General Policy Statement

EnrollVB, LLC, its affiliates and subsidiaries, suppliers, and/or licensors, including, but not limited to, Voluntary Employee Benefit Advisors USA, LLC and Willard-Block (collectively, “EnrollVB” and also referred to herein as “we”, “us” or “our”) respects your concerns about privacy and values the relationship we have with you (“you”, “your” or “user”). This online privacy policy statement (this “Statement”) describes your privacy rights regarding our collection, use, storage, sharing and protection of the Personal Information (as defined below) we collect through the services available on the website, [www.enrollvb.com].  It applies to the Website and all related sites, applications, services, and tools regardless of how you access or use them, but it does not apply to any non-EnrollVB website you may access via a link on the Website. 

The Website is intended for a United States audience.  If you access the Website from outside the U.S., you acknowledge, agree, and consent that any information you provide, including any Personal Information, will be transferred to and processed by a computer server located within the U.S. and subject to U.S. laws and regulations.

HIPAA Notice of Privacy Practice

To read more about our privacy practices regarding health and medical information under Health Insurance Portability and Accountability Act (“HIPAA”), please refer to our HIPAA Notice of Privacy Practices in Supplement A of this Statement.

Gramm-Leach-Bliley Act (“GLBA”) Privacy Notice

The GLBA Privacy Notice is provided to help you better understand how we obtain, use, share, and protect your non-public personal financial information (as defined under the GLBA), even after our customer relationship with you has ended. The details of our GLBA Privacy Notice are defined in Supplement B of this Statement.

Social Security Number Protection Policy

EnrollVB may collect Social Security numbers (“SSNs”) as part of its business and this notice applies to any SSNs that we collect in the course of those business activities. It is the policy of EnrollVB to protect the confidentiality of SSNs that we receive or collect in the course of business. We secure the confidentiality of SSNs through various means, including physical, electronic, and administrative safeguards that are designed to protect against unauthorized access. It is our policy to limit access to SSNs to that which is lawful, and to prohibit unlawful disclosure of SSNs.  We strive to protect the confidentiality of the social security numbers that we collect, by limiting access to social security numbers and by maintaining protections against the misuse, loss, or unlawful disclosure of social security numbers.

The Information We Collect

In order for you to use the service offered in the Website, we need to collect various types of information that can be used to identify you. This information will include name, address, e-mail address, social security numbers, telephone, fax numbers, and details relating specifically to any insurance coverage required (collectively “Personal Information”). When you visit the Website, our server will automatically record your domain and IP, the date, time and duration of your visit, and any information you provide by filling in forms on any of our websites. This includes Personal Information provided at the time of registering to use any of our websites. We may also ask you for Personal Information when you report a problem with our Website or if you contact us for any other reason. We may collect information about your computer, including where available, your IP address, operating system, and browser type. IP addresses are not linked to Personal Information. We only use IP addresses to analyze trends, administer our Website, track general user movements, and gather broad demographic information for aggregate use.

How We May Use Your Information

By using the Website and providing your Personal Information, you are agreeing that EnrollVB may store, process, and review such information and that we may use this Personal Information for the purpose for which it was collected.  As used in this Statement, Personal Information refers to information collected about you through your use of this Website, which may include Personal Health Information which is protected under HIPAA.

We may use your Personal Information for a number of purposes, such as:

• To transfer to certain service providers.

• To respond to an e-mail or particular request from you.

• To process an enrollment application as requested by you.

• To provide you with information that we believe may be useful to you.

• To comply with applicable laws, regulations, and legal process.

• To protect someone's health, safety, or welfare.

• To protect our rights, the rights of affiliates or related third parties, or take appropriate legal action, such as to enforce our terms of use.

• To keep a record of our transactions and communications.

• As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law.

• You understand and specifically agree that we may use your Personal Information to contact you through any contact information you provide through this Website, including any email address, telephone number, cell phone number, or fax number.

Disclosure of your Personal Information

We may disclose your Personal Information to third parties:

• Through our secure, online enrollment system that enables certain third-party service providers of employee benefits plans to upload your Personal Information to the system.

• In the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets.

• If EnrollVB, or substantially all of its assets, are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets.

• Where third party vendors act for us for further processing in accordance with the purposes for which the information was originally collected, or for purposes to which you have subsequently consented. For example, sometimes a third party vendor may have access to your Personal Information in order to support our information technology or help obtain, compile and manage the information.

