FirstEnroll, LLC Privacy Policy

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FirstEnroll, LLC (“FirstEnroll,” “we,” “us,” or “our”) believe that protecting the privacy of our current, former, and prospective customers (who are natural persons), as well as our online visitors, is important.  The following privacy policy (“Privacy Policy”) explains how we collect, use, and disclose personal data (as defined below) from and about you through your interactions with us concerning our services, including your interactions with our website, https://www.firstenroll.com/ (the “Website”).  In this Privacy Policy, we refer to our services and the Website all together as the “Services.”  Please review this Privacy Policy carefully.

The rights discussed in certain sections of this Privacy Policy may be subject to exemptions or other limitations under applicable law. 

By using the Services or otherwise providing us your personal data in connection with the Services, you consent to the collection, use, and disclosure of your personal data in accordance with this Privacy Policy.  If you have any questions about this Privacy Policy, please contact us using the information provided in Contact Us below.

If you are a California resident (as defined below) and your personal information (as defined by the CCPA) is subject to the California Consumer Privacy Act (with any implementing regulations and as may be amended from time to time, “CCPA”), please also review the below section, “Additional Information for California Residents” for additional disclosures, our Notice at Collection, and a description of your rights with regard to your personal information (as defined by the CCPA) and other information related to the CCPA. 

1. The Types of Information We Collect and How We Collect It

FirstEnroll may collect personal data about you when you visit our Website or communicate with us.  “Personal data” for the purposes of this Privacy Policy means any information that can directly or indirectly identify you, either on its own or in combination with other information.  

Personal Data You Provide to Us.  Depending on how you interact with us and the Services, FirstEnroll may collect the following categories of personal data from or about you, including:

• Identifiers and similar information such as a name, address, phone number, date of birth, email address, Social Security number, or other similar identifiers.  

• Additional information protected under certain federal or state laws, like a signature, insurance policy number, credit card, bank account, or other financial information.

• Characteristics of protected classifications under certain federal or state laws, including gender, age, and marital status.

• Internet or other electronic network activity information, including interactions with our Website or use of certain online tools.

Please note that some of this information may be considered sensitive personal data or sensitive personal information under applicable law.

Information We Collect Automatically.  We also collect information about you automatically, which may include personal data.  For example, when you visit the Website, we may collect your IP address, your browser type, your operating system, the pages you view on the Website, and the duration of your visit.  We generally collect this information using cookies.  For more information on our use of cookies and other technologies, please review Our Use of Cookies and Similar Technologies below.  If you communicate with our employees and other staff members via email, telephone, or other electronic channels, our information technology systems record details of those communications, sometimes including their content, for compliance and record-keeping purposes.

Information We Collect from Other Sources.  We may also collect personal data from other sources including our third-party partners and business customers.  For example, we may receive personal data including your name, email address, and Social Security number from our agents when you enroll in our Services.

2. How We Use the Personal Data We Collect

How we use your personal data may vary depending on how you interact with us and our Services.  Generally, we use data we collect about you primarily to provide our Services to you in accordance with any contract with you, communicate with you, and manage and improve our Services for you and our customers, as permitted by applicable law.

FirstEnroll may collect, use, and process your personal data for various business or commercial purposes, including to: 

• Provide you with our Services, including managing and administering our Services;

• Process transactions as necessary to meet our contractual obligations to you;

• Perform our contractual obligations to a customer;

• Comply with our legal or regulatory obligations;

• Improve the Website and learn how visitors use the Website;

• Communicate with you about our Services and support our marketing and advertising initiatives, including providing you with information about our Services and possible changes to this Privacy Policy;

• Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including preventing fraud; and

• Other purposes disclosed at the time you provide your information or otherwise with your consent. 

We may use information for any purpose if the information does not identify you and cannot be combined with other information accessible to us to identify you.

