internet is not 100% secure. We cannot promise that your use of our Services or Website will be completely safe. We encourage you to use caution when using the Internet. User IDs and passwords are needed to access our Services. It is your responsibility to protect your username and password.
ebm’s Subscription Service and Website may link to websites that are not owned or controlled by ebm. As such, this Privacy Statement does not apply to information collected on any third‑party site or by any third‑party application that may link to or be accessible from the Website or Subscription Service.
Our Website and Services are meant for adults. We do not knowingly collect personally identifiable data from persons under the age of 13, and we strive to comply with the provisions of COPPA (The Children’s Online Privacy Protection Act). If you are a parent or legal guardian and think your child under 13 has provided us with information, please contact us at email@example.com. You can also write to us at the address listed at the end of this Privacy Statement. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-line http://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online
ebm reserves the right to update or change this Privacy Statement from time to time. If we make material changes to this Privacy Statement, we will notify as required by applicable law. Please review the Privacy Statement periodically for any updates or changes that we may have made.
The controller of Personal Information you provide to us is ebenefit Marketplace, LLC, a Connecticut company, located in the United States of America.
You may contact us by the following means:
ebenefit Marketplace, LLC
Attn: ebm InfoSec & Privacy
37 Broadway, 2nd Floor
North Haven, CT 06473
United States of America
You may interact with us in various ways, and when you do, we may exchange information with third parties in addition to those described above.
All other feedback, comments, requests for technical support and other communications relating to the Website should be directed to firstname.lastname@example.org.
Last Updated: May 2018