Privacy Policy and Notice of Privacy Practices

Important Notice

This notice describes how health and personal information about you may be used and disclosed and how you can get access to this information. Please review it carefully.
 

Purpose

This policy describes the privacy practices of The Vita Companies, as required by the federal Health Insurance Privacy and Portability Act (HIPAA), the California Insurance Information and Privacy Protection Act, and the California Consumer Privacy Act (CCPA).
 

Protecting Your Information

Vita recognizes that your personal information is yours, not ours. We are committed to protecting your privacy, and our policies and practices are designed to do just that. We never rent or sell your personal information to anyone.
 

Protected Information

The HIPAA Privacy Rule governs Protected Health Information (PHI) which is generally health and personal information from a health provider or your health plan. The California Insurance Information and Privacy Protection Act protects Nonpublic Personal Information (NPI) which generally means personal demographic information. The California Consumer Privacy Act protects personal information that identifies you or could reasonably be linked to you or your household.
 

Technology and Information

The insurance and financial services industries are rapidly being shaped by technology that is changing the way we do business. To be successful, we must continue to ensure that our customers are confident in our ability to manage their affairs in a manner that protects each individual’s right to privacy.

Vita clients have access to a broad range of products and services, from employee benefit plans to basic investments and insurance, to pre-tax plans and COBRA administration. To deliver these products and services as effectively and conveniently as possible, it is essential that we use technology to manage and maintain certain information.

Vita engages sophisticated technology platforms and maintains clear business protocols to assure the security of the data we maintain and transmit.
 

Information We Collect or Retain About You

We collect personal, financial, and health-related information that is necessary for the processing of claims, for underwriting or applying for insurance, for securing investments, for fulfilling legal and regulatory requirements, and for assisting clients with policy or administration questions. The type of information we collect and maintain varies according to the products or services we provide for you or your employer.

We maintain pertinent personal identifying data (such as name, birth date, Social Security Number, and marital status) as well as financial information and historical information on policies, plans, or investments. We also maintain records on any health conditions disclosed or provided to us in the process of securing group or individual insurance, while assisting with an insurance policy question, or by an insurance company or health provider’s office.

We may collect non-public personal information as well as Protected Health Information about you from many sources, including information we receive about you on applications or other forms, information about your transactions with us, our affiliates, or others, and information we receive from non-affiliated third parties, including consumer reporting agencies.

Information about your computer hardware and software may be automatically collected by us via the Vita website. This information can include your IP address, browser type, domain names, access times, and referring website addresses. This information is used for the operation of the service, to maintain the quality of the service, and to provide general statistics regarding the use of the Vita website.
 

Information About You That We May Disclose

Vita places strict limits on sharing of specific information with unaffiliated companies about client accounts, PHI, NPI, financial information, and other personal information. We may share information with such companies in the process of securing proposals for products, implementing products or services, providing customer service to participants, or to the extent that it may benefit a client or that a client has requested the product, information, or service. We will only share such information in the course of fulfilling a business obligation. Whenever we do this, we carefully review the company and the product or service to make sure that it provides value to our customers.

Vita may share data with trusted partners to perform statistical analysis, send you emails or postal mail, provide customer support, or arrange for proposals. All such third parties are prohibited from using your personal information except to provide these services to Vita, and they are required to maintain the confidentiality of your information.

Vita may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: conform to the edicts of the law or comply with legal process served on Vita or the site; protect and defend the rights or property of Vita; and/or act under exigent circumstances to protect the personal safety of users of Vita, or the public.
 

Protection of Shared Information

Vita recognizes that a fundamental element of maintaining effective customer privacy procedures is providing reasonable protection against unauthorized access to client information and protected health information. Therefore, we have established appropriate physical, electronic, and procedural security safeguards, and standards to guard against any unauthorized access to customer information. In addition, Vita recognizes the responsibility of protecting data that is shared with other entities or business partners.

If we provide PHI, NPI, or personal information to a third party with which we have a business relationship, we require that the third party implement a Business Associate Agreement confirming they keep all such information confidential, consistent with the conduct of our business relationship.