3. How We Share the Personal Data We Collect

Depending on how you interact with us and our Services, FirstEnroll may share your personal data in the following circumstances with the following entities:

• Your Insurance Company.  We may share or otherwise provide your personal data to your insurance company in order to provide our Services.

• Analytics Providers.  We may engage analytics providers to help us understand how users engage with the Website.  These providers may use cookies and similar technologies to collect information about your use of the Website as well as information about your use of other websites over time.  The services we use include, but may not be limited to  Google Analytics, which may provide you with choices about how they collect and use information.  We share personal data with analytics providers to help manage our business effectively.  To learn more about how Google Analytics collects and processes data, please click here.  Google Analytics has its own cookies that it uses to track and aggregate this information.  You can prevent the use of Google Analytics relating to your use of our Website by downloading and installing the browser plugin available here.

• Service Providers.  We may share your personal data with vendors and service providers that perform services on our behalf in association with the operation of our Website and provision of our Services. For example, we may hire other companies to handle payment processing, provide data storage, help us operate the Services or our business, provide technical support, provide call center services, and assist in marketing.

• Consent.  We may share your personal data with your consent or at your direction. 

• Sale or Transfer of Business or Assets.  We may disclose and transfer information we have collected about you in connection with a merger, consolidation, restructuring, the sale or transfer of some or all of our interests and/or assets, or other corporate changes, including in connection with any due diligence process.

• Legal Matters.  We may disclose your information where required to comply with law (including applicable regulations), or to respond to subpoenas, judicial processes, or government requests and investigations, or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law.

• Safety and Security.  We may disclose your information where we believe the disclosure is necessary or appropriate to prevent physical harm or financial loss.  We may also disclose your information to protect the security of the Services, servers, networks systems, and business or as necessary to protect other business or legal interests. 

• Other.  We reserve the right to share your personal data if required or permitted to do so by law.

We may disclose your information to third-parties for the purposes described above in How We Use the Personal Data We Collect. 

Please note that we may also disclose data about you that does not identify you (and cannot be combined with other information accessible to us to identify you) for any purpose.  

We require third-party service providers to protect the confidentiality of personal data and to use such personal data only for the purposes for which it was disclosed to them.  FirstEnroll restricts access to personal data it collects about you to its employees and agents who have been advised as to the proper handling of such personal data and who need to know that personal data in order to provide our Services. 

We do not sell your personal data and have not done so in the last 12 months from the effective date of this Privacy Policy.

Please note that for purposes of this section (“How We Share the Personal Data We Collect”) “sharing” does not mean “sharing” as defined under the CCPA.  For additional disclosures and information on our CCPA practices, please review Additional Information for California Residents below.

4. The Security Measures We Take to Safeguard Information

FirstEnroll has implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.

5. Children’s Privacy

Our Website is intended for use by those over the age of 18, and minors under the age of 13 may not use the Website.  We do not knowingly solicit or collect personal data on the Website from children under the age of 13.  If we learn that, despite these measures, a child under the age of 13 has submitted personal data to us through the Website, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).  If you believe we might have information about your child, please contact us atMSinger@FirstEnroll.com.

6. Retention of Personal Data

FirstEnroll will retain your personal data for as long as we require it to perform our contractual rights and obligations or for our legitimate interests, or for such longer period as required by our legal or regulatory obligations.  In general, we will retain your personal data throughout your relationship with us and for a reasonable period after our relationship with you has ended.  To determine the appropriate retention period for your personal information, we will consider the amount, nature, and sensitivity of the personal information, the potential risk from unauthorized use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, and applicable legal requirements.

7. Links to External Websites

Our Website may contain links to third-party websites.  Any access to and use of such third-party websites is not governed by this Privacy Policy, but, instead, is governed by the privacy policies of those third-party websites.  We encourage you to read the privacy statements of these linked sites as their privacy policy may differ from ours.  FirstEnroll is not responsible for the information practices of such third-party websites.