• If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property or safety of EnrollVB, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Information Security

EnrollVB has implemented and adheres to stringent security standards designed to protect Personal Information on our Website against accidental or unauthorized access or disclosure. Among the safeguards that have been developed for this site are administrative, physical, and technical controls that together enhance the security of the information stored at this site.  However, due to the nature of the Internet and on-line communications, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk.

Use of Cookies

Cookies are pieces of information in the form of a small flat file that a website transfers to your hard drive to store and sometimes track information about the use of the website and the aspects of it that interest you. You are not obliged to accept a cookie that we send to you and you can in fact modify your browser so that it will not accept cookies. However, if you select this setting, you may be unable to access certain parts of the Website. For more information about cookies including how to set your browser to reject cookies, please go to www.allaboutcookies.org. We use this information to compile statistical data on the use of our Website, but we do not use the information itself.

Links to Other Third Party Websites

This site may provide links to other third party websites and we are not responsible for the privacy practices of these websites.  This statement applies solely to any Personal Information collected by our Website.

Online Communication Practices

General E-mail Communications

Most e-mail, including any e-mail functionality on our site, does not provide a completely secure and confidential means of communication. It is possible that your e-mail communication may be accessed or viewed inappropriately by another Internet user while in transit. If you wish to keep your information completely private, you should not use e-mail. We may send e-mail communications to you regarding topics such as general employee benefits and Website updates.

Other Online Communications

EnrollVB may send electronic newsletters, notification of account status, and other communications, such as information marketing other products or services offered by us, on a periodic basis to various individuals and organizations. To opt-out of any specific electronic communication you are receiving, follow the instructions provided with the specific communication or contact us using the communication preferences detailed in this Statement.

Modifying and Removing Personal Information

You have the right to ask us not to process your Personal Information for marketing purposes. We will typically inform you if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. If at any time you would like your record and all Personal Information relating to you removed from our system, please contact us using the communication preferences detailed in this Statement. Such removal may not be possible until any current contracts of insurance with you have expired.

Your Acceptance of These Terms

By using this Website, you consent to the collection and use of this information by EnrollVB to this Statement.

Changes to this Website Privacy Statement

If we decide to change the Website's privacy practices, we will post those changes to this Statement, to the home page, and to other places that we deem appropriate so that you are aware of such changes. EnrollVB reserves the right to modify this Statement at any time, so it is your responsibility to review the Statement each time you visit this Website. By continuing to use the Website, you consent to any changes to our Statement.

Contact Details

To contact us regarding this Statement or related privacy practices, please use the communication preferences detailed below.

EnrollVB, LLC
Attn:  Privacy Inquiry
10930 Crabapple Road, Suite 102
Roswell, GA 30075
P:770.709.6499
E:support@EnrollVB.com

Effective Date:

The Effective Date of this Statement is October 8, 2013

Supplement A:

HIPAA Notice of Privacy Practices

This notice describes how health information about you may be used and disclosed and how you can get access to this information. We are required by applicable federal and state laws to maintain the privacy of your Protected Health Information (“PHI”), if applicable. This notice describes our privacy practices and our legal duties concerning your PHI. We will follow the privacy practices that are described in this notice while it is in effect. We reserve the right to change our privacy practices and the terms of this notice at any time and to make the terms of our notice effective for all PHI that we maintain.  Before we make a significant change in our privacy practices, we will change this notice and send the new notice to you.

How We May Use Your Information

Without Specific Authorization

We have the right to use and disclose health information in certain instances. For example, we may use or disclose your health information:

• To You: We must disclose your PHI to you, as described in the Your Rights section of this notice.

• For Payment: For example, we may use and disclose PHI to pay claims for services provided to you by doctors, dentists or hospitals. We may also disclose your PHI to a health care provider or another health plan so that the provider or plan may obtain payment of a claim or engage in other payment activities.

• For Health Care Benefits: For example, we may use or disclose PHI to conduct quality assessment and improvement activities, to conduct fraud and abuse investigations, to engage in care coordination or case management, or to communicate with you about health related benefits and services or treatment alternatives that may be of interest to you. We may also disclose PHI to a health care provider or another health plan subject to federal privacy laws, as long as the provider or plan has or had a relationship with you and the PHI is disclosed only for certain health care operations of that provider or plan. We may also disclose PHI to other entities with which we have contracted to perform or provide certain services on our behalf (i.e. business associates).