When we make information available to you over the internet, we use technology such as internet data encryption technology, personalized passwords, and other precautions. We use electronic technology extensively and for a variety of purposes in the course of meeting the business responsibilities that we have been retained to provide. We never use e-mail for solicitation or advertising, and we never sell or otherwise make available your e-mail address to anyone except as may be necessary to provide our products and services to our customers.
 

Marketing – No Sale of Information

Vita does not share your personally identifiable data for marketing purposes. Vita does not rent or sell your personally identifiable data or client lists to other companies or third parties. This policy and practice to not rent or sell any personal data render the Opt-Out provisions of privacy laws moot (as there is no practice of renting or selling data from which to opt-out).
 

Electronic Mail

Vita uses electronic mail extensively to:

  • Correspond with clients on employee benefits strategy, administration, and service issues

  • Transmit flexible spending arrangement Explanations of Benefits and account statements and resolve claim issues.

  • Conduct COBRA eligibility, enrollment, and payment correspondence with carriers.

  • Resolve employee benefits claim issues and correspond about eligibility, enrollment, and payment with carriers and employer clients.

  • Transmit data required for proposals, policy implementation, compliance, and the provision of service to clients.

  • We do not use e-mail for solicitation or advertising. Vita never sells or otherwise makes available your e-mail address to anyone except as may be necessary to provide our products and services to our customers.
     

Protecting Your Personal Information

We want to assure all of our clients and plan participants that whenever personal information is used, it is done with discretion. Safeguarding our clients’ personal information is a very high priority. We maintain physical, electronic, and procedural safeguards that protect your information. The following policies guide us in protecting our customers’ privacy:

  • At Vita, we believe the confidentiality and protection of customer information is one of our fundamental responsibilities. While information is critical to providing quality service, we recognize that one of our most important assets is our customers’ trust.

  • Vita limits the use, collection, and retention of customer information to what we believe is necessary or useful to conduct our business, provide high-quality service, and offer products and services.

  • Access to PHI, NPI, and personally identifiable information for our employees is limited to those with a business reason to know such information.

  • Employees and contractors are educated and trained on the importance of maintaining the confidentiality of customer information. Because of the importance of these issues, all Vita employees are responsible for maintaining the confidentiality of customer information. Employees who violate these policies are subject to disciplinary action.

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: there are security and privacy limitations inherent to the Internet which are beyond our control and the security, integrity, and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed.
 

Security Breach

In the event of a security breach, we will follow the specific procedures outlined in the HIPAA Security Rule. You will be notified to the extent that it is determined that there has been a breach of your PHI. If you have questions, you may contact our Privacy Officer at the address provided at the bottom of this policy document.
 

Cookies

The Vita website may use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server for recordkeeping purposes. For example, a cookie could allow the websites to recognize your browser, while another could store your preferences and other information. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize Vita pages, or register with Vita site or services, a cookie helps Vita to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, mailing addresses, and so on. When you return to the same Vita website, the information you previously provided can be retrieved, so you can easily use the Vita features that you customized.

Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Vita services or websites you visit.

1. Vita Cookies

Vita may place our cookies on your device via our websites and services. Accordingly, our Privacy Policy will apply to our treatment of the information we obtain via our cookies.
 

2. Uses for Vita Cookies

Vita uses cookies for a number of purposes, such as the following:

  • To enable, facilitate and streamline the functioning of our sites across different webpages and browser sessions

  • To simplify your access to and use of our sites and make it more seamless

  • To monitor and analyze the performance, operation, and effectiveness of our sites, so that we can improve and optimize it

  • To show you content that is more relevant to you
     

3. Other Technologies

Our sites may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain anonymous data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.
 

4. Disabling Cookies

Most browsers automatically accept cookies, but you can modify your browser setting to turn off cookies. If you choose to turn off cookies, please note that some interactive features of our sites may not function properly.
 

5. Changes to this Cookie Policy

If there are any material changes to this Cookie Policy, you will be notified by email, on our sites, or by posting a prominent notice on our websites prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our cookie practices. Your continued use of our websites constitutes your agreement to be bound by such changes to this Cookie Policy. If you do not accept the terms of this Cookie Policy, you can discontinue use of our websites or disable cookies and be subject to a potentially degraded experience.