8. Our Use of Cookies and Similar Technologies

Cookies are small text files that are stored in your computer’s memory and hard drive or in your mobile device or tablet when you visit certain web pages.  They are used to enable websites to function or to provide information to the owners of a website or other third parties that receive data obtained from that website.  Our Website uses cookies and other online tracking technologies (collectively “cookies”) to collect analytics information about your visit to our Website, including Google Analytics.  Service providers, including Google, may provide these tools.  For more information on (a) how Google Analytics collects and processes such information, please click here, and (b) how to prevent the use of Google Analytics relating to your use of our Website by downloading and installing a browser plug-in, please click here.  You can change your cookie preferences by changing the setting on your web browser to delete or reject cookies.  If you delete or reject cookies, some websites may not function properly.

Please note that some of our third-party service providers may use cookies and similar technologies to support the operation of our digital offerings.  These entities may be collecting such information in order to provide services to or for us.  You should be aware that these third-party service providers may have different privacy policies and information security practices; as such, we encourage you to read the privacy statements provided by other websites before you provide personal data to them.

9. Do Not Track

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking.  We do not currently respond to such signals.

Third-parties, such as our analytics providers, may collect data that relates to you on the Website, across time, and over other websites.  We cannot control third-parties’ responses to do-not-track signals or other such mechanisms.  Third-parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies

10. Your Choices and Rights and How to Exercise Them

If you no longer wish to receive marketing materials from us, you can let us know by contacting us at CS@FirstEnroll.com or using other unsubscribe features that we provide in our marketing communications.

Subject to local law, you may have certain additional rights regarding your personal data.  These may include the following rights to:  (i) access your personal data; (ii) correct inaccuracies in the data we hold about you; (iii) delete personal data we have collected from or about you; (iv) receive your personal data in a usable electronic format and transmit it to a third-party; and (v) opt out of the processing of your data for purposes of (a) targeted advertising, (b) the sale of personal data, or (c) profiling in furtherance of decisions that produce legal or similarly significant effects.

If you are a California resident, please review Additional Information for California Residents below for a description of your California-specific rights regarding your personal information. 

How to Exercise Your Rights.  If you would like to exercise the rights you may have with regard to your personal data, contact us at CS@FirstEnroll.com or call us at (732) 440-8600. 

11. Additional Information for California Residents

The CCPA imposes certain obligations on FirstEnroll and grants certain rights to California residents (“California Resident,” “you,” or “your”) with regard to “personal information.”  If you are a California Resident, please review the following information about our privacy practices, including how and why we collect, use and disclose your personal information, our Notice at Collection, and your potential rights with regard to your personal information under the CCPA.  The rights described herein are subject to exemptions under the CCPA and other limitations under applicable law, and are only available to California Residents.

Terms used in this California-specific section have the meaning ascribed to them in the CCPA.  FirstEnroll is a “business.”  

Notice at Collection and Use of Personal Information

Information We Collect 

Depending on how you interact with us, we may collect the categories of personal information listed above in The Types of Information We Collect and How We Collect It.

Purpose for Collection and Use of Information 

We may collect and use your personal information for the purposes listed above in How We Use the Personal Data We Collect.

Sale or Sharing of Personal Information

We do not sell or share your personal information (as such terms are defined under the CCPA).

How Long We Keep Information

We retain your personal information as described above in Retention of Personal Data. 

For more information about our privacy practices, please review our entire Privacy Policy. 

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Our Collection, Use, and Disclosure, of Personal Information and Sensitive Personal Information

Information We Have Collected and Our Purpose for Collecting It

In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information from the categories of sources listed above in The Types of Information We Collect and How We Collect It.  We may collect all or a few of the categories of personal information for the business or commercial purposes identified in How We Use the Personal Data We Collect. 

Our Disclosure of Personal Information

FirstEnroll does not sell or share your personal information (as those terms are defined under the CCPA).  We do not knowingly sell or share personal information of California Residents under 16 years old. 

In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to the following categories of third parties, as describe in the below chart: 

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