• For Public Health and Safety: We may use or disclose PHI to the extent necessary to avert a serious and imminent threat to the health or safety of you or others. We may also disclose PHI for public health and government health care oversight activities and to report suspected abuse, neglect, or domestic violence to government authorities.

• As Required by Law: We may use or disclose PHI when we are required to do so by law.

• For Process and Proceedings: We may disclose PHI in response to a court or administrative order, subpoena, discovery request, or other lawful process.

• For Law Enforcement: We may disclose PHI to a law enforcement official with regard to crime victims and criminal activities.

• Special Government Functions: We may disclose the PHI of military personnel or inmates or other persons in lawful custody under certain circumstances. We may disclose PHI to authorized federal officials for lawful national security activities.

• For Research, Death, and Organ Donation: We may use or disclose PHI in certain circumstances related to research, death or organ donation.

• For Workers’ Compensation: We may disclose PHI as permitted by workers’ compensation and similar laws.

Only After Authorization is Received

You may give us written authorization to use your PHI or disclose it to anyone for any purpose not otherwise permitted or required by law. If you give us an authorization, you may revoke it in writing at any time. Your revocation will not affect any use or disclosure permitted by your authorization while it was in effect.

While the law permits us in certain circumstances to disclose your PHI to family, friends and others, we will do so only with your authorization. In the event you are unable to authorize such disclosure, but emergency or similar circumstances indicate that disclosure would be in your best interest, we may disclose your PHI to family, friends or others to the extent necessary to help with your health care coverage arrangements.

Complaints / Violations

If you are concerned that we may have violated your privacy rights, you may inquire with us using the contact information listed on our privacy notice. You may also submit a written complaint to the U.S. Department of Health and Human Services. We will provide you with the address for the U.S. Department of Health and Human Services upon request. We support your right to protect the privacy of your PHI. We will not retaliate in any way if you choose to file a complaint with us or with the U.S. Department of Health and Human Services.

Supplement B:

Gramm-Leach-Bliley Act Privacy Notice

The GLBA Privacy Notice is provided to help you better understand how we obtain, use, share, and protect your non-public Personal Financial Information.  We are committed to maintaining the confidentiality of your Personal Financial Information. For the purposes of this notice, "Personal Financial Information" means information, other than health information, about an enrollee or an applicant for health care coverage that identifies the individual, is not generally publicly available, and is collected from the individual associated with providing health care coverage to the individual.

The Information We Collect

We collect Personal Financial Information about you and your family when you complete enrollment applications and forms. We also collect information from your dealings with us, our affiliates, or others.  For example, we may receive information about you from participants in the healthcare system, such as your doctor or hospital, as well as from employers or plan administrators, credit bureaus, and the Medical Information Bureau. The information we receive may include such items as your name, address, telephone number, date of birth, Social Security number, premium payment history, and your activity on our Website.  This also includes information regarding your medical benefit plan, your health benefits, and health risk assessments.

Disclosure of your Information

We do not disclose Personal Financial Information about our enrollees or former enrollees to any third party, except as required or permitted by law. In the course of our general business practices, we may disclose Personal Financial Information about you or others without your permission to our corporate affiliates to provide them with information about your transactions, such as your premium payment history.

Information Security

EnrollVB restricts access to Personal Financial Information about you to our employees and service providers who are involved in administering your employee benefits and providing related services.  Among the safeguards that have been developed to protect your Personal Financial Information are administrative, physical, and technical controls that together enhance the security of the information. We conduct periodic assessments of these safeguards to ensure appropriate and secure handling of your Personal Financial Information.

Accessing and Modifying Personal Financial Information

Based on your state of residence, you may have a right to request access to the Personal Financial Information that we maintain. Your right includes the right to know the source of the information and the identity of the persons, institutions, or types of institutions to whom we have disclosed such information.  Your right includes the ability to view such information and copy it in person or request that a copy of it be sent to you by mail.  We may charge you a reasonable fee to cover our costs associated with this request. Your right also includes the right to request corrections, amendments, or deletions of any information in our possession. The procedures that you must follow to request access to or amend your information are as follows:

• Submit a request in writing that includes your name, address, date of birth, member identification number, telephone number, and the recorded information to which you would like access.

• Articulate in the request whether you would like access in person or to have a copy of the information sent to you by mail.

• Upon receipt of your request, we will contact you within 30 business days to arrange providing you with access in person or the copies that you have requested.