 

GDPR Compliance Statement

Vita is committed to our users’ rights to privacy. The following is a collection of resources regarding your use of our sites and services as well as information about how we may use data.

1. GDPR Compliance

The EU’s General Data Protection Regulations (GDPR) went into effect May 25, 2018, and we support these regulations for a safe and secure browsing experience across the Internet. The details below outline what we are doing to comply with the new regulations.
 

2. Personally Identifiable Information

Our website typically collects two kinds of information about you: information that you provide that personally identifies you and information that does not personally identify you that we automatically collect when you visit our website or that you provide to us. In a few instances, we may require personally identifiable information in order to use certain features of our services. For example, we may ask for an email address to subscribe to one of our newsletters or to download a selected piece of collateral.
 

3. Non-Personal Information

In addition to any personally identifiable information or other information that you choose to provide to us on our website, we may use a variety of technologies, now and hereafter devised, that automatically collect certain non-personal information whenever you visit or interact with our website.

We use non-personal information in a variety of ways, including to help analyze site traffic, understand user needs and trends, carry out targeted promotional activities and to improve our products and services. We may use your non-personal information by itself or aggregate it with information we have obtained from others.

If data collection is not required for the functionality of our site, we do not collect it. At any time, you may request your information to be exported and sent to you for review, and we promptly honor any requests by you to have your information deleted and forgotten, subject to the deletion exemptions outlined below.

 

California Consumer Privacy Act Compliance Statement

The CCPA and the California Privacy Rights Act afford California residents specific rights relative to personal information provided to Vita. Following is an outline of how we apply each of the key rights.

1. Right to Know

Information about the specific information shared with us is outlined in the Privacy Policy and Notice of Privacy Practices. You may also request a copy of your personal data. 
 

2. Right to Delete

Information about this right can be found under the Right to Delete paragraph below.
 

3. Right to Opt-Out

While the right to Opt-Out is maintained, Vita does not sell your personally identifiable data. This policy and practice renders the CCPA Opt-Out provisions moot (as there is no practice of selling data from which to opt out).
 

4. Right to Non-discrimination

We do not discriminate against any employer or plan participant for exercising their rights under the CCPA.
 

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records; and

  • Direct any service providers to delete your personal information from their records.

Please note that we may not be able to comply with requests to delete your personal information if it is necessary to:

  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity

  • Debug to identify and repair errors that impair existing intended functionality

  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law

  • Comply with the California Electronic Communications Privacy Act

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent

  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us

  • Comply with an existing legal obligation

  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information

  • Retain data for ERISA, DOL, and IRS audit purposes.

To the extent that a request to delete does not fall under one of the exceptions, the request will be accommodated. However, it should be noted that in essentially all cases, the data that we retain is required to be maintained under one of the exceptions outlined above.
 

Children Under Thirteen

Vita does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.
 

Changes to this Privacy Policy

Vita reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account and/or by placing a prominent notice on our website. Your continued use of the website and/or services available after such modifications will constitute your acknowledgment and understanding of the modified Privacy Policy and your agreement to be bound by the revised Privacy Policy.
 

Applicability

This Privacy Policy applies to Vita Insurance Associates, Inc. and www.vitacompanies.com and governs data collection and usage. For the purposes of this Privacy Policy all references to Vita include Vita Insurance Associates, Inc. and www.vitacompanies.com. The Vita website provides service descriptions, knowledge articles, and portal access. By using the Vita website, you consent to the data practices described in this statement.
 

Opt-Out Information

If you wish to make corrections to any personally identifiable information you have provided or want to opt-out from receiving future commercial correspondence, including emails, please contact us through one of the inquiry methods provided below. We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable.

 

Inquiries

If you have questions about this Privacy Policy, please contact us through one of the methods outlined below:

The Vita Companies

1451 Grant Road, Suite 200
Mountain View, CA 94040
www.vitacompanies.comEmail: help@vitamail.com

Vita Benefits Group
(650) 968-8811

Vita Administration Company
(650) 966-1492

Vita Planning Group
(650) 567-9300

Securities offered by Vita Planning Group, LLC, Member NASD, SIPC, MSRB




Revision Date: January 2024